Rbc Capital Markets, LLC

Advisory Programs Disclosure Document Form ADV, Part 2A Appendix 1, Wrap Fee Programs Brochure September 30, 2026 This wrap fee program brochure provides information about the qualifications and business practices of RBC Wealth Management (“RBC WM”), a division of RBC Capital Markets, LLC (“RBC CM”). If you have any questions about the contents of this brochure, please contact us at (800) 759-4029. 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. Additional information about RBC CM and RBC WM is available on the SEC’s website at www.adviserinfo.sec.gov. Registration with the SEC does not imply a certain level of skill or training. RBC Wealth Management 250 Nicollet Mall | Minneapolis, MN 55401-1931 (800) 759-4029 | www.rbcwealthmanagement.com PLEASE RETAIN A COPY OF THIS DOCUMENT FOR YOUR RECORDS Investment and insurance products offered through RBC Wealth Management are not insured by the FDIC or any other federal government agency, are not deposits or other obligations of, or guaranteed by, a bank or any bank affiliate, and are subject to investment risks, including possible loss of the principal amount invested. © 2026 RBC Wealth Management, a division of RBC Capital Markets, LLC, registered investment adviser and Member NYSE/FINRA/SIPC. All rights reserved. 26-25-5088800_25213 (09/26) HNW_NRG_B_Inset_NoMask ITEM 2: MATERIAL CHANGES This Form ADV Part 2A wrap fee programs disclosure brochure (the “Brochure“), dated September 30, 2026, contains the following material changes and other updates from the previously amended Brochure dated June 30, 2026. For more details on any specific update, please see the item in this Brochure referred to in the summary below. • In Item 4, the subsection of the RBC Unified Portfolio Program overview titled “Rebalancing of Assets” has been updated to clarify the three rebalancing frequency options (quarterly, annually, or no rebalance), the timing of initial and subsequent account rebalancing, and the circumstances that can result in unscheduled rebalancing of a client’s RBC Unified Portfolio account. • In Item 4, under “RBC Unified Portfolio,” we have updated the subsection formerly titled “Overlay Manager Discretionary Authority” with the new heading “Investment Manager and Overlay Manager Discretionary Authority,” and the addition of language explaining how the services and investment strategies selected determine discretionary authority between the Overlay Manager and the selected Investment Manager(s) for a client’s RBC Unified Portfolio account. • In Item 4, under “RBC Unified Portfolio,” we have updated the disclosures under the subsection titled “Tax Management” relating to clients electing Tax Management services in RBC Unified Portfolio. The updated language clarifies that clients that request the Overlay Manager consider realized gains from assets held outside their RBC UP account when seeking losses to offset gains for the current tax year (“External Gains to Offset”) will need to reset this number every calendar year by contacting their Financial Advisor. • In Item 4, section titled “Eligible Investments; Fund Share Class Selection,” subsection titled “Funds,” we have updated our disclosure as follows: If your Program account includes a share class that is not available in the Program, we may grant an exception for you to continue to hold your existing Fund shares (in the cheaper share class), but you cannot purchase any additional shares of that share class. In such case, you will need to work with your Financial Advisor to select an alternate Fund. In RBC Unified Portfolio, if an exception has been granted for you to retain Fund shares that are not available in the Program and such Fund is included in your target investment allocation, your Overlay Manager (RBC WM or Envestnet) may make additional purchases of such Fund in the share class that is available in the Program. • In Item 4, section titled “Cash Balances and the Cash Sweep Program,” subsection titled “Retirement Accounts,” we have updated our disclosure as follows: Beginning on or after November 9, 2026 (the “Effective Date”), Excess Funds in Retirement Accounts not subject to ERISA will no longer be invested in shares of the Federated Money Market Fund, but will instead be placed into Deposit Accounts at one of the RBC Affiliate Banks, initially CNB, without limit and without regard to the FDIC insurance limit, unless you designate the RBC Affiliate Bank as ineligible to receive your Excess Funds or the RBC Affiliate Bank is unwilling or unable to receive your Excess Funds. In such cases, your Excess Funds will be placed in Deposit Accounts at the other RBC Affiliate Bank, initially RBC Bank. You cannot designate both RBC Affiliate Banks as ineligible to receive your Excess Funds. Any Excess Funds invested in shares of the Federated Money Market Fund on the Effective Date will be liquidated and deposited into an RBC Affiliate Bank. • Information Cash Sweep Program conflicts of interest, previously spread throughout the Brochure, is now consolidated in Item 4 section titled “Cash Balances and the Cash Sweep Program,” subsection titled “Cash Sweep Program Conflicts of Interest.” Further, this section has been revised to add clarity. • In Item 6, the disclosures under the section titled “Related Persons as Investment Manager, Model Provider, and/or Overlay Manager, and Associated Conflicts of Interest” have been updated to add clarity around certain Investment Strategies available in both the Consulting Solutions and RBC Unified Portfolio Programs, including the fees clients pay, and we retain, in each of these Programs and the conflicts of interest that arise relating to our Financial Advisors recommending the use of such Investment Strategies in one of these Programs over the other. • In Item 9, under the section titled “Other Financial Industry Activities and Affiliations,” we have enhanced the following language related to nonpublic information under the new subsection title: “Nonpublic Information.” The updated language is as follows: Nonpublic Information In the course of our respective investment banking or other activities, we and our affiliates may, from time to time, acquire confidential or material nonpublic information about corporations or other entities or their securities that may prevent us or them, for a period, from purchasing or selling particular securities in your Program account. We and our affiliates will not be permitted to divulge or to act upon any such information with respect to our or our affiliates’ advisory or brokerage activities, including activities with regard to your Program account. • In Item 9, the section titled “Other Financial Industry Activities and Affiliations” has been updated with the addition of the following new subsection: RBC Wealth Management Advisory Programs Disclosure Document Page 2 of 46 26-25-5088800_25213 (09/26)  Restrictions on Certain Securities Transactions From time to time, restrictions on certain securities transactions are imposed by RBC CM to address the potential for self-dealing and conflicts of interest that arise in connection with RBC CM ’s broker-dealer and investment banking businesses. RBC CM has adopted various procedures to guard against insider trading that include an “Information Barrier” procedure, pursuant to which information known within one area of RBC CM (e.g., investment banking) is not permitted to be distributed to other areas (e.g., investment advisory), and the use of a restricted list and various other monitoring lists. These investment banking or other activities will from time to time compel RBC CM to forgo investing in (or liquidating) the securities of companies with which these relationships exist. These restrictions may adversely impact the investment performance of an advisory client’s account. • In Item 9, under the section titled “Participation or Interest in Client Transactions,” we have added the following new subsection which contains the following language: RBC CM or its Affiliate(s) in Underwriting Syndicate; RBC WM Distribution of Securities If RBC CM or its affiliate(s) is a member of the underwriting syndicate from which a security is purchased by an unaffiliated Investment Manager, and allocated to your account, we or our affiliates could directly or indirectly benefit from such purchase. If RBC CM participates in the distribution of new issue securities that are purchased for a client’s account by an unaffiliated Investment Manager, RBC CM will receive a fee to be paid by the issuing corporation to the underwriters of the securities and ultimately to RBC CM, which will be deemed additional compensation to us, if received by us. RBC Wealth Management Advisory Programs Disclosure Document Page 3 of 46 26-25-5088800_25213 (09/26)  ITEM 3: TABLE OF CONTENTS ITEM 1: COVER PAGE .............................................................................................................................................................................. 1 ITEM 2: MATERIAL CHANGES ................................................................................................................................................................. 2 ITEM 3: TABLE OF CONTENTS ................................................................................................................................................................ 4 ITEM 4: SERVICES, FEES AND COMPENSATION ................................................................................................................................... 5 Services ............................................................................................................................................................................................................. 5 Advisory Programs ........................................................................................................................................................................................... 7 RBC Advisor Program ................................................................................................................................................................................. 7 Portfolio Focus Program ............................................................................................................................................................................. 7 RBC Unified Portfolio Program ................................................................................................................................................................... 7 Recommendation of Investment Strategy ................................................................................................................................................... 8 Consulting Solutions Program ................................................................................................................................................................... 11 Managed Account Program ....................................................................................................................................................................... 11 Other Disclosures Relating to the Programs ............................................................................................................................................... 12 Other Services .......................................................................................................................................................................................... 12 Funding Program Accounts ....................................................................................................................................................................... 12 Withdrawals from Program Accounts ........................................................................................................................................................ 12 Eligible Investments; Fund Share Class Selection .................................................................................................................................... 12 Cash Balances and the Cash Sweep Program ......................................................................................................................................... 14 Non-Retirement Accounts ........................................................................................................................................................................ 14 Harvesting Gains or Losses ...................................................................................................................................................................... 16 Securities-Based Lending ......................................................................................................................................................................... 17 Fees and Compensation ................................................................................................................................................................................ 18 Fees .......................................................................................................................................................................................................... 18 Calculation of Program Fees; Valuation of Account Assets ...................................................................................................................... 20 Payment of Program Fee .......................................................................................................................................................................... 21 Offset of Certain Fees to Retirement Accounts ......................................................................................................................................... 21 Comparing Costs ............................................................................................................................................................................................ 21 Additional Fees and Expenses ...................................................................................................................................................................... 22 Compensation to Financial Advisors ............................................................................................................................................................ 25 ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ........................................................................................................... 26 ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION ........................................................................................................ 26 Selection of Investment Managers and Model Providers ........................................................................................................................... 26 Monitoring and Review of Investment Managers and Model Providers .................................................................................................... 27 Removal of an Investment Strategy, Model Portfolio, Overlay Manager, or Fund .................................................................................... 28 Related Persons as Investment Manager, Model Provider, and/or Overlay Manager, and Associated Conflicts of Interest ............... 28 RBC WM and Financial Advisors Acting as Portfolio Managers ................................................................................................................ 30 Performance-Based Fees and Side by Side Management ....................................................................................................................... 30 Methods of Analysis, Investment Strategies and Risk of Loss .................................................................................................................. 30 Voting Client Securities (Proxy Voting) ...................................................................................................................................................... 34 ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS .......................................................................................... 35 ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS ................................................................................................................. 36 ITEM 9: ADDITIONAL INFORMATION ..................................................................................................................................................... 36 Disciplinary Information ................................................................................................................................................................................. 36 Other Financial Industry Activities and Affiliations ..................................................................................................................................... 39 Broker-Dealer Registrations ...................................................................................................................................................................... 39 Futures/Commodities-Related Registrations ............................................................................................................................................ 39 Material Relationships with Related Persons ............................................................................................................................................ 39 Other Material Relationships ..................................................................................................................................................................... 41 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................................................................... 42 Code of Ethics and Personal Trading ........................................................................................................................................................ 42 Participation or Interest in Client Transactions .......................................................................................................................................... 43 Review of Accounts ........................................................................................................................................................................................ 44 Client Referrals and Other Compensation ........................................................................................................................................................ 45 Financial Information ........................................................................................................................................................................................ 46 RBC Wealth Management Advisory Programs Disclosure Document Page 4 of 46 26-25-5088800_25213 (09/26)  ITEM 4: SERVICES, FEES AND COMPENSATION RBC Capital Markets, LLC (“RBC CM”), an indirect, wholly owned subsidiary of the Royal Bank of Canada (“RBC”), is a registered investment adviser and broker-dealer with the U.S. Securities and Exchange Commission (“SEC”) and is a member of the Financial Industry Regulatory Authority (“FINRA”), the New York Stock Exchange (“NYSE”), and other major securities exchanges. RBC CM, through its RBC Wealth Management (”RBC WM”) division, offers clients (“you” or “your”) products and services in its capacity as investment adviser, including portfolio management, and as sponsor of various wrap fee advisory programs. For purposes of this brochure, RBC CM and RBC WM will collectively be referred to as “RBC WM,” the “Firm,” “we,” “us,” or “our.” This brochure provides information about RBC WM and the following investment advisory wrap fee programs it sponsors and offers to clients through its “Financial Advisors” (each, a “Financial Advisor”): RBC Advisor, Portfolio Focus, RBC Unified Portfolio (“RBC UP”), Consulting Solutions, and the Managed Account Program (“MAP”) (each, a “Program,” and collectively, the “Programs”). The investment advisory fee(s) you pay will vary depending on the Program you select. In this brochure, the term “Investment Manager” refers to a client’s affiliated or unaffiliated discretionary investment adviser that manages client accounts in accordance with one or more of their investment strategies (each, an “Investment Strategy”) available in the applicable Program. For certain Programs, the Investment Manager may be RBC CM or its affiliates, including (but not limited to) RBC Global Asset Management (U.S.) Inc. (“RBC GAM – U.S.”) and RBC Rochdale, LLC (“RBC Rochdale”). In RBC UP, the term “Overlay Manager” refers to either RBC CM or Envestnet Asset Management, Inc. (“Envestnet”) and the term “Model Provider” refers to RBC WM and affiliated or unaffiliated non-discretionary investment advisers that provide their model portfolio(s) (each, a “Model Portfolio”) for implementation in RBC UP. The term “Funds” includes open-end mutual funds, exchange-traded funds (“ETFs”), exchange-traded notes (“ETNs”), and certain interval funds, unless otherwise specified. Interval funds are a type of closed-end mutual fund that does not trade on a secondary market. Rather, the fund only provides periodic offers to repurchase a limited number of shares. As a result, shareholders may not have access to the invested assets for extended periods of time. Refer to the Interval Fund Disclosure for more information. Information about other advisory and non-wrap fee programs sponsored by RBC WM, including Clearing and Custody Advisory Programs, Retirement Institutional Consulting, and Financial Planning, is contained in separate ADV brochures which are available upon request, from your Financial Advisor, or at the SEC’s website: www.adviserinfo.sec.gov. The Form ADV Part 2A brochure for each Investment Manager, Model Provider, and the third-party Overlay Manager (Envestnet) available in applicable Programs is also available at the SEC’s website at www.adviserinfo.sec.gov. We provide services in the Programs in our capacity as a registered investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). As further discussed below in Items 4 and 5, to obtain services in any of the Programs, you will enter into a written agreement with us that expressly acknowledges our investment advisory relationship with you and describes our obligations to you under each of the Programs. This brochure describes the advisory services that we provide, the fees you will pay, our role and that of our advisory personnel, our other business activities and financial industry affiliations and the economic and other arrangements we have that create conflicts of interest. When you participate in any of the Programs, we are a fiduciary to you under the Advisers Act. As a fiduciary, we act in your best interest and seek to provide you access to material facts and information relating to the Programs and services including by providing this brochure, and material and other updates thereto, to meet our disclosure obligations. In addition, we reasonably expect to provide services as a “fiduciary” (as that term is defined in Section 3(21) (A) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), and/or Section 4975 of the Internal Revenue Code of 1986, as amended (the “Code”)), with respect to retirement accounts. For retirement accounts subject to ERISA that are discretionary accounts managed by us, we provide the relevant services as an “investment manager” (as that term is defined in Section 3(38) of ERISA). For purposes of this brochure, the term “Retirement Account” will be used to cover (i) “employee benefit plans” (as defined under Section 3(3) of ERISA), which include pension, defined contribution, profit-sharing and welfare plans sponsored by private employers, as well as similar arrangements sponsored by governmental or other public employers which are generally not subject to ERISA; and (ii) individual retirement accounts (each, an “IRA”) (as described in the Code). Please see the “Retirement Fiduciary Status Disclosure” on our public website at www.rbcwm.com/disclosures for more information. Assets Under Management As of June 30, 2026, we had $345,747,567,752 in assets under management, $263,708,872,591 of which was managed on a discretionary basis and $82,038,695,161 of which was managed on a non-discretionary basis. Services To open and enroll an account in any of the Programs described herein, clients are required to enter into a written investment advisory agreement with RBC WM known as the “Advisory Master Services Agreement.” RBC WM discontinued the use of its pre-existing “Single Program Agreement” for opening new Program accounts (but some existing Program accounts may have been opened using that Single Program Agreement). The Single Program Agreement and the Advisory RBC Wealth Management Advisory Programs Disclosure Document Page 5 of 46 26-25-5088800_25213 (09/26)  Master Services Agreement shall be collectively referred to herein as the “Advisory Agreement.” As discussed in Item 5, the Advisory Agreement governs the terms of a client’s current and future Program account(s) and relationships with RBC WM and outlines the services to be provided to the client’s account(s) in a Program. As part of the Program account opening process, your Financial Advisor will require you to provide them with certain information, including but not limited to, your risk tolerance, investment objective(s), investment time horizon, and financial situation (when referred to collectively, the “Advisory Risk Profile”). It is each client’s responsibility to verify that the information they provide to RBC WM is, and continues to be, complete and accurate, and to notify their Financial Advisor promptly if any of their information or circumstances change. RBC WM tailors its investment advisory services to the individual needs of Program clients. Based on your Advisory Risk Profile and other information you provide to us during the account opening process, your Financial Advisor will recommend a Program that is suitable and appropriate for you. Not all Financial Advisors may offer all Programs, strategies, or level of services. If your Financial Advisor is not able to offer a particular Program, strategy, or level of service, you may be able to participate through another Financial Advisor. Pursuant to the Advisory Agreement, and as further discussed below, clients pay a quarterly, asset-based, wrap fee (the “Program Fee”) for investment advisory, brokerage execution, and other services rendered under a Program, to RBC WM, typically based on the value of your Program account(s) regardless of the number of trades placed. In certain circumstances, RBC WM may require you to sign additional documentation relating to your Program Fee. The services generally covered by the Program Fee include the investment advisory and Program management services provided by RBC WM (and depending on the Program, investment advisory services provided by the Investment Manager, Model Provider, and/or Overlay Manager), as well as trade execution, clearing, custody, and other administrative and account reporting services provided by RBC WM. Where these services are provided by or through RBC WM, they are included in the Program Fee. Please see the detailed discussion of fees and other costs below under “Fees and Compensation” in Item 4. Certain clients may receive services from a specific team of Financial Advisors, who are collectively referred to as “RBC Advantage.” The RBC Advantage team provides the same level of fiduciary service described in this brochure, though in general, the team offers only those Programs in which RBC Advantage exercises non-discretionary authority. Reasonable Investment Restrictions For all Programs except RBC Advisor (a non-discretionary Program, described below), clients can request that certain reasonable investment restrictions be placed on the management of their Program account(s). Reasonable investment restrictions include restrictions on the purchase and/or sale of certain securities or categories of securities related to a financial sector or industry (e.g., fossil fuels, tobacco). Such restrictions are subject to acceptance by us and, where applicable, the Investment Manager(s) and/or the Overlay Manager(s) as reasonable, in each of their sole discretion. In MAP, clients are responsible for notifying the Investment Manager of any reasonable investment restrictions (and any changes thereto) they wish to impose on their accounts. It should be noted that any reasonable investment restrictions will not apply to the underlying portfolio of any Fund, Alternative Investment, unit investment trust (“UIT”), the subaccounts of annuities, or other similar securities that are held or purchased in a Program account. When an account is terminated from a Program and reverts to a commission-based brokerage account, any previously accepted, client-imposed investment restrictions for that account will also terminate and will no longer be applicable to the account as a brokerage account is outside of the Programs. Where reasonable investment restrictions have been accepted, they can be implemented in various ways, including, but not limited to, increasing the relative proportions of other securities in a portfolio to replace the restricted securities and/ or selecting alternate securities. Any investment restrictions clients impose on the management of their Program account(s) can limit our, the Investment Manager’s, and/or the Overlay Manager’s ability to make investments or take advantage of opportunities. The application of restrictions can cause an account to underperform or overperform relative to similarly invested accounts that have not elected restrictions. Clients are responsible for notifying us of any changes to their investment restrictions. RBC WM will then notify the Overlay Manager and/or Investment Manager of any changes to the investment restrictions. Custody Generally, RBC WM will act as custodian for the assets and securities held in Program account(s). However, in specific circumstances, upon a client’s request and direction and with RBC WM’s consent, a client may arrange for the assets in their Program account to be custodied with certain affiliated or unaffiliated, third-party custodians provided they meet the definition of a “qualified custodian” under the Advisers Act (hereinafter, each a “Third-Party Custodian”). Any such arrangement is not included in the Program Fee paid to RBC WM and the client is responsible for payment of any separate fees and expenses associated with the use of a Third-Party Custodian as agreed upon by and between the client and any such Third-Party Custodian. RBC Wealth Management Advisory Programs Disclosure Document Page 6 of 46 26-25-5088800_25213 (09/26)  Advisory Programs RBC Advisor Program RBC Advisor is a non-discretionary investment advisory Program where you receive ongoing investment advice and recommendations from your Financial Advisor but retain final decision-making authority over the investing activity in your accounts. In RBC Advisor, your Financial Advisor will work with you to determine a suitable investment strategy that’s consistent with your Advisory Risk Profile. Your Financial Advisor will then recommend various investment products including equities, fixed income, Funds, and/or other eligible investments, in accordance with your investment strategy. However, since this Program is non-discretionary, your Financial Advisor will only effect transactions in your RBC Advisor account after receiving your approval. In identifying and selecting investments eligible for recommendation in RBC Advisor, we use various sources of information including, but not limited to, data provided by unaffiliated third parties, research materials, prospectuses, financial publications, and other public filings and reports. As further discussed below in “Eligible Investments; Fund Share Class Selection” in Item 4, while your Financial Advisor has no discretionary authority with respect to RBC Advisor accounts, if you have transferred in a Fund share class that is not eligible for the Program, RBC WM can convert the ineligible Fund share class to an eligible share class of the same Fund without notification to you. An RBC Advisor account is not intended for day trading or excessive trading, including trading in securities based on market timing, and accounts may be restricted or terminated at our discretion upon written notice to you. Further, it is important to note that while RBC WM generally permits clients to place unsolicited orders in RBC Advisor accounts, we have the right, in our sole discretion, to decline to accept or effect any unsolicited orders at any time. Portfolio Focus Program In the Portfolio Focus Program (“Portfolio Focus”), Financial Advisors approved to participate in the Program (“Portfolio Focus Managers”) as agents of RBC WM will provide you with investment advice and portfolio management services on a discretionary basis, in accordance with your Advisory Risk Profile and any other information you have provided to us for your Program account(s). Because Portfolio Focus accounts are advised and managed on a discretionary basis, your Financial Advisor will effect transactions in your Portfolio Focus account without your prior approval. To become an eligible Portfolio Focus Manager, Financial Advisor(s) must meet specific qualification criteria and complete mandatory training prior to being approved to manage accounts on a discretionary basis in Portfolio Focus. See Item 6, “Portfolio Manager Selection and Evaluation,” for further details on this approval process. Based on your Advisory Risk Profile and any other information you have provided for your account (including any reasonable investment restrictions), your Financial Advisor will recommend an investment strategy that is suitable and appropriate for you. Then, your Financial Advisor will manage the assets in your Portfolio Focus account on a discretionary basis in accordance with such strategy, subject to RBC WM’s guidelines for Portfolio Focus. If we determine that your Financial Advisor is no longer eligible to exercise discretion, your Portfolio Focus account will typically be reassigned to a Financial Advisor that is approved to exercise discretion in the Portfolio Focus Program. If reassignment to another Financial Advisor is not feasible, your Portfolio Focus account will be terminated and your account will revert to a client-directed brokerage account, subject to standard, trade-by-trade commissions. Investments generally eligible in Portfolio Focus can include (but are not limited to) equity securities (both foreign and domestic), bonds (both taxable and non-taxable), Funds, Alternative Investments (on a non-discretionary basis, as described below), and other wrap-eligible exchange-traded products (“ETPs”). To assist in the management of Portfolio Focus accounts, we provide Financial Advisors access to various sources of information including, but not limited to, data provided by RBC WM and/or unaffiliated third parties, research materials, financial publications, prospectuses, and other public filings and reports. We may also provide the Financial Advisors with various portfolios which they can consider for discretionary management. Further, it is important to note that while RBC WM generally permits clients to place unsolicited orders in Portfolio Focus accounts, we have the right, in our sole discretion, to decline to accept or effect any unsolicited orders at any time. RBC Unified Portfolio Program The RBC UP Program is a “unified managed account” program in which a single client account can invest in all or some of the following investment products (each, an “Investment Product”), which may or may not be affiliated with RBC WM: eligible Funds, closed-end funds, Model Portfolios managed and provided by Model Providers and/or Investment Strategies managed by Investment Managers. The different Investment Products are held in “sleeves” (each, a “Sleeve”) in a single RBC UP account. Except for Sleeves managed by Investment Managers, Sleeves are managed on a discretionary basis by the Overlay Manager. The Overlay Manager for an RBC UP account will either be RBC WM or Envestnet, a third-party portfolio manager that is not affiliated with RBC WM. In addition to providing discretionary account management, each Overlay Manager provides portfolio implementation, coordination, and other services as specified below. This discretionary authority includes the authority to RBC Wealth Management Advisory Programs Disclosure Document Page 7 of 46 26-25-5088800_25213 (09/26)  implement any Model Portfolio(s), Fund(s) and/or closed-end fund(s) you have selected for your RBC UP account, subject to any reasonable investment restrictions you have requested, and which have been accepted by RBC WM, and the Overlay Manager. The Overlay Manager will not have discretionary authority over Sleeves managed by Investment Managers. The Overlay Manager for your RBC UP account will be determined by the specific services you elect to receive in the Program. If you elect tax management services (“Tax Management”) and/or responsible investing screens services (“Screens”), each as further described below, your account will be managed by Envestnet as Overlay Manager. If you do not select Tax Management or Screens, your account will be managed by RBC WM as Overlay Manager. Recommendation of Investment Strategy Based on your Advisory Risk Profile and any reasonable investment restrictions established by you (and accepted by us and the Overlay Manager as reasonable), your Financial Advisor will recommend a suitable and appropriate investment strategy and target investment allocation for your RBC UP account. The recommended target investment allocation for your RBC UP account will ultimately be comprised of the specific Investment Product(s) that you select from those available in the Program and a target allocation to each such Investment Product. The target investment allocation and Investment Product(s) selected for your account, will be provided to the Overlay Manager and/or Investment Manager(s). You may change the target investment allocation and/or Investment Products for your account by notifying, and discussing any such modifications with your Financial Advisor, who will in turn notify the Overlay Manager and/or Investment Manager(s) of the change. RBC WM will send you written confirmation of such change. As further discussed below under “Eligible Investments; Fund Share Class Selection,” if your target investment allocation includes a Fund share class that is ineligible for the Program, we can update your allocation to the eligible share class of the same Fund without notification to you. If your target investment allocation includes a Fund or closed-end fund that becomes closed to all purchases, or if you do not want to purchase additional shares of a fund included in your target investment allocation, you, or your Financial Advisor if you have granted them discretionary authority, may apply an “alternate fund”. When an alternate fund is applied, no additional shares of the fund will be purchased; however, your Overlay Manager can sell existing shares of the fund. All additional shares will be invested in the alternate fund. Financial Advisor Discretionary Authority If your Financial Advisor is approved for Portfolio Focus, you may grant your Financial Advisor certain limited discretionary authority in RBC UP which includes the authority to: (a) select or change Investment Product(s) for you, (b) select the rebalancing frequency (described below), and/or, (c) define and adjust your target investment allocation based on your Advisory Risk Profile. Conversely, no such discretionary authority can be granted by a client to any Financial Advisor who is not approved to exercise discretion over client accounts (i.e., as an approved Portfolio Focus Manager). If you have granted your Financial Advisor discretionary authority in RBC Unified Portfolio and we determine that your Financial Advisor no longer meets eligibility requirements to exercise discretion your Financial Advisor no longer meets the eligibility requirements to exercise discretion, that Financial Advisor’s discretionary authority will be removed from your account and you will be responsible for approving: (a) the selection and changes to Investment Product(s), (b) the rebalancing frequency, and/or (c) adjust your target investment allocation based on your Advisory Risk Profile. Whereas you, or your Financial Advisor, are responsible for determining the target investment allocation for your account, the Overlay Manager and Investment Manager(s), if applicable, exercises the day-to-day discretion over the account to execute the securities transactions required to conform your account to your strategy, as appropriate. Investment Manager and Overlay Manager Discretionary Authority Investment Managers have discretionary authority over the implementation of their respective Investment Strategies. As such, if you select one more Investment Strategies, the Investment Manager(s) will execute trades in your account’s applicable Sleeve in accordance with the Investment Strategy that you have selected, subject to any investment restrictions you have requested, and which have been accepted by RBC WM and the Investment Manager. The Overlay Manager has discretionary authority over Model Portfolios, Funds and closed-end funds. If your account is comprised of one or more Model Portfolios, the Overlay Manager will manage your RBC UP account in accordance with such Model Portfolios, and any updates thereto, as provided and communicated by the respective Model Providers to the Overlay Manager. While implementing the Model Portfolio, the Overlay Manager will take into account any reasonable investment restrictions as discussed above, or client elected services as discussed below. The Model Portfolios, and changes to the Model Portfolios, are typically implemented by the Overlay Manager as soon as practicable after they are received from the Model Provider. Therefore, reasonable delays may occur between the receipt of Model Portfolio revisions, and the resulting execution of securities transactions by the Overlay Manager for client accounts. Depending on the circumstances (including the extent to which Model Portfolios are widely distributed, the timing in which the Overlay Manager receives revisions to the Model Portfolios RBC Wealth Management Advisory Programs Disclosure Document Page 8 of 46 26-25-5088800_25213 (09/26)  and acts on them, and the trading activity in the securities contained in the Model Portfolios),transactions in client accounts can be subject to significant market impact prior to execution. For example, the implemented Model Portfolio can receive less favorable execution prices, particularly if the overall trading in the securities is large in relation to the securities’ trading volume. Rebalancing of Assets You, or your Financial Advisor, if the Financial Advisor has been granted discretion, will choose from three rebalancing frequencies for your RBC UP account: quarterly, annually or no rebalance. If quarterly or annually is selected, the Overlay Manager will execute trades and coordinate with any Investment Managers, as needed, to bring your account as close to your target investment allocation as practicable. Your first scheduled rebalance will occur one quarter or one year, as applicable, from the date your account is enrolled in RBC UP. If your rebalancing frequency is changed from no rebalance to quarterly or annually, your account will be rebalanced at the time of the change and the rebalance date will be set to the next quarter or year, as applicable. If you, or your Financial Advisor, if the Financial Advisor has been granted discretion, select no rebalance, the account will only be rebalanced upon request. Regardless of the selected rebalance option, 1) your account can be rebalanced at any time when deemed necessary or appropriate by the Overlay Manager to implement the allocation and investments selected or due to other factors that include, but are not limited to, contributions, withdrawals, updates to any Model Portfolio(s) and/or Investment Strategy(s), 2) you, or your Financial Advisor, if the Financial Advisor has been granted discretion, may request that your account be rebalanced. Any unscheduled rebalance of your account will reset the next rebalance date to the next quarter or a year, as applicable. If you have elected to receive Tax Management (described below), Envestnet will evaluate the trade-off between rebalancing the account and the tax consequences of any client specified limits. If your account is not tax-exempt, the sale, redemption, or exchange of investments may result in taxable gains or losses. We will not be liable for any tax consequences or Fund redemption fees (see the Fund’s prospectus) that result from rebalancing. In general, any contributions or withdrawals of assets to or from your account will be applied to the target investment allocation. Tax Management You can elect Tax Management if you are utilizing an equity or Fund Model Portfolio, or any combination thereof. If you elect Tax Management, Envestnet will develop a tax strategy for your account based on the information and instructions, including any limits you provide to RBC WM and RBC WM forwards to Envestnet. The tax strategy Envestnet develops is provided solely in connection with your account. Neither Envestnet nor RBC WM provide tax advice or tax planning services of any kind; clients are urged to consult with their own personal tax advisors for advice specific to their situation. If you elect Tax Management, please consider the following: • Tax Management is limited in scope and is not designed to eliminate taxes in the account. Envestnet can, in light of other considerations in an account, effect transactions even though they may generate tax liabilities, including short-term taxable income, or exceed any of the limits or mandates identified by the client. Envestnet makes no guarantee that tax liability in the account will be reduced or that any indicated limits or mandates will be met. • The use of limits to restrict the amount of capital gains realized can severely restrict trading in the account and could result in substantial deviations from your target investment allocation. Limits should only be imposed on the account after you have consulted with your own personal tax advisor. The limits specified will be used annually until you instruct us and Envestnet otherwise. If you elect Tax Management, your account can perform better or worse than similarly invested accounts that did not elect Tax Management. • You may request that Envestnet consider realized gains from assets held outside of your RBC UP account when seeking losses to offset gains for the current tax year (“External Gains to Offset”) by contacting your Financial Advisor. The External Gains to Offset number you provide expires at the end of each calendar year; therefore, you must contact your Financial Advisor to reset this number for each calendar year. • When providing Tax Management, Envestnet avoids net short-term capital gains where possible, but does not limit net long-term capital gains. • If your account is funded with positions that have long-term capital gains and you have not set a long-term capital gain limit, then all long-term tax lots of securities that are not included in your equity Model Portfolio(s) will be sold, which will cause you to incur long-term capital gains. • If Fund Model Portfolios, or Envestnet’s Quantitative Portfolios, are included in your target investment allocation, existing Fund positions held in your account may be able to be retained for tax reasons, regardless of whether they are part of such Fund Model Portfolios, or Envestnet Quantitative Portfolios. The Fund positions that are retained may have a higher cost. However, if you are not invested in Fund Model Portfolios, or Envestnet Quantitative Portfolios, any existing Fund positions held in your account that are not included in your target investment allocation will be sold upon Program account opening regardless of tax consequences. RBC Wealth Management Advisory Programs Disclosure Document Page 9 of 46 26-25-5088800_25213 (09/26)  • You may cancel Tax Management at any time. Cancelling Tax Management may result in the recognition of significant taxable capital gains or losses. If you cancel Tax Management, but your account maintains or enrolls in Screens, Envestnet will continue to act as Overlay Manager. If you cancel Tax Management, and your account is not enrolled in Screens, RBC WM will become your Overlay Manager. • Significant investment allocations to certain Fund Model Portfolios may result in less effective Tax Management. For example, Envestnet has less flexibility in managing a client’s tax strategy where a client is invested in a Fund Model Portfolio with frequent, tactical changes, thereby making it difficult to evaluate the portfolio’s tracking error. • Accounts that include Investment Products not eligible for Tax Management (e.g., Funds, closed-end funds and/or bond Model Portfolios, Investment Strategies) may still elect Tax Management, but Tax Management will not be applied to those Investment Products. Envestnet performs an automated year-end tax loss harvest review. For accounts with Tax Management that have net realized gains for the year, securities in equity Model Portfolios are reviewed for harvesting. Starting with the largest percentage loss tax lots that are available to sell (i.e., there is no known wash sale or other sale restriction on the tax lot or security), Envestnet will harvest losses until the account’s net realized gains are eliminated, or all available tax lots with losses greater than 10% are harvested. The sales proceeds are invested in other Model Portfolio holdings and/or cash. This review process typically occurs in early December and is intended to harvest losses while minimizing the impact to the integrity of the investment allocation. Envestnet’s ability to harvest losses is dependent on account circumstances and market environment, among other factors. If your account is enrolled in Tax Management, you may not separately request that Envestnet harvest gains or losses in your account. Except when Envestnet’s Quantitative Portfolios are included in your investment allocation, Envestnet will only seek to harvest losses from equity Model Portfolios and Fund Model Portfolios. Envestnet will not seek to harvest losses from Funds, closed-end funds, or bond Model Portfolios. When the equity Model Portfolios in a client’s target investment allocation are solely Envestnet’s Quantitative Portfolios, and they comprise at least 35% of the client’s total target investment allocation, the client can select Envestnet’s “Portfolio Diversification Solution,” an additional Tax Management service. Envestnet’s “Portfolio Diversification Solution” is a Tax Management service designed to transition a client’s current holdings to their target investment allocation over a longer period of time (subject to any maximum imposed by Envestnet) than might otherwise be allowed based on Envestnet’s standard tracking error thresholds. For these purposes, tracking error measures the difference between the performance of Model Portfolios when used in accounts with Tax Management and when used in accounts without Tax Management. With Envestnet’s Portfolio Diversification Solution, there are no limits on the initial tracking error provided that the selected tax budgets will allow full transition to the target investment allocation within the determined time period. Tracking error will be higher at the beginning of the transition and will decline over time as capital gains are realized and the client’s investments become increasingly more in line with the target investment allocation. You should consult your own personal tax advisor before enrolling in Tax Management and providing any tax information to RBC WM and Envestnet. For more information on Tax Management, please refer to Envestnet’s ADV which is available upon request or at the SEC’s website: www.adviserinfo.sec.gov. Responsible Investing Screens Screens are available to you if you are utilizing an equity Model Portfolio. Clients may restrict their accounts from investing in certain securities or industries by selecting Screens for their account(s). Envestnet relies on third-party data research providers for industry and socially responsible classifications of individual securities, and Envestnet and RBC WM make no guarantee as to the accuracy of such third parties’ classification. The third-party data research providers of these classifications apply different definitions and criteria from other similar providers, which can generate different responsible investing ratings that, when applied, could result in the restriction of different securities (i.e., there is no single industry definition or uniformly applied criteria that inform the Screens). If a third-party data research provider changes the classification of an individual security, Envestnet will make reasonable efforts to implement those changes in a timely manner. Envestnet may implement restrictions by, for example, increasing the relative proportions of other securities to replace the restricted securities and/or selecting alternate securities. Many of the Screens have both a “Best in Class” and “Strict” restriction. Best in Class restrictions are designed for investors seeking to achieve alignment between their values and the prudent management of their investments, while Strict restrictions are designed for investors who want to integrate more stringent environmental/social criteria into their investments by minimizing exposure to companies with specific products, services, and/or operations that do not meet the investor’s personal values criteria. Screens will only be applied to equity Model Portfolios and not to other Investment Products in a Program account. The application of Screens can cause an account to underperform or overperform when compared to similarly invested accounts that have not elected Screens. RBC Wealth Management Advisory Programs Disclosure Document Page 10 of 46 26-25-5088800_25213 (09/26)  In addition to the Screens discussed above, in certain circumstances, as directed by the client, Envestnet will facilitate the implementation of other responsible investing screening approaches in your account. If you, or we, elect other responsible investing screening approaches, your account will be managed by Envestnet as Overlay Manager. Consulting Solutions Program In the Consulting Solutions Program, your Financial Advisor will assist you in selecting one or more Investment Managers and one or more of their Investment Strategies (each, an “Investment Strategy”) from those RBC WM has made available in this Program. Upon consultation with you, your Financial Advisor will provide you with recommendations regarding Investment Managers and their Investment Strategy or Investment Strategies that they believe are suitable and consistent with your Advisory Risk Profile. The Investment Managers made available to clients through this Program include both affiliated and non-affiliated Investment Managers who meet the Firm’s eligibility requirements for participation as detailed below in Item 6: “Portfolio Manager Selection and Evaluation.” In Consulting Solutions, you are responsible for the ultimate selection of the Investment Manager and Investment Strategy; neither RBC WM nor your Financial Advisor have discretionary authority with respect to the selection of your Investment Manager or Investment Strategy. The Investment Manager has discretionary authority over your account and will implement the investment decisions for your account in accordance with the selected Investment Strategy, subject to any investment restrictions you have requested, and which have been accepted by RBC WM and the Investment Manager. In Consulting Solutions, the Advisory Agreement that you sign is between you and RBC WM; you do not sign a separate agreement with the Investment Manager. Several direct indexing Investment Strategies are available in Consulting Solutions. Investment Managers who offer direct indexing Investment Strategies typically require that accounts enrolled in such Investment Strategies they manage be set to a Highest Cost, First Out (“HIFO”) tax lot accounting method. If you elect to enroll your account and invest in a direct indexing Investment Strategy, RBC WM will change the tax lot accounting method of your account to HIFO upon your written consent before your enrollment in such direct indexing Investment Strategy (if it was not already set to HIFO). If you terminate the Investment Strategy or your Consulting Solutions account, the tax lot accounting method for your account will remain HIFO unless you provide written instruction to RBC WM to change the tax lot accounting method for your account. Managed Account Program MAP is primarily designed to accommodate clients who wish to maintain a relationship with an Investment Manager and/or to invest in an Investment Strategy not otherwise available in Consulting Solutions or RBC UP (as applicable), and to receive certain brokerage and/or other services from us. From time to time, clients may elect to enroll in MAP to invest in an Investment Strategy available through Consulting Solutions or RBC UP. Such scenarios can arise where, for example, a client prefers to invest directly with an Investment Manager that we currently only make available as a Model Provider in RBC UP and not as an Investment Manager in Consulting Solutions, where a client’s particular situation necessitates certain customizations that cannot be accommodated in the other Programs, or where a client has negotiated a lower fee for the Investment Strategy than they would in the other Programs. In MAP RBC WM has engaged Due Diligence Works, Inc. (“DDW”), a third-party service provider, to provide independent due diligence and monitoring of Investment Managers and Investment Strategies selected by clients through MAP. In MAP, in consultation with your Financial Advisor, you select an Investment Manager (and one or more of their Investment Strategies) that you believe is appropriate and consistent with your Advisory Risk Profile, to manage your account(s) on a discretionary basis in accordance with the Investment Strategy you have selected. The decision to participate in MAP and selection of the Investment Manager(s) is your responsibility, regardless of whether your relationship with an Investment Manager predates your relationship with RBC WM and/or your current Financial Advisor. You will instruct RBC WM to accept orders from your Investment Manager(s) for your MAP account(s). We will not have any discretionary authority over the assets in your MAP account. If you select an Investment Manager and/or Investment Strategy not already being utilized in MAP, RBC WM will perform an initial review of the Investment Manager and/or Investment Strategy to confirm it meets MAP Program guidelines and can be operationally supported. If so, DDW will conduct an independent due diligence review of the Investment Manager and Investment Strategy. After DDW’s review, RBC WM will decide whether to make an Investment Manager and Investment Strategy available in MAP. Based on DDW’s ongoing monitoring, we may remove an Investment Manager and/or Investment Strategy from MAP. If you do not reallocate applicable account assets prior to the termination date provided by RBC WM, we may terminate your Program and your account will revert to a commission-based brokerage account. In addition to the Advisory Agreement between you and RBC WM, you will execute a separate investment advisory agreement directly with your selected Investment Manager(s). You are solely responsible for negotiating such agreement with the Investment Manager(s). RBC WM will not participate or advise you regarding the terms of such agreement, the advisability of entering into RBC Wealth Management Advisory Programs Disclosure Document Page 11 of 46 26-25-5088800_25213 (09/26)  such agreement, or of continuing the retention of your Investment Manager(s). You are also responsible for payment of each Investment Manager’s fee, which is negotiated separately between you and the selected Investment Manager(s). We strongly encourage you to contact your Investment Manager(s) periodically to discuss your MAP account and its investment performance, discuss any investment restrictions you may wish to impose or modify on your account, request information regarding conflicts of interest between you and your Investment Manager(s), receive a current copy of your Investment Manager’s Form ADV filing and/or brochure for your review, and review your Investment Managers’ investment style and philosophy so you can determine the ongoing suitability and consistency of your Investment Manager(s) with your Advisory Risk Profile. Other Disclosures Relating to the Programs The following disclosures generally apply to all the Programs, unless noted otherwise. Other Services In limited circumstances, upon written agreement between you and RBC WM, and in some instances for a separate fee, RBC WM may provide one of more of the following non-discretionary services to certain Retirement Account clients in certain Programs: • assist in creating, monitoring and/or updating from time to time a client’s investment policy statement; • provide an asset allocation review designed to identify one or more investment portfolios based on information provided by client; • assist in evaluating and selecting other services providers including third-party administrators, trustees, and/or custodians; • conduct group meetings with retirement plan participants to provide education about plan features, enrollment procedures and investment options; and/or • review the retirement plan design and make recommendations to improve plan efficiencies and reduce administrative costs. Funding Program Accounts You can fund your Program account by depositing cash and/or securities acceptable to RBC WM (subject, for Retirement Accounts, to any limitations imposed under the retirement plan documents, ERISA, or the Code, as applicable). The investment of assets in a Program account will only occur when all operational requirements have been met. Deposits of cash and/or securities into Consulting Solutions, RBC UP, or MAP accounts will be invested by the Investment Manager or the Overlay Manager, as applicable, as soon as reasonably practicable. The management of a new Program account will begin after RBC WM has accepted the account into a Program and, as applicable, after the Investment Manager or Overlay Manager has accepted the account. At the time of Program enrollment, account acceptance could be delayed or rejected if the account is underfunded, funded with ineligible securities, and/or for other operational reasons. If you fund your Consulting Solutions, RBC UP, or MAP account with securities, the Investment Manager or Overlay Manager (which may be RBC WM), as applicable, will liquidate the securities on your behalf, or request that RBC WM liquidate the securities on your behalf, and allocate the proceeds in accordance with the Investment Strategy or Investment Products you have selected. Depending on the type of security involved, liquidation may result in redemption charges and/or taxable gains or losses. RBC WM will not be liable for any lost opportunity profits that may result from investing or liquidating deposits. Withdrawals from Program Accounts Withdrawals from a Program account will be taken first from any free credit cash balances and then from cash balances in your Cash Sweep Option. If the liquidation of securities is required to effect a withdrawal, trades will be implemented as soon as practicable, although they may be delayed depending on market volatility, the Program in which your account is enrolled, and/or the types of securities held in your account.. Frequent withdrawals from your Program account may affect the performance and the investment objective of your account. Taxable gains and losses may be realized as result of your withdrawal instructions. RBW WM reserves the right to terminate a Program account if a withdrawal or series of withdrawals results in the account assets falling below the Program minimum. Eligible Investments; Fund Share Class Selection RBC WM may restrict the purchase or holding of certain investments in Program accounts. If a Program account is funded with investments deemed to be ineligible, RBC WM, the Investment Manager and/or Overlay Manager, as applicable, will generally liquidate such investments, move such investments to an eligible account as instructed by you, or in the case of Funds, convert such investments to an eligible share class of the same Fund without notice to you. Your account may incur certain transaction charges as a result. RBC Wealth Management Advisory Programs Disclosure Document Page 12 of 46 26-25-5088800_25213 (09/26)  Funds In identifying and selecting Funds eligible in the Programs, we may use many sources of information and analysis about Funds, including data provided by third parties. We determine which Fund share classes are available in the Programs based on a number of factors, including, but not limited to, availability, eligibility requirements, and payment of Operational Support and/or Marketing Support to us (as described below in the “Fund Fees and Expenses” section). We do not always make the lowest cost share class available to you. Lower cost share classes may be available to you elsewhere, including, but not limited to, through other broker-dealers or registered investment advisers to which RBC WM provides clearing, custody, and execution services. Where RBC WM offers a lower cost share class than the designated eligible share class for the Programs, in certain circumstances, RBC WM may grant exceptions for clients to hold their existing share class and for institutional clients to purchase the lower cost share class option. In accordance with applicable regulations, we will make a Fund’s current prospectus accessible to you when you purchase shares of the Fund through us. Fund companies can offer various share classes of a Mutual Fund which allows investors to access the same strategy or portfolio of assets through different types of shares within the same Mutual Fund, each with a unique fee structure, investment requirement, and suitability for different investors. Some share classes may be cheaper than the share classes available in the Program. If your Program account includes a share class that is not available in the Program, we may grant an exception for you to continue to hold your existing Fund shares (in the cheaper share class), but you cannot purchase any additional shares of that share class. In such case, you will need to work with your Financial Advisor to select an alternate Fund. In RBC Unified Portfolio, if an exception has been granted for you to retain Fund shares that are not available in the Program and such Fund is included in your target investment allocation, your Overlay Manager (RBC CM or Envestnet) may make additional purchases of such Fund in the share class that is available in the Program. If your account is not tax-exempt, the redemption or exchange of Fund shares can result in taxable gains or losses. RBC WM does not provide tax, legal or accounting advice and, therefore you should consult your own personal tax, legal or accounting advisors for such advice. We are not liable for any tax consequences or redemption fees that can result from rebalancing. Compensation differences between product types may create a conflict of interest for RBC WM and its Financial Advisors as there may be an incentive to make products available that pay higher compensation. For a discussion of fees and certain conflicts of interest associated with Fund share class selection, please see the section below titled, “Fund Fees and Expenses.” Please see the section above titled “Eligible Investments; Fund Share Class Selection” for more information. Annuities Annuities purchased with a commission may be linked to your Program account statement for informational purposes only. In such cases, these annuities are not considered advisory assets covered under the Advisory Agreement and are not subject to the Program Fee. In limited certain circumstances, upon written agreement with RBC WM, annuities purchased without a commission through a fee-based advisory relationship will be covered under the Advisory agreement and subject to the Program Fee. In such cases, your Financial Advisor will provide you with non-discretionary advisory services with respect to that annuity and any underlying annuity contract fees as outlined in the prospectus or statement of understanding will be addition to the Program Fee. Annuities not subject to a written agreement with RBC WM as described above may be linked to your Program account statement for informational purposes only. In such cases, these Fee-Based Annuities are not considered advisory assets covered under the Advisory Agreement and are not subject to the Program Fee. Consequently, RBC WM and your Financial Advisor have an incentive to recommend an exchange of any annuities you own that are not subject to the Program Fee to an investment that is subject to the Program Fee or to an investment, including an annuity, that pays RBC WM and your Financial Advisor a brokerage commission. Alternative Investments Alternative investment (“Alternative Investment”) refers to an investment, as designated by us, with risk and return characteristics not generally correlated with traditional investments (i.e., equities, fixed income and cash), including but not limited to, hedge funds, managed future funds, non-traded REITS and non-traded business development companies, private equity funds, exchange funds, and 1031 exchange funds, and for which RBC WM has conducted due diligence and approved to make available to clients. Alternative Investments are sold by offering documents (e.g., private placement memorandum or prospectus; limited partnership agreement; and subscription agreement) prepared by the Alternative Investment manager. Alternative Investments are available in RBC Advisor and Portfolio Focus on a non-discretionary basis. Clients must authorize the commitment to, and purchase of, the Alternative Investment by executing a written agreement (e.g., subscription agreement) with the Alternative Investment manager. Additionally, Alternative Investments are only available to certain clients who meet applicable eligibility and suitability requirements. Alternative Investment managers engage and compensate various service providers related to operating the fund (e.g., fund administrator, custodian, lender, trading platform, etc.). RBC or an affiliate (e.g., CNB or RBC CM, etc.) may act as a service provider to an Alternative Investment. As a result, RBC or an affiliate may benefit when RBC US WM recommends the Alternative Investment to clients. RBC Wealth Management Advisory Programs Disclosure Document Page 13 of 46 26-25-5088800_25213 (09/26)  Alternative Investment feeder funds may be created to provide a way for investors to pool capital to invest into a larger, often exclusive, master fund investment opportunity. The feeder fund feeds capital into the master fund which then executes the investment strategy. In some cases, fund managers may only allow individual investors, including RBC WM clients, access to their investment strategy via a feeder fund though it is possible a client may be able to access the strategy via the direct fund through another firm. Feeder funds are generally more expensive to the client than direct funds because they include an additional layer of fees when compared to the direct fund. Cash Balances and the Cash Sweep Program Events such as deposits, the sale of securities, and/or other similar activity can generate uninvested cash balances in your account. Pursuant to your brokerage account agreement with RBC WM (the “Client Account Agreement”), you have the option to have uninvested cash balances in your account(s) automatically deposited, on a daily basis, into an interest- bearing deposit account, a specified money market mutual fund, or a non-sweep cash investment alternative (each, a “Cash Sweep Option,” and collectively, the “Cash Sweep Options”). Upon notice to you, RBC WM may add, remove, or change the Cash Sweep Options available through the Cash Sweep Program (hereinafter, the “Cash Sweep Program”). As discussed below, the different available Cash Sweep Options are subject to eligibility requirements and restrictions. You should review your Client Account Agreement and related Cash Sweep Program disclosures for details regarding the Cash Sweep Options. For additional information and disclosures on the Cash Sweep Options, refer to the links under “Cash Management” on our public website at www.rbcwm.com/disclosures. The Cash Sweep Options available for selection by Program clients only apply to Program accounts for which we are the custodian; in other words, Program accounts, and the uninvested cash balances within those accounts, held with and utilizing the services of a Third-Party Custodian are not covered by the Cash Sweep Program. As such, clients utilizing a Third-Party Custodian are responsible for separately establishing appropriate sweep arrangements with that Third-Party Custodian. The Cash Sweep Options available to you will depend, in part, on the type of account you have opened. You should consider the investment objectives, risks, charges, and expenses of the Cash Sweep Option(s) available to you before making a selection. Please read any related disclosures, including prospectuses (as applicable), carefully before investing to make sure your selected Cash Sweep Option is appropriate for your goals and risk tolerance. Non-Retirement Accounts Cash held in non-retirement accounts will be swept into the Cash Sweep Option you choose. The available Cash Sweep Options for non-retirement accounts are: RBC Insured Deposits. RBC Insured Deposits is a Cash Sweep Option that automatically deposits, or “sweeps,” available cash balances in your Program account into interest-bearing deposit accounts (“Deposit Accounts”) established for you at participating depository institutions (“Program Banks”), whose deposits are insured by the FDIC up to applicable limits, subject to bank capacity (“Deposit Limit”). The Program Banks include unaffiliated, third-party banks and two affiliated banks, RBC Bank (Georgia), N.A. (“RBC Bank”) and City National Bank (“CNB”) (together, “RBC Affiliate Banks” or “Affiliate Banks”). Funds in RBC Insured Deposits are not subject to market risk and potential value loss, but they are subject to the risk of a Program Bank’s failure. RBC WM is not an FDIC-insured depository institution and FDIC insurance only protects against the failure of a Program Bank. FDIC insurance available in RBC Insured Deposits is subject to certain conditions. A list of Program Banks is available at www.rbcwm.com/rbc-insured-deposits-program-banks. The RBC Insured Deposits terms and conditions are available at www.rbcwm.com/rbc-insured-deposits. More information regarding FDIC insurance is available at www.fdic.gov. In the event a Program Bank fails, deposits at each Program Bank are eligible for FDIC coverage up to applicable limits. However, deposits at each Program Bank are not protected by the Securities Investor Protection Corporation (“SIPC”) or any excess coverage purchased by RBC CM. Cash balances in RBC Insured Deposits in excess of applicable limits (“Excess Funds”) are swept into one or more other banks (“Excess Banks”), which will accept funds without limitation and without regard to the FDIC limit, and which may be RBC Affiliate Banks. Currently, the primary Excess Bank is CNB. Credit Interest Program. The Credit Interest Program (“CIP”) is a non-sweep cash alternative and represents our direct obligation to repay the invested amount, on demand, plus interest. We invest and use CIP assets as free credit balances for our benefit, and we periodically adjust the interest rate payable on CIP accounts. We use these funds in the ordinary course of our brokerage business, subject to the requirements of Rule 15c3-3 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). The difference between amounts earned by us from our investments and the rate we pay to CIP account holders is our profit. Cash invested in the CIP is protected by SIPC up to $250,000 per account on claims for cash. SIPC protects against the custodial risk (and not a decline in market value) when a brokerage firm fails by replacing missing cash up to the $250,000 limit. Retirement Accounts Cash balances held in Retirement Accounts subject to ERISA or Section 4975 of the Code will bear a reasonable rate of interest as required under the prohibited transaction exemptions of ERISA and the Code that permit the investment of such Retirement Account assets in deposits of Affiliated Banks. RBC Wealth Management Advisory Programs Disclosure Document Page 14 of 46 26-25-5088800_25213 (09/26)  • ERISA Retirement Accounts. Cash held in Retirement Accounts subject to ERISA will be swept into the Federated Money Market Fund. • Non-ERISA Retirement Accounts. Cash held in Retirement Accounts, excluding Retirement Accounts subject to ERISA, will be swept into RBC Insured Deposits and will be placed into Deposit Accounts at our Affiliate Banks up to applicable limits, as discussed in the RBC Insured Deposits program terms and conditions. Excess Funds in non-ERISA Retirement Accounts in RBC Insured Deposits will be automatically invested in shares of an unaffiliated money market fund, the Federated Hermes Treasury Obligations Fund (the “Federated Money Market Fund”), unless you designate the Federated Money Market Fund as ineligible. You may access the most recent Federated Money Market Fund prospectus by contacting your Financial Advisor or by accessing Federated Investment Management Company’s website at www. federatedinvestors.com/products/mutual-funds/treasury-obligations/as.do. If you designate the Federated Money Market Fund as ineligible to receive your Excess Funds, the available Excess Funds will be swept into a designated Excess Bank, which will accept funds without limitation and without regard to the FDIC insurance limit. Currently, the primary Excess Bank is CNB. However, beginning on or after November 9, 2026 (the “Effective Date”), Excess Funds in Retirement Accounts not subject to ERISA will no longer be invested in shares of the Federated Money Market Fund, but will instead be placed into Deposit Accounts at one of the RBC Affiliate Banks, initially CNB, without limit and without regard to the FDIC insurance limit, unless you designate the RBC Affiliate Bank as ineligible to receive your Excess Funds or the RBC Affiliate Bank is unwilling or unable to receive your Excess Funds. In such cases, your Excess Funds will be placed in Deposit Accounts at the other RBC Affiliate Bank, initially RBC Bank. You cannot designate both RBC Affiliate Banks as ineligible to receive your Excess Funds. Any Excess Funds invested in shares of the Federated Money Market Fund on the Effective Date will be liquidated and deposited into an RBC Affiliate Bank, as described above. Money Market Funds in the Cash Sweep Program The Federated Money Market Fund is offered in the Cash Sweep Program, as described above. Certain clients may have remaining balances in a money market fund we no longer offer as a Cash Sweep Option (as described below in the section titled “Material Relationships with Related Persons”). Money market funds will usually pay a higher rate of interest on cash balances than RBC Insured Deposits or the Credit Interest Program. Other financial institutions may offer cash sweep options that pay you a higher rate of interest than is available in our Cash Sweep Program. You can also receive higher rates on cash balances outside of the Cash Sweep Program by investing directly in money market funds or other cash alternatives; however, such direct investments must be directed by you, or your Financial Advisor authorized to act with discretion, and will not be invested automatically. For more information about the Cash Sweep Options available to you, please refer to your Client Account Agreement, the “RBC Insured Deposits” disclosure pages which can be found at www.rbcwm.com/disclosures, and/or the prospectus of the Federated Money Market Fund. Interest Rates In RBC Insured Deposits, Program accounts receive a separate interest rate from brokerage accounts. The interest rates for RBC Insured Deposits balances are tiered based upon the total assets in all accounts in a client’s household (as defined in the Client Account Agreement), including Program and brokerage accounts, as well as the value of balances held in RBC Insured Deposits across a client’s household. Current RBC Insured Deposits interest rates are set forth on our public website under “Program Interest Rates” at www.rbcwm.com/rbc-insured-deposits. Interest rates are variable and subject to change without notice. Cash Sweep Program Conflicts of Interest RBC WM has a conflict of interest in offering the Cash Sweep Options because RBC WM and/or our affiliates receive compensation or benefits from cash balances swept to these Cash Sweep Options, in addition to the Program Fee assessed on Program accounts. This conflict of interest is greater when higher cash balances are maintained in your account. This creates an incentive for RBC WM to offer these Cash Sweep Options and to encourage deposits in these specific Cash Sweep Options. At times, however, we and/ or the Investment Manager(s) or Model Provider(s) may believe it is in your best interest to maintain assets in cash, particularly for defensive purposes in volatile markets. We address these conflicts of interest through proper disclosure and by also offering in RBC Insured Deposits the ability to opt-out of having your deposits maintained at Affiliate Banks for non-retirement accounts. • The Program Fee. We charge the Program Fee on cash balances in your Program account(s) and we and/or our affiliates receive benefits from amounts invested in the Cash Sweep Options. This means that we and/or our affiliates earn two levels of fees on the same cash balances in your account. • RBC Affiliate Banks. For non-Retirement Accounts, RBC Affiliate Banks pay RBC WM an annual per- account fee for each account enrolled in RBC Insured Deposits. RBC WM receives such fees in addition to the Program Fee you pay to RBC WM. This creates a conflict of interest for RBC WM because we have an incentive to maintain and direct uninvested cash in RBC Wealth Management Advisory Programs Disclosure Document Page 15 of 46 26-25-5088800_25213 (09/26)  your account into Deposit Accounts at our Affiliate Banks where they use such deposits to generate additional revenue for themselves. Our Affiliate Banks make a profit on the difference, or “spread,” between the interest they pay and other costs they incur on deposits, and the interest or other income they earn using the deposits for loans, investments, and the purchase of other assets. Our Affiliate Banks can change the interest rate they pay on deposits at any time, and we can increase the amount of the fee we retain, both of which can change the amount of interest you receive on cash balances. Because the amount of interest paid to clients in RBC Insured Deposits is deducted from the revenue our Affiliate Banks earn on these deposits, RBC WM has a conflict of interest in that the less interest is paid to you, the more revenue RBC WM and our Affiliates Banks earn on those assets. Further, RBC WM receives internal accounting credits for cash balances deposited in our Affiliate Banks that help us meet our internal profitability goals as reported to our mutual parent company, which positively affects the amount of bonus paid to senior executives, including branch director personnel who supervise your accounts. For RBC Insured Deposits cash balances placed with our Affiliate Banks in both Retirement Accounts and non-Retirement Accounts, including amounts that exceed total FDIC program coverage and are placed at an Affiliate Bank in its capacity as the primary Excess Bank, our Affiliate Banks will receive a stable source of deposits at a cost that is less than other funding sources available. By being designated as the Primary Excess Bank in RBC Insured Deposits, our Affiliate Banks will receive substantial additional deposits to use in their businesses to increase their profitability. We address these conflicts of interest through proper disclosure, by offering clients the ability to opt-out of having their Deposit Accounts maintained at Affiliate Banks in non-retirement accounts, and by not receiving per-account fees from Affiliate Banks for Retirement Accounts. • Third-Party Program Banks. Third-party Program Banks holding deposits through RBC Insured Deposits pay RBC WM a fee based on a percentage of the average daily balance of the assets placed with them. The amount of fees retained by RBC WM will affect the interest rate you earn on your deposits. The fee retained by RBC WM is larger than the amount of interest you receive. The Program Banks can change the interest rate they pay on deposits, and we can increase the amount of the fee we retain, both of which can change the amount of interest you receive on cash balances. Therefore, RBC WM has a conflict of interest in that the less interest you receive for your deposits, the more in fees we retain on those cash balances. • Credit Interest Program. For CIP, we invest and use cash balances as free credit balances for our benefit. We use the free credit balances in the ordinary course of our brokerage business, subject to the requirements of Rule 15c3-3 under the Exchange Act. Under these arrangements, we invest CIP cash balances and generally earn interest or a return based on short-term market interest rates prevailing at the time. We periodically adjust the interest rate we pay you on CIP cash balances, and the spread between the interest earned by us from our investments and the interest rate we pay you on CIP cash balances will be favorable to us. We address these conflicts of interest through proper disclosure and by making the CIP unavailable to Retirement Account clients. • Money Market Funds. For amounts invested in the Federated Money Market Fund, the fund pays RBC WM service fees in the form of a recordkeeping fee and a shareholder servicing fee. This provides us with an incentive to use money market funds that pay us such fees instead of other funds that do not. These money market funds typically pay you a lower yield than money market funds that do not pay us recordkeeping or shareholder servicing fees. We address this conflict of interest by proper disclosure. • Recurring Distributions. In non-retirement accounts, you may also elect to automatically distribute accrued dividends, interest, capital gains, and return on capital payments from your account on a recurring basis. RBC WM invests and uses such cash balances as free credit from the date of deposit until the funds are distributed from your account, which is a benefit to us. You do not earn interest on free credit cash balances. Additional information regarding RBC WM’s use of free credit cash balances can be found in the Credit Interest Program section of the Client Account Agreement between you and RBC WM. • Differential Interest Rates by Business Channel. You may receive a different interest rate in RBC Insured Deposits from clients who enroll through a different business channel. This creates a conflict of interest because clients receive a lower interest rate on their RBC Insured Deposits cash balances in business channels where RBC WM retains a higher fee on such cash balances. Please see the Cash Management section of our public website at www.rbcwm.com/disclosures for more information regarding RBC WM’s Cash Sweep Program. Harvesting Gains or Losses Except for RBC UP accounts enrolled in Tax Management provided by Envestnet, you can request that the Overlay Manager or Investment Manager harvest gains or losses in your RBC UP, Consulting Solutions, or MAP account. Such requests are subject to acceptance by the Overlay Manager or Investment Manager. To request harvesting of gains or losses for your account in any of these Programs, you can notify us, and we will in turn notify your Overlay Manager or Investment RBC Wealth Management Advisory Programs Disclosure Document Page 16 of 46 26-25-5088800_25213 (09/26)  Manager. You must make such request each time, and for each account, that you desire gain or loss harvesting. Through the notification of your direction to the Overlay Manager or Investment Manager for your account, you are providing independent instructions to said Overlay Manager or Investment Manager to sell and to then either reinvest the loss sale proceeds in one or more replacement securities or retain the proceeds in cash. Gain sale proceeds will be reinvested in the account in accordance with the applicable asset allocation, as determined by the Overlay Manager or Investment Manager. You can typically request gain or loss harvesting (i) for specified securities, (ii) for specified tax lots, (iii) in a specified total amount, or (iv) in the maximum amount available, subject to each Investment Manager’s and Overlay Manager’s own policies and/or ability and willingness to accommodate such requests. It is important to note that the Investment Manager or the Overlay Manager may reject your request for tax harvesting in whole or in part, at its discretion. In addition, tax harvesting services may not be available for certain Investment Strategies, and the availability of tax-harvesting functionality may be limited due to technology-related and other factors. Please be aware that gain or loss harvesting is an intricate, nuanced strategy that may not be appropriate in all situations and may adversely impact investment performance. Neither RBC WM (including its affiliates) nor the Investment Managers or Overlay Managers provide any tax advice or make any guarantee that tax harvesting will be successful or produce any specific outcome. As such, you should consult your own independent tax, accounting and/or legal professionals before requesting gain or loss harvesting. In addition, when harvesting gains or losses, please keep the following in mind: • If a replacement security increases in value during any applicable wash sale period, such increase can result in a short- term capital gain to you when sold upon expiration of the applicable wash sale period. • There is no guarantee that harvesting requests received late in a calendar year will be completed before year-end. • There is no guarantee that harvesting will achieve any particular result. Tax management or “harvesting” is not tax advice and may not achieve the intended results. • If utilizing harvesting, your account holdings and performance can differ from other similarly invested accounts that do not utilize harvesting. • Harvesting requests only apply to the specific account for which the request is made. If you buy or sell securities in an account that overlaps with the securities sold in another account and such sale generates a loss, this loss may be disallowed under the IRS wash sale rules. • Withdrawing sale proceeds generated from harvesting will likely result in the rebalance of your account and the realization of additional capital gains or losses. Securities-Based Lending Clients have the opportunity to borrow money through lending programs, including RBC Express Credit (“Margin”) offered by RBC WM and RBC Credit Access Line (“CAL”) offered by Royal Bank of Canada and RBC Bank, bank affiliates of RBC WM (collectively referred to as “Lending Programs,” subject to eligibility requirements. In these Lending Programs, the client’s loan is secured by investments and other assets in their account(s) at RBC WM, including those held in Program accounts. Retirement Accounts, including those subject to Title I of ERISA and IRAs, are not eligible for participation in the Lending Programs. To participate in a Lending Program, you agree to maintain securities and/or other assets (“Collateral”) in your account that have a value at least equal to the amount required by its terms (“Maintenance Requirement”). Various factors may be considered in determining you Maintenance Requirement(s), including the value, liquidity and concentration of the Collateral. Not all securities are eligible to be used as Collateral. If the Collateral declines in value, certain actions may be taken to maintain the Maintenance Requirement, including selling securities or other assets in your account. Due to market volatility, debt you incur can exceed the value of the Collateral you deposit in your account. You will be required to deposit additional cash or securities, or pay down your loan, should the value of your Collateral decline below the percentage equity you must maintain for your Maintenance Requirement, or should the percentage equity you must maintain for your Maintenance Requirement increase. Through the Lending Programs, RBC WM receives interest on loans it extends on Margin or through CAL. RBC WM is permitted to lend or utilize securities on Margin in its possession and may receive compensation in connection with the use of such securities. Additionally, Financial Advisors are compensated based on clients’ outstanding balances in the Lending Programs, which is calculated monthly, as further described below for each Lending Program. This compensation creates a conflict of interest because it incentivizes RBC WM and its Financial Advisors to recommend these Lending Programs to you as discussed in Item 4 “Compensation to Financial Advisors.” Additionally, RBC WM clients with balances in a Lending Program may be charged a different interest rate from clients who have balances in the same program through a different business channel. This creates a conflict of interest because RBC CM, retains a higher percentage of the revenue received on loans in business channels that charge clients a higher interest rate. RBC Wealth Management Advisory Programs Disclosure Document Page 17 of 46 26-25-5088800_25213 (09/26)  RBC Express Credit (Margin) In this Lending Program, we charge you interest on credit extended to you for the purpose of purchasing, carrying, or trading in securities or commodities or otherwise using eligible securities in your accounts held with us as Collateral. Margin interest rates are determined using a base lending rate plus a sliding scale of percentages according to the size of your Margin debit balance. Your Financial Advisor is paid a portion of the interest you pay on your loan balance. The use of Margin in your Program account will impact the Program Fee you pay as further discussed in the section titled, “Calculation of Program Fees” in Item 4 below. RBC Credit Access Line (CAL) In this Lending Program, you have access to a securities-based line of credit through Royal Bank of Canada and RBC Bank. Interest rates can vary depending on factors such as your creditworthiness and the amount of credit for which you are eligible, as determined by Royal Bank of Canada and RBC Bank. Interest you pay on your CAL is paid to Royal Bank of Canada and/or RBC Bank. RBC WM also receives a portion of the interest and transactions fees earned by Royal Bank of Canada and/ or RBC Bank on your CAL. For more information about these Lending Programs, please refer to “Risks Related to Securities-Based Lending” in Item 6 below and the “RBC Credit Access Line”, “RBC Express Credit”, and “Schedule of Fees” disclosures available at www.rbcwm.com/disclosures. Fees and Compensation Fees In the Programs, you will pay the “Program Fee,” which is comprised of the RBC WM Advice Fee and, for certain Programs, the Investment Manager Fee, the Model Provider Fee, and/or the Overlay Manager Fee (each as defined and described below). Each of these is expressed as a percentage rate. The Program Fee will not exceed 3.0%. • RBC WM Advice Fee. In all Programs, you will pay us an “RBC WM Advice Fee” which is an asset-based “wrap” fee for the services we and your Financial Advisors provide in the Programs. The RBC WM Advice Fee covers our investment advisory and management services, custody of account assets, trade execution, clearing and settlement (with or through RBC WM), account reporting and other administrative services, as well as compensation to Financial Advisors. Generally, the RBC WM Advice Fee is expressed as a schedule that applies different rates to specified asset levels, or breakpoints at which the percentage of the value of the managed assets paid goes down as the asset level increases. Your Financial Advisor may aggregate your account with related Program accounts for the purpose of providing a more favorable RBC WM Advice Fee rate for you based on the combined assets of the related accounts. Discounts, if any, are negotiated separately for each breakpoint. The maximum annual rate for the RBC WM Advice Fee is 2.50%. • Investment Manager Fee. In the Consulting Solutions Program, and the RBC UP Program when utilizing Investment Strategies managed by any Investment Manager(s), you will pay a fee for the investment management services of any Investment Manager (the “Investment Manager Fee”). For accounts in MAP, the Program Fee does not include the Investment Manager Fee that you agree to pay any Investment Manager directly. • Overlay Manager Fee. In the RBC UP Program, you will pay a fee for the services of the Overlay Manager (the “Overlay Manager Fee”). • Model Provider Fee. In the RBC UP Program, as applicable, you will pay a fee for the Model Portfolio(s) provided by any Model Provider(s) (the “Model Provider Fee”). You will receive written confirmation of the Program Fee for your account upon enrollment in a Program, and each time you and your Financial Advisor agree to any RBC WM Advice Fee changes. In certain circumstances, RBC WM and/or your Financial Advisor may require you to sign additional documentation relating to the Program Fee (or a component thereof) for your account(s). On account confirmations and other communications to you, the term “Management Fee” will include, as applicable, the Overlay Manager Fee, the Model Provider Fee, and/or the Investment Manager Fee. Information and ranges for Investment Manager Fees, Model Provider Fees, and Overlay Manager Fees are included below. These fee rates may increase or decrease from time to time which will impact the relevant fee component of your total Program Fee. If you change your Investment Manager, Model Provider, or Overlay Manager, the relevant components of your total Program Fee may increase or decrease based on the Investment Manager, Model Provider, or Overlay Manager selected by you. In such case, we will notify you in writing of any change to your Program Fee. Program Fee Components and Ranges by Program The Program Fee is established at the account level. The Program Fee components depend on the Program in which your account is enrolled, and therefore, the Program Fee can vary between Program accounts, as follows: • RBC Advisor and Portfolio Focus. The Program Fee consists solely of the RBC WM Advice Fee. RBC Wealth Management Advisory Programs Disclosure Document Page 18 of 46 26-25-5088800_25213 (09/26)  • Consulting Solutions. The Program Fee consists of the RBC WM Advice Fee and the Investment Manager Fee. Investment Manager Fees range from an annual rate of 0.00% to 0.50% of Program account assets under management and vary by Investment Manager, and Investment Strategy. We pay a portion of the Investment Manager Fee to each Investment Manager, which typically ranges from 0.00% to 0.50% of Program account assets. Such amount is determined by the specific Investment Strategies of each Investment Manager currently available in the Program, the services provided by each Investment Manager, the total assets managed by each Investment Manager, and fee negotiations with the Investment Manager, as set forth in an agreement between RBC WM and each such Investment Manager. In some cases, fees we pay to Investment Managers may be lower than the amount of the Investment Manager Fee you pay us. Additionally, we negotiate fee schedules with some Investment Managers, which reduce the effective fee rate we pay to Investment Managers as the total amount of Program assets managed by those Investment Managers increases. Any difference in Investment Manager Fees charged to clients and the percentage of such fees we ultimately pay to the Investment Managers are retained by us. Fees retained by us are not passed on to the Financial Advisors. The fee we pay Investment Managers may change from time to time and such change may impact the total Program Fee we charge you. That is, if we negotiate a lower Investment Manager Fee for the Investment Strategy of an Investment Manager in which your Program account is invested, we may similarly decrease the Investment Manager Fee you pay us as part of the Program Fee. If we renegotiate an existing Investment Manager’s current fee rate, we will notify affected clients of any increase to the Investment Manager Fee. • RBC UP. The Program Fee consists of the RBC WM Advice Fee, the Overlay Manager Fee and, as applicable, the Model Provider Fee and/or the Investment Manager Fee. When RBC WM acts as Overlay Manager, the Overlay Manager Fee is 0.05% and is in addition to the RBC WM Advice Fee paid to us. When Envestnet acts as Overlay Manager, the Overlay Manager Fee is 0.10% and includes Envestnet’s Tax Management and/or Screens services, if selected. As noted above in Item 4, the Overlay Manager Fee will be assessed on all assets in the account, regardless of whether Tax Management and/or Screens are applied to all or some of those assets. When Envestnet is the Overlay Manager, we pay a portion of the Overlay Manager Fee to Envestnet that ranges from an annual rate of 0.00%-0.08% of account assets under management. We retain any difference between the Overlay Manager Fee of 0.10% that you pay and the portion of such fee we ultimately pay to Envestnet. The Model Provider Fee component of the Program Fee varies by Model Provider, Model Portfolio and type of account, and ranges from 0.00% to 0.65% annually of the market value of an account’s assets allocated to a Model Portfolio, as set forth in an agreement between RBC WM and each Model Provider. If more than one Model Portfolio and/or Investment Strategy is included in your RBC UP account, RBC WM employs a Sleeve-level billing methodology to calculate the amount of each Model Provider Fee and/or Investment Manager Fee. The amount will be determined by calculating the value invested in each Model Portfolio and/or Investment Strategy, or Sleeve, multiplied by the applicable Model Provider Fee for each Model Portfolio and/or Investment Manager Fee for each Investment Strategy in your RBC UP account at the time of each billing event. We pay each Model Provider and Investment Manager a portion of the Model Provider Fee or Investment Manager Fee you pay us. Any difference in the Overlay Manager Fee, Model Provider Fee and/or Investment Manager Fee paid by clients and the percentage of such fees that we ultimately pay to the Overlay Manager, Model Provider and/or Investment Manager are retained by us. Since we do not pay any part of the retained fees to Financial Advisors, they do not have a direct financial incentive to recommend one Overlay Manager, Model Provider and/or Investment Manager over another in relation to the portion of fees we retain. • MAP. The Program Fee consists solely of the RBC WM Advice Fee. The Investment Manager Fee is negotiated separately between you and the Investment Manager, and you are responsible for paying the Investment Manager Fee directly to the Investment Manager. Provided you have not instructed us otherwise, and in accordance with the Advisory Agreement, upon receipt of an official invoice from the Investment Manager(s), we will debit and pay the Investment Manager Fee specified on such invoice to the Investment Manager from your Program account. Any inaccuracy with respect to the amount of the Investment Manager Fee charged by an Investment Manager is solely your responsibility and not that of RBC WM. Fees are Negotiable In its discretion, subject to the maximum fee rates specified above, we may negotiate, reduce, rebate, or waive the RBC WM Advice Fee for any client. The RBC WM Advice Fee rate is determined between you and your Financial Advisor at time of Program enrollment and is negotiable based on various factors including type and size of the account and the range of services RBC WM provides. In addition to the negotiability of the RBC WM Advice Fee rate, in limited circumstances, as negotiated between you and your Financial Advisor, instead of the standard asset-based Program Fee, you may pay an RBC WM Advice Fee that consists of an annual fixed dollar amount. RBC Wealth Management Advisory Programs Disclosure Document Page 19 of 46 26-25-5088800_25213 (09/26)  You will receive written confirmation of the Program Fee for your account upon enrollment in a Program, and each time you and your Financial Advisor agree to any change to the RBC WM Advice Fee. In certain circumstances, RBC WM may require you to sign additional documentation relating to the Program Fee (or a component thereof) for your account(s). Your Program Fee may be higher or lower than (i) the fees and commissions you would pay in a brokerage account; (ii) the fees we charge other clients depending on considerations such as the size of your account, the amount of time you have had an account with us, the combined value of related advisory accounts, the total amount of business you conduct through RBC WM, the types of securities and services provided, and other relevant criteria; and (iii) the cost of similar services offered through other financial institutions. Calculation of Program Fees; Valuation of Account Assets Typically, the Program Fee is charged quarterly, in advance, based on the market value of the assets in a Program account, including securities, cash, money market funds, Cash Sweep Program balances, and/ or Credit Interest Program balances as of the last business day of the preceding calendar quarter. We include the full market value of assets purchased on Margin in the calculation of your Program Fee and do not reduce the market value of your account by your Margin debit balance. Because the Program Fee is assessed on the market value of assets in your account at the end of a quarter, the total amount of the Program Fee billed each quarter will generally change as Program assets increase or decrease in the Program account. Exchange-traded securities will be valued at the last trade price, or if unavailable, the last known bid price as provided by a third-party vendor. Over-the-counter and illiquid securities will be valued using the broadest and most representative market available. Securities for which market quotations are not readily available will be valued at the known current bid price. If updated pricing is not available from the third-party vendor within 45 days or RBC WM determines the price received from the third-party vendor does not reasonably reflect the last trade price, last known bid price or current market value, as applicable, the price of the security will be removed from the system. All other securities are valued by an independent third- party retained by us or, if unavailable, by a valuation statement provided by the issuer, which will remain unchanged for one year from the date on the valuation statement or until an updated statement is received. Securities where the price cannot be determined will be excluded from the Program Fee charged by RBC WM. Assets Held with a Third-Party Custodian Where a client maintains the assets in their Program account with a Third-Party Custodian, we will calculate the Program Fee based on the market value of the assets and any other related information provided by such Third-Party Custodian, which may use a different method to value the securities in the account than we do. We will not be responsible for verifying the accuracy of information provided by such Third-Party Custodian regarding a client’s account or any losses or errors that result from that information. Funds To compute the value of assets held in a Program account custodied at RBC WM, we value Fund shares at their respective net asset values as reported on the valuation date by each Fund. Fee-Based Annuities RBC WM values Fee-Based Annuities based on the daily end-of-day contract values provided by annuity issuers. RBC WM provide no assurance that the end-of-day contract values provided to us by the annuity issuers are accurate and we do not verify the annuity contract values provided. Alternative Investments RBC does not conduct an independent valuation of any alternative investments you hold as positions in your account and RBC WM does not, and is under no obligation to, validate or warrant that any such valuation is accurate. RBC WM relies on the valuation information provided to us by the managers of the Alternative Investments or another service provider, as applicable, which RBC generally receives in arrears of the Alternative Investment’s valuation date. Therefore, the valuation will not reflect the current net asset value of the Alternative Investment as of the date that the Program Fee is calculated for your Account. RBC WM will not retroactively adjust your Program Fees paid on such valuations. Any capital calls and/or subscription amounts sent from your Program account and related to such investment appear on your account statement as an estimated value until confirmed by the Alternative Investment manager’s valuation information. Any distributions received into your Program account will reduce the overall position, resulting in an estimated value until RBC WM receives the Alternative Investment manager’s valuation information. Cash positions resulting from distributions in your account are and will continue to be subject to the Program Fee. Such estimated values related to capital calls and/or subscription amounts are included in the Program Fee. RBC Wealth Management Advisory Programs Disclosure Document Page 20 of 46 26-25-5088800_25213 (09/26)  Dividends In non-retirement accounts, if you have elected to automatically distribute accrued dividends, interest, capital gains, and return on capital payments from your account on a recurring basis, the proceeds of these payments will not be assessed a Program Fee from the date these payments are made to the date of distribution. Deposits, Withdrawals and Changes Program Fees are prorated for any billing period that is less than a complete quarter. Unless otherwise agreed to in writing between you and RBC WM, deposits to or withdrawals from a Program account of cash and/or securities with a value equal to or greater than $10,000 will be billed at the applicable fee rate on a pro-rated basis. Deposits and withdrawals on the same day will offset each other, and the net amount will be used to calculate on a daily basis an additional Program Fee or refund to your account. In each case, the additional Program Fee or refund will be calculated based on the applicable fee rate times the amount of the increase or decrease, pro-rated based on the number of days from the date of the triggering event to the last day of the calendar quarter. If there is any change in your Overlay Manager, Model Provider, Model Portfolio, Investment Manager, Investment Strategy or investment allocation in your account before the end of a quarter, we will use the market valuation from the date of the change to adjust only the portion(s) of the Program Fee (e.g., Overlay Manager Fee, Model Provider Fee, Investment Manager Fee) affected by such change on a pro-rated basis. At the time of such account change the market value of your account may be higher or lower than the market value of your account at the time your quarterly Program Fee was calculated. As a result, the prorated Model Provider Fee, Overlay Manager Fee, and/ or Investment Manager Fee portion of the Program Fee may be higher or lower than when originally calculated. RBC WM reserves the right to correct errors in calculations of Program Fees that were charged to you by debiting or crediting your account, as applicable, without prior notice to you. Additionally, RBC WM reserves the right to increase any components of the Program Fee upon thirty (30) days’ advance written notice to you. Fees Upon Termination You or RBC WM can terminate your Program account in accordance with the notice and other provisions contained in the Advisory Agreement. If a Program account is terminated prior to the last day of the quarter, we will refund you the prorated portion of the Program Fee you paid, calculated based upon the days remaining in the quarter. The termination of a Program account will terminate the Advisory Agreement for that account which will revert to a brokerage account, subject to all standard fees and commissions, and we will no longer be acting as a fiduciary to you with respect to that account. Payment of Program Fee The Program Fee will be deducted on a quarterly basis directly from your Program account unless you affirmatively elect, verbally or in writing, to be billed directly, or to have the Program Fee deducted from another RBC WM account, provided that the account is not a custodial account (e.g., UGMA/UTMA account) or a Retirement Account, as permitted by applicable law. If you have elected to be invoiced for the Program Fee and the Program Fee is not paid within sixty (60) days of the date of the invoice, RBC WM will instead debit your applicable Program account for the invoiced amount of the Program Fee due. Offset of Certain Fees to Retirement Accounts With respect to Retirement Accounts (including IRAs and accounts subject to Title I of ERISA), if you hold RBC GAM – U.S. Funds, including the RBC BlueBay Access Capital Community Investment Fund, RBC BlueBay Destra International Event- Driven Credit Fund, or Funds subadvised by RBC Rochdale, we will rebate the net management fee charged by the Fund company to you. For other affiliated Funds and/ or Funds sub-advised by an affiliate of ours (e.g., RBC GAM – U.S.), the RBC WM Advice Fee, and the Overlay Manager Fee when RBC WM acts as Overlay Manager in RBC UP, will not be assessed on the value of these Funds in Retirement Accounts. Unless required by applicable law, the credit or offset will not apply to other Fund expenses such as transfer agency fees and shareholder servicing fees, or actual distribution, shareholder servicing and other fees paid to RBC WM and its affiliates. Additionally, RBC WM has a conflict of interest in offering and recommending proprietary and affiliated Funds in the Programs over non-proprietary and/or non-affiliated Funds because we and/or our affiliates receive the fees and expenses charged by such Funds rather than a non-affiliate. For more information see “Fees to RBC Affiliates” on our public website at www.rbcwm.com/disclosures. Comparing Costs You may pay more or less in a Program than you might otherwise pay if you purchased the services separately, through other firms, or if you chose to purchase the same or similar securities in a brokerage account through RBC WM. Factors to consider with respect to the cost of a Program include but are not limited to: the cost of the services if provided and charged separately; the Program Fee rate charged in the Program; and the trading activity in your Program account. RBC Wealth Management Advisory Programs Disclosure Document Page 21 of 46 26-25-5088800_25213 (09/26)  When making cost comparisons, you should be aware that the combination of investment management, custodial, consulting, and brokerage services available through a Program may not be available separately or may require multiple accounts, agreements, and fees. In addition, certain Investment Strategies, Overlay Managers, and/or Model Portfolios may not be available to clients outside of a Program either because of minimum account size requirements, fee schedules, geographic availability, or other factors. When assessing the overall cost of a Program, you should also consider that a Program account with low trading volumes, high cash balances, and/or significant fixed income positions could receive similar services at a lower cost in a brokerage account. If a Program account is actively traded through RBC WM, the Program Fee may be less expensive than separately paying investment management fees, consulting fees, and trading and execution costs. In addition, investments that have no upfront fees or commissions, such as no-load Funds and certain alternative investments and annuities, may be available to you outside of a Program account at no additional cost. As discussed below in Item 4 under “Fund Fees and Expenses,” fees charged in connection with certain investments in your Program account, such as management and other fees charged by Funds, are not included in the Program Fee and will result in higher total costs than if you invested in such securities outside of a Program account. Additional Fees and Expenses The Program Fee (including all components described above) does not cover or include any of the following additional fees and expenses, where applicable: • for MAP accounts, the Investment Manager Fee, which you pay directly to the Investment Manager, as further described in the above “Managed Account Program” section; • commissions, “mark-ups,” “mark-downs,” and dealer spreads, if any, (i) that RBC WM or its affiliates receive when acting as principal in certain transactions where permitted by law, rule, or regulation, or (ii) that other broker-dealers receive when acting as principal in certain transactions effected through RBC WM and/or its affiliates acting as agent, which • is typically the case for dealer market transactions (e.g., fixed income, over-the-counter equity, and foreign exchange (“FX”) conversions in connection with purchases or sales of non-US dollar-denominated securities and with payments of principal and interest dividends on such securities); • underwriting commissions, investment banking, and other fees where RBC WM is a member of an underwriting syndicate; • certain other costs or charges that may be imposed by third parties pursuant to law, rule, or regulation including, among other things, bid-ask spreads, odd-lot differentials, exchange fees, transfer taxes, foreign custody fees, supplemental transaction fees, regulatory fees and other fees or taxes that may be imposed pursuant to law, rule, or regulation; • RBC WM’s usual and customary transaction charges on the liquidation of investments deemed ineligible for the Programs; • any contingent deferred sales changes, redemption charges, or other fees and expenses imposed by certain Funds or alternative investments (see Fund prospectus or private placement memorandum (“PPM”), as applicable, for details); • performance-based fees and/or expenses imposed by and paid to the fund manager or alternative investment manager as further described in the “Performance-Based Fees and Side-by-Side Management” section; • check reordering costs and fees; • RBC WM transaction and annual maintenance fees associated with alternative investments held in your Program account as an accommodation; • short-term trading charges for purchases and corresponding redemptions of certain Fund shares (see Fund prospectus for details) made within a short period of time; • costs and expenses of UITs (e.g., organization costs, operating expenses, portfolio supervision, bookkeeping, trustee, and other administrative fees, etc.); • fees and charges specific to Fee-Based Annuities and other annuities linked to your Program account, which may include but are not limited to, administrative and termination/distribution charges, mortality and expense risk charges, expenses for underlying investment options and optional rider/benefit fees; • RBC Express Credit (margin) or RBC Credit Access Line (CAL) interest, or interest on other debit account balances; • safekeeping fees for physical securities; • American Depositary Receipt (“ADR”) pass-through fees; • additional costs incurred when purchasing foreign securities that are assessed by the foreign exchange, including, but not limited to, exchange fees, taxes, conversion fees and currency translation costs. For example, when “ordinary shares” are purchased on a foreign exchange (which may charge a fee or tax on the trade) and are converted to ADRs, the depository bank may charge a fee to convert the ordinary shares to ADRs and in doing so, there may be currency translation costs associated with the conversion; RBC Wealth Management Advisory Programs Disclosure Document Page 22 of 46 26-25-5088800_25213 (09/26)  • additional costs when investing in foreign securities and utilizing foreign tax relief and reclamation services; • fees charged by RBC WM related to reporting and filing unrelated business taxable income in Retirement Accounts; • costs of custody and execution services by any Third-Party Custodian; and • any fees/expenses associated with RBC Insured Deposits. Fund Fees and Expenses Funds pay fees and expenses that are ultimately borne by clients (including, but not limited to, management fees, brokerage costs, administrative, and custody fees), as detailed in each Fund’s prospectus. Program clients who are holding or investing in Funds will pay two levels of investment advisory fees: 1) investment management fees charged by the Fund companies, and 2) Program Fees to RBC WM, the Investment Managers, the Model Providers, and/or the Overlay Manager. Some of the fees and expenses are paid to and, where permitted under applicable regulatory requirements, retained by us for advisory and/or other services. Funds eligible for the Programs will be subject to the Program Fee which could also subject you to a higher overall cost. Outside of the Cash Sweep Program, RBC WM may, without notice to you, convert Funds in your Program account to a lower cost share class of the same Fund offered by RBC WM or make changes to your investment model or allocation in the event a lower cost share class of the same Fund is or becomes available through RBC WM. However, if you purchased a Fund from RBC WM with an up-front sales charge, typically in a brokerage account outside of the Programs, and subsequently transfer such Fund shares into an advisory Program account, those Fund shares will not be subject to the Program Fee for two or more years from the date of initial purchase. Fund shares purchased at other financial institutions may be converted to the appropriate share class in a Program account and subject to the Program Fee immediately whether you paid an up-front sales charge or other compensation or not. RBC WM may also elect not to convert certain Fund shares if, for example, there is no equivalent share class available in the Programs, or such conversion could subject you to additional sales or other charges, or in certain other circumstances, as determined by us. Additionally, if you have a systematic buy or sell transaction established for a Fund that is ineligible for the Program selected, the transaction may be rejected resulting in your trade(s) not being fulfilled. Prior to enrolling in the Programs, you should review the costs and impact of converting your Fund share classes and discuss this with your Financial Advisor. If you do not want your Funds converted, or your investment model/allocation updated, you should discuss leaving those holdings in, or transferring those holdings to, a non-Program account. Under certain circumstances, your account may be invested in a Fund share class with a 12b-1 fee. This fee, which is also known as a distribution fee, is an operational expense used to pay for marketing and distribution expenses and is therefore included in the Fund’s expense ratio. 12b-1 fees are part of the overall Fund expense ratio, which is paid by you through deduction of assets in the Fund’s daily net asset value calculation. 12b-1 fees may vary by share class, with certain share classes having lower or no 12b-1 fees. Typically, the 12b-1 fee is paid to RBC WM (and a portion is shared with the Financial Advisor) as ongoing compensation for a period of time, as outlined in the applicable prospectus, creating an incentive for a Financial Advisor to recommend a Fund and a share class that pays a 12b-1 fee as opposed to a Fund or share class that does not. Excluding the Cash Sweep Program, RBC WM addresses this conflict of interest by (1) limiting offerings of share classes that pay a 12b-1 fee in the Programs, and (2) crediting any 12b-1 fees that we receive back to you. Funds and certain other investments will be accompanied by a prospectus or other offering document that contains important information about each such Fund, including investment objectives, risks, and applicable fees and expenses. Clients should read each Fund’s prospectus carefully and consider all the information in it before investing. If, and to the extent that your account is invested in a Fund managed by an affiliate of ours, you will indirectly pay two levels of advisory and other fees to us in connection with such balances (i.e., the investment management fees charged by the Fund companies, and the Program Fee). We address this conflict through disclosure and by subjecting the affiliated Funds to the same selection and evaluation standards as non-affiliated Funds. Further, in Retirement Accounts, if you hold RBC GAM – U.S. Funds, including the RBC BlueBay Access Capital Community Investment Fund, RBC BlueBay Destra International Event-Driven Credit Fund, or Funds subadvised by RBC Rochdale, the management fee charged by the Fund company will be rebated to you. For other RBC WM affiliated Funds, including Funds subadvised by RBC GAM – U.S. or RBC Rochdale, the RBC WM Advice Fee, and when RBC WM acts as the Overlay Manager in RBC UP, the Overlay Manager Fee component of the Program Fee, will not be assessed to the value of such Funds maintained in Retirement Accounts. You should read the Fund’s prospectus carefully prior to selecting a Fund in which to invest. Alternative Investment Fees and Expenses Investing in Alternative Investments is generally more expensive than certain other investment options offered in the Programs. In addition to RBC WM’s Program Fee, you pay the following Alternative Investment’s fees, as disclosed in the Alternative Investment’s offering documents: • management fees; • incentive fees, as applicable; RBC Wealth Management Advisory Programs Disclosure Document Page 23 of 46 26-25-5088800_25213 (09/26)  • redemption and transfer charges, as applicable; and • other fees and expenses disclosed in the Alternative Investment’s offering documents. Under certain circumstances, Alternative Investments pay fees to RBC WM for the solicitation of and placement of client investments into the Alternative Investment (“Upfront Placement Fees”) and for ongoing shareholder and administrative servicing of Alternative Investments (“Annual Trailing Fees”). Upfront Placement Fees are paid to RBC WM as a percentage of the initial amount invested which reduces the amount of your initial investment while ongoing Annual Trailing Fees are paid to RBC WM out of the management fee the Alternative Investment charges you. Upfront Placement Fees and Annual Trailing Fees paid to RBC WM create an incentive for a Financial Advisor to recommend a certain Alternative Investment that pays these fees over an Alternative Investment that does not. RBC WM addresses this conflict by not accepting Upfront Placement Fees and Annual Trailing Fees for Program accounts or crediting to your account any Upfront Placement Fees and Annual Trailing Fees that we receive related to investments in the Programs. Trading Away and Associated Costs We generally anticipate most Investment Managers and the Overlay Managers will effect substantially all portfolio trades for Program accounts with or through us. This arrangement creates an incentive for us to recommend Investment Managers or Model Providers with lower portfolio turnover rates. There are certain Investment Managers, including those offering certain fixed income strategies, that have historically directed most, if not all, their trades to outside broker dealers. RBC WM makes information on Investment Managers’ trading practices in this regard available via the “Investment Managers and Trading Practices” link at RBC WM’s legal disclosure website, www.rbcwm.com/disclosures. The information we provide in this regard is based solely on the historical information provided to us by the Investment Managers. We do not make any representations regarding their future trading practices. For accounts enrolled in MAP, since RBC WM does not monitor the Investment Managers clients elect to use in MAP, clients should contact any such Investment Manager directly for information on their trading practices and associated costs. If Investment Managers trade away from RBC WM with other broker dealers, you should understand that commissions, mark- ups, spreads, and other transactional charges for such trades are charged to you by the executing broker dealer (and passed along to you by RBC WM). Accordingly, the Program Fee you pay to RBC WM does not cover such costs charged by other broker-dealers; the Program Fee covers these costs only when the transactions are executed by RBC WM. The executing broker-dealers may net these commissions, mark-ups, spreads and other transactional charges into the overall purchase or sale price of the trades, and these commissions, mark-ups, spreads and other transactional charges are not delineated on your RBC WM trade confirmation, monthly transaction summary or statement. RBC WM does not restrict an Investment Manager’s ability to trade away, as the responsibility to determine the suitability of trading away from RBC WM and for best execution is that of the Investment Manager. RBC WM does not evaluate whether an Investment Manager is meeting its best execution obligations when trading away. You should understand that RBC WM is not a party to transactions that are not executed through or with us and therefore, we are not able to negotiate the price or transaction-related charge(s) with the executing broker-dealer. While the costs associated with equity trades done away are typically in the form of commissions and other transactional charges that are disclosed and accessible to RBC WM, the additional costs associated with fixed income trades are not identified separately because they are incorporated into the net price of the trade. Additional information on trade away practices of Investment Managers in Consulting Solutions is available at: www.rbcwm.com/disclosures. Note, before selecting an Investment Manager for any Program described in this brochure, you should carefully review all material related to that Investment Manager, including any disclosure on whether the Investment Manager uses broker- dealers other than RBC CM to effect any trades and any additional trading costs (brokerage commissions or other charges) associated with executing trades with such other broker-dealers. You should consider this information, (i.e., an Investment Manager’s trading practices and any associated additional costs and expenses), when assessing the overall costs of a Program and a particular Investment Manager and/or Investment Strategy. Foreign Tax Relief and Reclamation Services For clients that invest in international securities, we utilize a third-party vendor that provides foreign tax relief and reclamation services on behalf of clients. For more information, please see “Foreign Tax Relief and Reclamation Overview” on our public website at www.rbcwm.com/disclosures. Tax Considerations The payment of the Program Fee as described above may produce income tax results different from those resulting from the payment of brokerage commissions or other transactional charges on a per trade basis. If you are not a tax-exempt entity, the sale, redemption, or exchange of investments may result in taxable gains or losses. Further, it is your responsibility to ensure that the payment method selected, and subsequent treatment of the related expenses, complies with applicable tax laws and other regulations. RBC Wealth Management Advisory Programs Disclosure Document Page 24 of 46 26-25-5088800_25213 (09/26)  In addition, careful consideration should be given prior to purchasing investments or selecting strategies that may utilize “tax-advantaged” investments in certain qualified accounts. This may result in no additional tax benefits at the expense of performance. Neither RBC WM, nor its affiliates or employees provide legal, accounting or tax advice. All legal, accounting or tax decisions regarding your accounts and any transactions or investments entered into in relation to such accounts, should be made in consultation with your independent advisors. No information, including but not limited to written materials provided by RBC WM or its affiliates or employees should be construed as legal, accounting or tax advice. Compensation to Financial Advisors Advisory Fees If you invest in one of the Programs described in this brochure, we pay your Financial Advisor, on an ongoing basis, a portion of the RBC WM Advice Fee payable to us in connection with your Program account. The amount we allocate to your Financial Advisor in connection with an account enrolled in any of the Programs could be more than if you pay separately for investment advice, brokerage, and other services. Therefore, Financial Advisors could have a financial incentive to recommend an advisory Program account over a brokerage account. If you invest in one of the Programs, your Financial Advisor may charge less than the maximum RBC WM Advice Fee. Excluding the RBC Advantage team and its Financial Advisors who are compensated on a salary basis, all other RBC WM Financial Advisors with Advisory Program clients receive as compensation a percentage of the RBC WM Advice Fee such clients pay to us, and therefore those Financial Advisors have a financial incentive not to reduce the RBC WM Advice Fee because it would reduce the amount of compensation they receive. Similarly, Financial Advisors have an incentive to recommend lower cost Investment Strategies and/or Model Portfolios so that the Financial Advisor may charge the highest possible RBC WM Advice Fee, increasing their compensation. Financial Advisors also have an incentive to recommend the Portfolio Focus Program or the RBC Advisor Program, which do not charge an Investment Manager, Model Provider, or Overlay Manager Fee, so that the client is paying only the RBC WM Advice Fee, allowing the Financial Advisor to receive higher compensation. Financial Advisors are compensated based on the market value of billable assets in the account. In certain instances, your account could contain assets that are not included in the billable value of the account. Therefore, this is a conflict of interest as your Financial Advisors could have a financial incentive to sell these assets and purchase assets that would be included in the billable value of the account and directly impact compensation. Securities-Based Lending Through Lending Programs (i.e., RBC Express Credit or RBC Credit Access Line), RBC WM, and generally Financial Advisors receive additional compensation based on the amount of loan balance outstanding. This additional compensation presents a conflict of interest for us because it creates an incentive for us to recommend affiliated Lending Programs to you and/ or to recommend that you increase your monthly loan balance. We and your Financial Advisor are further incented to recommend the Lending Programs to you to the extent it encourages you to not liquidate certain securities and assets. This is a conflict of interest, as we and your Financial Advisor have a financial incentive to avoid recommending that you liquidate assets under management because the Program Fee is based on assets under management. These conflicts of interest are addressed by appropriate disclosure to clients and training for our Financial Advisors. Recruitment RBC WM offers recruiting packages to Financial Advisors joining from other firms. Under these packages, Financial Advisors are eligible for two types of promissory notes in designated amounts. The first note is issued to the Financial Advisor once his or her securities license is transferred to RBC WM. Depending upon the recruiting package, RBC WM will either forgive or collect the principal and interest amount of this note each month, so long as the Financial Advisor remains employed and in good standing for a predetermined period of time. Although there are no set production goals for the note to be forgiven, a Financial Advisor must maintain a certain production level to remain employed. The second type of note is issuable each year for a fixed number of years if the Financial Advisor meets specified production goals. After issue, depending upon the recruiting package, RBC WM either forgives or collects these loans each month so long as the Financial Advisor remains employed and in good standing for a predetermined period of time. Both loans create a conflict of interest because they provide incentives for our Financial Advisors to encourage you to effect more investment transactions, to invest more advisory assets, and/or to recommend products and services that generate more revenue for us. Rewards, Incentive Compensation and Bonuses Your Financial Advisor is eligible to qualify for both recognition programs and practice development and training programs. These rewards, such as trips to a specified destination, incentive compensation, such as deferred compensation, and bonuses are based on the amount of your Financial Advisor’s compensation, length of service, and the amount of RBC Wealth Management Advisory Programs Disclosure Document Page 25 of 46 26-25-5088800_25213 (09/26)  compensation your Financial Advisor generates for us over time. Awards given in the form of deferred compensation have minimum vesting schedules and are subject to forfeiture under certain circumstances. The practice development and training programs provide the opportunity for a Financial Advisor to participate in a practice management, business development, and/or training program that may include travel to a specified destination. Each program allows the Financial Advisors to interact with both peers and industry experts and to exchange ideas on business practices and development. These rewards, incentive compensation, and bonuses create a conflict of interest because they provide an incentive for your Financial Advisor to encourage you to engage in more investment transactions so that they qualify for such rewards, incentive compensation, and bonuses. Branch Directors and Complex Directors, who may also be Financial Advisors, perform supervisory responsibilities over other RBC WM Financial Advisors for the branch or region in which they are located. We compensate these individuals for their supervisory activities through a base salary, but also pay a bonus to these individuals based on meeting certain internal benchmarks, which include revenue generated by the Financial Advisors in their branch or region. This is a conflict of interest as supervisors have an incentive to encourage the recommendations of products, services and investments that generate greater revenue for RBC WM to meet the revenue portion of the internal benchmark. We mitigate this conflict by not compensating our supervisors directly based on the recommendation of any specific products, services, or investments but instead on attainment of specific internal benchmarks, which include revenue goals. ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS To open an account in any of the Programs and receive the investment advisory and other related services described in this brochure, you must enter into the Advisory Agreement with RBC WM. The Advisory Agreement expressly acknowledges our investment advisory relationship with you and describes our obligations, services we will provide to you, and our specific authority under the Program(s) in which you are opening and enrolling one or more Program account(s). The Advisory Agreement governs the terms of your existing and future Program accounts and relationships with RBC WM. Each of the Programs generally requires a certain minimum amount of assets to open an account in that Program. However, RBC WM has the discretion to accept accounts below the Program minimums. RBC WM reserves the right to terminate a Program account if the account assets fall below the Program minimums set forth below. • RBC Advisor: $25,000. • Portfolio Focus: $25,000. • RBC UP: Depending on services and Investment Products selected, minimums range from $2,500-$500,000. • Consulting Solutions: $100,000-$600,000 for equity strategies; $100,000-$500,000 for fixed income strategies, subject to minimum account requirements imposed by the applicable Investment Manager. • MAP: $100,000 or the Investment Managers’ minimum, whichever is greater. RBC WM provides investment advisory services to individuals, foundations, endowments, employee benefit plans, trusts, estates, educational institutions, corporations, businesses, government entities and other entities. The Programs are generally available for both non-retirement and Retirement Accounts, including IRAs. When providing services to clients who are subject to ERISA, we may rely on various Prohibited Transaction Exemptions (“PTEs”) available under ERISA, including PTE 84-14, which is only available to qualified professional asset managers (the “QPAM Exemption”). On March 5, 2024, the French Court of Appeal rendered a judgment of conviction (the “Conviction”) against Royal Bank of Canada Trust Company (Bahamas) Limited (“RBCTC Bahamas”), an affiliate of RBC CM, and other parties regarding a charge of complicity in estate tax fraud relating to actions taken relating to a trust for which RBCTC Bahamas serves as trustee. In 2016, RBC was granted an exemption by the U.S. Department of Labor that allowed RBC and its current and future affiliates to continue to qualify for the QPAM Exemption under ERISA despite the conviction of RBCTC Bahamas in the French proceeding for a temporary one-year period from the date of conviction. In 2025, the Department of Labor granted RBC an exemption providing longer-term relief, which is effective from August 12, 2025, through March 4, 2030. ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION Selection of Investment Managers and Model Providers In RBC UP and Consulting Solutions, we consider and select only Investment Managers and Model Providers that meet our eligibility requirements. In identifying and choosing Investment Managers and Model Providers, we evaluate the financial and organizational stability of the firm and product, historical performance results, experience, and other factors. Based on the evaluation, Investment Managers and Model Providers are categorized by their respective investment styles. Each Model Portfolio and Investment Strategy added to the RBC UP and/or Consulting Solutions Programs, as applicable, are further categorized by the level of conviction RBC WM has in the Investment Manager and/or Model Provider and their respective RBC Wealth Management Advisory Programs Disclosure Document Page 26 of 46 26-25-5088800_25213 (09/26)  Investment Strategy or Model Portfolio. Information we gather regarding Investment Managers and Model Providers is believed to be reliable and accurate, but we do not independently verify it. We conduct periodic reviews of Envestnet and our own Overlay Manager function to evaluate adherence to Model Portfolios and investment allocations selected by you. In Portfolio Focus, generally, Financial Advisors who become officially approved to participate in Portfolio Focus have met standards of education, industry experience, investment management experience and compliance. Applications to participate in Portfolio Focus are reviewed by field supervisors, divisional management, compliance, and Advisory Programs management. Advisory Programs management admits qualified Financial Advisors into Portfolio Focus after a thorough review. As described above in Item 4, you will establish an Advisory Risk Profile for your Program account. For Programs in which you select an Investment Manager(s) or Model Provider(s), your Financial Advisor will consult with you regarding investment alternatives consistent with your Advisory Risk Profile. You, or your Financial Advisor acting with discretion in RBC UP, then select one or more Investment Managers (and their Investment Strategy(ies)) and/or Model Providers (and their Model Portfolio(s)). When required to do so by law or as otherwise agreed to with an Investment Manager, we will provide you with a copy of each Investment Manager’s and/or the Overlay Manager’s written disclosure statement (Part 2A of its Form ADV or other comparable document) at the time of Program enrollment. Monitoring and Review of Investment Managers and Model Providers On a quarterly basis, we monitor and review the Investment Managers we make available in Consulting Solutions and RBC UP, and the Model Providers we make available in RBC UP, to determine whether they continue to meet the standards and requirements of RBC WM. This evaluation may involve, among other things, a review of investment discipline and trends in investment philosophies. Comparisons are made to other accounts and to standard industry market statistics. These initial and ongoing due diligence reviews are conducted by the RBC Global Manager Research team (“GMR”). The level of review applied by GMR depends on RBC WM’s conviction in each Investment Manager and Model Provider and their respective Investment Strategies and Model Portfolios. For the highest conviction Investment Strategies and Model Portfolios, this review is based on both the investment style descriptions offered by the Investment Managers and Model Providers (qualitative factors) and analysis performed by GMR (quantitative factors). GMR’s ratings and opinions for the highest conviction Investment Strategies and Model Portfolios are available to Financial Advisors. These ratings and opinions are updated annually or more frequently, as needed. Investment Strategies and Model Portfolios not deemed highest conviction are reviewed quarterly based primarily on quantitative factors. A quantitative score (“Score”) is assigned to each Investment Strategy and Model Portfolio based on multiple factors related to the firm and product, investment professionals, investment approach and performance and weights assigned to the individual factors selected. Investment Strategies and Model Portfolios not deemed to be the highest conviction must meet these predefined Scores to be added and maintained in RBC UP and Consulting Solutions. If a Score cannot be calculated, the same factors are reviewed manually, instead of systematically, until a Score can be calculated. For cases where a Score cannot be produced, GMR will continue to qualitatively monitor the applicable Investment Strategies and Model Portfolios and provide annual updates as needed to the RBC WM Managed Account Investment Committee. Scores are not assigned to the RBC WM Portfolio Advisory Group (“PAG”) Model Portfolios. Each of the PAG Model Portfolios is reviewed quarterly by an internal oversight committee led by GMR to determine if it continues to align with its stated investment objective. Through our monitoring process, the level of conviction in an Investment Strategy or Model Portfolio may change, and therefore, the level of review applied may also change. If you would like information regarding RBC WM’s conviction in a particular Investment Strategy or Model Portfolio, please contact your Financial Advisor. The level of conviction we have in an Investment Strategy or Model Portfolio is not indicative of its quality nor is it a basis for how the Program Fee is determined. Watch List As part of our monitoring process, RBC WM maintains a watch list of Investment Strategies and Model Portfolios for which there may be developments of potential concern. Such developments may include the Investment Managers’ or Model Providers’ adherence to management style, consistency with client objectives, unexplained poor performance, or other matters that come to our attention. The watch list provides us with the means to review and communicate developments related to Investment Managers and Model Providers in RBC UP and Consulting Solutions. Placement of Investment Managers and/or Model Providers on the watch list initiates a probationary period that allows us adequate time to better assess the effects—negative or positive—stemming from the developments in question. Performance • Investment Manager and Model Provider. For all Investment Strategies and Model Portfolios, we produce product profiles containing reported historical performance available to your Financial Advisors to provide to you. These product profiles include the Investment Manager’s or Model Provider’s reported performance and generally present 10 years of an investment strategy’s performance history. RBC Wealth Management Advisory Programs Disclosure Document Page 27 of 46 26-25-5088800_25213 (09/26)  • Fund Performance. We utilize the Fund’s published performance for review purposes. • Portfolio Advisory Group (PAG). We create performance composites for each PAG Model Portfolio and make them available to your Financial Advisor to provide to you. These composites are comprised of the RBC UP Sleeves invested in each such Model Portfolio. We make product profiles for each PAG Model Portfolio available to Financial Advisors to provide to you. These product profiles include our calculated composite performance. We may provide you with information to allow you to compare this PAG performance data with your account and/or Sleeve performance. • MAP Investment Managers. In MAP, we may provide you with information to allow you to compare the Investment Manager’s overall performance data with industry market statistics or data the Investment Manager reports to consulting and database services. You are responsible for reviewing the information provided and assessing any MAP Investment Manager’s overall performance. We do not provide this review or subject these Investment Managers and Investment Strategies to the monitoring and review process described above for RBC UP and Consulting Solutions. • Portfolio Focus Managers. In Portfolio Focus, Financial Advisor strategies are monitored by Complex Management and Product Surveillance on a continuous basis to ensure adherence to Program guidelines. Surveillance of Program accounts include many metrics, including daily trade monitoring and weekly monitoring of Program investment management guidelines. Additionally, on an annual basis, Financial Advisors are required to recertify for participation in the Program. Based on the outcome of the review, the Financial Advisor will either be recertified for continuance in the Program or can be removed from the Program as further discussed below in “Removal of an Investment Manager, Model Provider, Fund, or Financial Advisor” in Item 6. Generally, the investment performance of a Financial Advisor’s strategies in Portfolio Focus is not calculated. However, under certain circumstances, select Portfolio Focus Financial Advisors managing a specific strategy are able to use composite performance reports for that strategy with clients and prospective clients. This requires approval from the Financial Advisor’s field supervisors, divisional management, compliance, and Program management. We require the Financial Advisor to provide a description for each strategy employed in Portfolio Focus and accounts must be managed to the described strategy unless the account meets certain strategy exclusion requirements. We have employed policies and procedures for Financial Advisors and the composite construction and performance calculation methodology. A third- party vendor has been engaged to examine the performance presentation of the composite. Removal of an Investment Strategy, Model Portfolio, Overlay Manager, or Fund Upon written notice to affected clients, we may remove an Investment Strategy or Model Portfolio from RBC UP or Consulting Solutions if our rating and/or opinion of the Investment Strategy or Model Portfolio materially changes. This will most commonly be a result of fundamental developments that are determined to be detrimental to the potential longer-term success of the Investment Manager, Model Provider, or underlying investment strategy (e.g., departure of key personnel, performance, etc.). In the event RBC WM removes an Investment Strategy from Consulting Solutions, and you do not reallocate applicable account assets prior to the termination of the Investment Strategy, we may terminate your Program account. In RBC UP, when RBC WM removes a Model Portfolio or Investment Strategy selected for your account, if you or your Financial Advisor do not select a new Model Portfolio or Investment Strategy before the removal date, we will move your assets to an available Investment Strategy or Model Portfolio which we deem, in our sole discretion, to be consistent with the removed Model Portfolio/Investment Strategy. If an appropriate replacement Model Portfolio or Investment Strategy is not available, we will move your assets to an appropriate Fund and/or closed-end fund. In RBC UP, we will provide information to your Financial Advisor regarding a Fund that is no longer eligible for the Program. Your Financial Advisor will work with you to select a suitable replacement investment, or the Financial Advisor will select a replacement for you if you have granted your Financial Advisor discretion. In RBC UP, we may change the Overlay Managers upon advance written notice to the affected clients. Related Persons as Investment Manager, Model Provider, and/or Overlay Manager, and Associated Conflicts of Interest If you invest in certain Programs described in this brochure, your account may be managed by an Investment Manager who is an affiliate of ours (also referred to as a related person), or who is a client of an affiliate of ours. In addition, we or our affiliates (or clients of our affiliates) may act as Model Providers. Related persons or their clients acting as Investment Managers or Model Providers are subject to the same eligibility, review, and removal procedures as non-affiliated Investment Managers and Model Providers, as described above. When related persons or their clients act as Investment Managers or Model Providers for Program clients, certain conflicts of interest exist (see Item 9, “Material Relationships with Related Persons,” for more information on conflicts of interest). RBC Wealth Management Advisory Programs Disclosure Document Page 28 of 46 26-25-5088800_25213 (09/26)  In some cases, the same investment strategies are available in both Consulting Solutions and RBC UP. However, the fees associated with these investment strategies may differ depending on the Program. Generally, for fixed income investment strategies available in both Consulting Solutions and RBC UP, the Investment Manager Fee is the same. However, for equity investment strategies available in both Consulting Solutions and RBC UP, the RBC UP Model Provider Fee is generally lower than the Consulting Solutions Investment Manager Fee due to the specific services provided in each Program. Specifically, Consulting Solutions client accounts are separately managed to an Investment Strategy by an Investment Manager on a discretionary basis; while in RBC UP, implementation of, and updates to, Model Portfolios are effected by the Overlay Manager. When we act as Overlay Manager in RBC UP, we retain the 0.05% Overlay Manager Fee that we charge which can give us an incentive to promote RBC UP over Consulting Solutions, particularly where an investment strategy is available in both Programs. Any difference in fees paid by you and fees we pay to the Investment Managers, Model Providers or the Overlay Managers is retained by RBC WM and not shared with our Financial Advisors. Therefore, Financial Advisors do not have a direct financial incentive to recommend using investment strategies in one Program over the other. Our Cash Sweep Program creates a conflict of interest for us because we have an incentive for you to maintain and direct otherwise uninvested cash in your account to Deposit Accounts of our Affiliate Banks and third-party banks, where RBC WM earns a fee on such cash balances and RBC WM and our affiliates can use such deposits to generate additional revenue. Please see above Cash Sweep Program Conflicts of Interest section in Item 4 for additional details. More information regarding the Cash Sweep Program is available in the Cash Management section of our public website at www.rbcwm.com/disclosures. In the Programs, you may be able to invest in affiliated Funds and other affiliated investment products. Certain conflicts of interest among the issuer, Fund, the Fund manager, and/or the broker or agent may exist as described in the PPM or applicable prospectus. Where we are affiliated, through common ownership and control by RBC, with a Fund, Fund manager, issuer or agent, we have an incentive to make our proprietary or affiliated product available over an unaffiliated product, such that the fees and expenses charged by the Fund, Fund manager, issuer or agent are earned by us or our affiliate, rather than a non-affiliate. You may invest in an affiliated Investment Manager and/ or Model Provider. We have an incentive to make our affiliated Investment Managers and Model Providers available because RBC WM and its affiliates receive greater revenue. RBC GAM – U.S. RBC GAM – U.S. acts as an Investment Manager in Consulting Solutions, as a Model Provider in RBC UP and may be selected by clients as an Investment Manager in MAP. This is a conflict of interest as we are incented to recommend RBC GAM – U.S. over non-affiliates. This conflict of interest is addressed by proper disclosure. If you select RBC GAM – U.S. as your Investment Manager in Consulting Solutions or MAP, or as your Model Provider in RBC UP, RBC GAM – U.S. and RBC WM will each collect separate advisory fees for non-retirement accounts. If you select RBC GAM – U.S. as your Investment Manager for your Retirement Account in Consulting Solutions, RBC WM will charge the Program Fee on such Retirement Account, but RBC GAM – U.S. will not charge the Investment Manager Fee on any such Retirement Account. If you select RBC GAM – U.S. as your Investment Manager for your Retirement Account in MAP, RBC WM will not charge the Program Fee on any such Retirement Account, but RBC GAM – U.S. will charge the Investment Manager Fee on any such Retirement Account. In RBC UP, an internally approved Financial Advisor may use limited discretion as described above in Item 4, provided also granted by applicable client(s), to select RBC GAM – U.S. as the Model Provider for a client’s account, as suitable and appropriate. This is a conflict of interest since we have an incentive to select an affiliated Model Provider because the Model Provider Fee will be paid to and received by our affiliate as opposed to an unaffiliated Model Provider. We address this conflict of interest by proper disclosure and by only selecting the most suitable Model Portfolio available for you based on your investment objectives and Advisory Risk Profile. If you, or your Financial Advisor, select RBC GAM – U.S. as the Model Provider for your Retirement Account in RBC UP, RBC WM will charge the Program Fee on such account, but RBC GAM – U.S. will not charge your Retirement Account the Model Provider Fee. RBC Global Asset Management (UK) Limited RBC Global Asset Management (UK) Limited (“GAM UK”) acts as a Model Provider in RBC UP. This is a conflict of interest as we are incented to recommend GAM UK over non-affiliates. This conflict of interest is addressed by proper disclosure. If you select GAM UK as your Model Provider in RBC UP, GAM UK and RBC WM will each collect separate advisory fees for non- retirement accounts. In RBC UP, an internally approved Financial Advisor may use limited discretion as described above in Item 4, provided also granted by applicable client(s), to select GAM UK as the Model Provider for a client’s account, as suitable and appropriate. This is a conflict of interest since we have an incentive to select an affiliated Model Provider because the Model Provider Fee will be paid to and received by our affiliate as opposed to an unaffiliated Model Provider. We address this conflict of interest by proper disclosure and by only selecting the most suitable Model Portfolio available for you based on your investment objectives and Advisory Risk Profile. RBC Wealth Management Advisory Programs Disclosure Document Page 29 of 46 26-25-5088800_25213 (09/26)  If you, or your Financial Advisor, select GAM UK as the Model Provider for your Retirement Account in RBC UP, RBC WM will charge the Program Fee on such account, but GAM UK will not charge your Retirement Account the Model Provider Fee. RBC Rochdale If you select RBC Rochdale as your Investment Manager in MAP, RBC Rochdale and RBC WM will each collect separate advisory fees for non-retirement accounts. This is a conflict of interest as we are incented to recommend RBC Rochdale. To the extent permitted by applicable law, this conflict of interest is addressed by proper disclosure. In addition, where RBC Rochdale acts as Investment Manager for your Retirement Accounts in MAP, RBC Rochdale will not charge the Investment Manager Fee on any such Retirement Accounts. RBC WM and Financial Advisors Acting as Portfolio Managers As discussed above in Item 4, RBC WM acts as the Overlay Manager in RBC UP and certain approved Financial Advisors act as Portfolio Managers in the Portfolio Focus Program. Our participation in a Program creates an incentive for us to recommend such Program where we are the Portfolio Manager over other qualified and suitable Portfolio Managers. Where RBC WM serves as the Overlay Manager in RBC UP, we charge and retain the Overlay Manager Fee component of the Program Fee you pay. PAG independently analyzes research from its research providers and makes such information available to our Financial Advisors and their clients. The research that is produced by PAG is intended to provide a broad and extensive array of fundamental research in the marketplace by focusing on key analysts, recommendations, and trends within their research sources, including those of RBC CM as well as through nationally recognized correspondents. Using such research data provided by PAG, RBC WM also creates equity Model Portfolios for use in RBC UP. RBC WM does not receive a Model Provider Fee for providing these Model Portfolios. In the RBC Advisor and Portfolio Focus programs, Financial Advisors may implement these portfolios, in part or in full, in client accounts. While PAG’s research is independent, RBC WM has a conflict of interest when selecting Funds for inclusion in a model portfolio because we have an incentive to use certain Funds over others. Specifically, we have an incentive to select 1) Funds for which we receive additional compensation from the investments in such Funds, and/or 2) Funds managed by an affiliate of RBC WM which results in compensation to any such affiliate. We mitigate this conflict of interest by disclosure and subjecting RBC WM’s Model Portfolios to review by an internal oversight committee on a regular basis, consistent with the standards employed when reviewing and selecting those of unaffiliated and affiliated Investment Managers and Model Providers, as further detailed in Item 6. Selection of Investment Managers and Model Providers. RBC WM may designate selected Financial Advisors to act as Portfolio Managers in Portfolio Focus. Selected Financial Advisors will manage assets in the Portfolio Focus account on a discretionary basis based on your Advisory Risk Profile and subject to our guidelines for the Program. In RBC UP, designated Financial Advisors who are approved to exercise discretion may select affiliated Model Providers, Investment Managers or other available Investment Products. By selecting any such affiliated Model Providers, Investment Managers and/or Investment Products, an incentive and/or conflict of interest exists in using ourselves over another qualified and/or suitable unaffiliated Model Providers, Investment Managers or Investment Product because we earn more. We mitigate this conflict of interest by proper disclosure and by not providing any compensation or other incentive for your Financial Advisor to select or use affiliated Model Providers, Investment Managers or other Investment Products. Performance-Based Fees and Side by Side Management RBC WM does not charge performance-based fees in the Programs. However, certain Funds and Alternative Investments available in the Programs may be subject to performance-based fees or varying expense charges imposed by the Fund manager or Alternative Investment Manager. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies The methods of analysis used and investment strategies available in each Program are described above in the “Services, Fees and Compensation” and the “Portfolio Manager Selection and Evaluation” sections. We obtain information from various sources including financial publications, company press releases and securities filings, research and due diligence material prepared by RBC WM, our affiliates and other third parties, rating or timing services, regulatory reports, third-party data, and research providers, professionals, and other public sources. Our Financial Advisors may use research, model portfolios and asset allocation recommendations provided by RBC WM, our affiliates and/or third parties to make recommendations to you. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. There is no guarantee of performance for any investment strategy implemented or recommended, and the value of a client’s investments will fluctuate due to RBC Wealth Management Advisory Programs Disclosure Document Page 30 of 46 26-25-5088800_25213 (09/26)  market conditions and other factors. Investments are subject to various risks, including, but not limited to, market, liquidity, currency, economic, and political risk, and will not necessarily be profitable. Past performance does not predict or guarantee any level of future performance. For the strategies used in the Programs, equities, Funds, options, and fixed income securities are the primary investments. Below are certain material risk factors associated with the Programs and the strategies utilized in the Programs. There are certain other risk factors described throughout this brochure. For more details on material risk factors associated with Investment Strategies, Model Portfolios, and/or the services of the unaffiliated Overlay Manager in applicable Programs, please refer to each Investment Manager’s, Model Provider’s, and/or the Overlay Manager’s Form ADV Part 2A brochure and/or other similar disclosure documents. In addition, always read the prospectus or other offering documents for a full description of risks associated with a particular investment. You are urged to consult with your Financial Advisor to discuss the risks associated with any investment strategy, particular investments, securities, and/or transactions recommended or effected in your Program account(s). Some of the material risks associated with investments available in the Program are as follows: • Market Risk. The value of securities owned by an investor may go up or down, sometimes rapidly or unpredictably, due to factors affecting certain industries and/or securities markets generally. • Interest Rate Risk. Fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. • Economic Conditions Risk. The economic, political, or financial developments will, from time to time, result in periods of volatility or other adverse effects that could negatively impact your account. • Credit Risk. Investors could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. • Liquidity Risk. Investors would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments and interval funds have higher liquidity risk than securities traded on exchanges, fixed income securities or open-end mutual funds. • Risks Relating to Equities. The price may rise or fall, sometimes rapidly or unpredictably, because of changes in a company’s financial condition. These price movements can result from economic changes or macro factors such as the economic performance of a particular country, interest rate movements, and international developments. Sector or industry developments as well as changes in government regulations may affect equity prices. • Risk Relating to Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures, and the investor may lose income. • Risks Relating to Specific Styles. Different types of stocks tend to shift in and out of favor depending on market and economic conditions. To the extent a portfolio emphasizes a value or growth style of investing, a portfolio runs the risk that undervalued companies’ valuations will never improve or that growth companies may be more volatile than other types of investments, respectively. • Risks Relating to Securities-Based Lending. Certain Program accounts may be eligible for Margin or other types of securities-based lending as part of RBC WM’s brokerage services. The extension of credit may be obtained through Lending Programs described above. Prior to enrolling in any of the Lending Programs, you should carefully review the agreement and disclosures for such Lending Program and ensure that you understand the risks associated with leveraging your account. You must carefully consider: — Whether or not you can afford, and want, to assume the additional risks that losses in your account may be significantly greater than if you decide not to invest with borrowed funds (i.e., not to use leverage). Leveraging your account may increase your risks and make your investment objectives more difficult to realize you may lose more than your original investment; — You will pay interest on the outstanding loan balance; thus, the use of leverage will increase your costs of investing; — Since the Program Fee is calculated as a percentage of the net market value in a Program account, the use of Margin to purchase additional securities in a Program account will increase the net market value of the Program account by the value of such additional securities purchased with the proceeds of the Margin loan (and will not be offset by the amount of the client’s Margin debit held in an account outside of a Program). This will result in a higher Program Fee you pay to us. This will result in additional compensation to RBC WM and its Financial Advisors; RBC Wealth Management Advisory Programs Disclosure Document Page 31 of 46 26-25-5088800_25213 (09/26)  — RBC WM, or a third-party lender, can force the sale of Program assets to satisfy collateral requirements without notice to you; — Neither RBC WM, our affiliates nor our Financial Advisors will act as an investment adviser to you with respect to the liquidation of securities held in a Program account to meet collateral requirements. These liquidations will be executed in our capacity as broker-dealer and creditor and may, as permitted by and in accordance with applicable laws, rules, and regulations, including the Advisers Act, result in executions on a principal basis in your account; and — Under these circumstances, RBC WM cannot guarantee a favorable price on the sale of Program assets or that the liquidations align with your investment strategy or Advisory Risk Profile. RBC WM is permitted to lend or utilize Margin securities in its possession and receives compensation in connection with the use of such securities. The costs you pay associated with the Lending Programs is not included in the Program Fee and will result in additional compensation to RBC WM, its Financial Advisors, and/or our affiliates. For more information, please see the “Margin Disclosure Statement” on our public website at www.rbcwm.com/disclosures. • Risks Relating to Money Market Funds. An investment in a money market fund is neither insured nor guaranteed by the FDIC or any other government agency. Although money market funds seek to preserve the value of your investment at $1.00 per share, there is no assurance that will occur, and it is possible to lose money if the fund value per share falls. Moreover, in some circumstances, money market funds may be forced to cease operations when the value of a fund drops below $1.00 per share. If this happens, the fund’s holdings are liquidated and distributed to the fund’s shareholders. This liquidation process is likely to take a month or more. During that time, these funds would not be available to you to support purchases, withdrawals and, if applicable, check writing or other money movement debits from your account. • Concentration Risk. To the extent a client concentrates their investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub-sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub-sectors. An individual sector, industry, or sub-sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may not all react in the same way to economic, political, or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub-sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. • Risks Relating to Foreign Securities and Emerging Markets. Investments in securities of foreign issuers denominated in foreign currencies are subject to risks in addition to the risks of securities of U.S. issuers. These risks include political and economic risks, civil conflicts and war, greater volatility, expropriation and nationalization risks, sanctions or other measures by the United States or other governments, currency fluctuations, higher transactions costs, delayed settlement, possible foreign controls on investment, liquidity risks, and less stringent investor protection and disclosure standards of some foreign markets. Events and evolving conditions in certain economies or markets may alter the risks associated with investments tied to countries or regions that historically were perceived as comparatively stable becoming riskier and more volatile. These risks are magnified in countries in emerging markets, which may have relatively unstable governments and less-established market economies than those of developed countries. Emerging markets may face greater social, economic, regulatory, and political uncertainties. These risks make emerging market securities more volatile and less liquid than securities issued in more developed countries. For more information, see the “Risks Related to Foreign Securities and Foreign Currencies section” in the Client Account Agreement and Disclosures, available on our public website at www.rbcwm.com/disclosures. • Risks Relating to Annuities. Annuities are long-term investments and can offer tax-deferred accumulation with options for downside protection, death benefits and lifetime income. Variable annuities are securities that offer a range of investment options, called subaccounts, across different asset classes. Registered indexed linked annuities may also offer subaccounts and a choice of index strategies and provides certain protection against downside market risk and limited participation in index gains without directly investing in the market or an index. Fixed indexed annuities offer a choice of index strategies and provides protection against downside market risk combined with limited participation in gains tied to a particular index without directly investing in the markets or an index. Variable annuities and registered indexed linked annuities have market risk because the contract value fluctuates based on the investment performance of the subaccounts or the index accounts selected. Because the value of a variable annuity and a registered indexed linked annuity is tied to the performance of the investment options chosen, it is subject to investment risk. The value of your annuity will vary and could decline to less than the value of the premiums you have paid. You must pay the annuity fees, charges, and other expenses, regardless of how the annuity performs. Optional guaranteed benefits, which can normally only be elected at the time your annuity contract is issued, could restrict your investment options RBC Wealth Management Advisory Programs Disclosure Document Page 32 of 46 26-25-5088800_25213 (09/26)  and in some cases cannot be reversed. You will pay additional charges for optional benefits and guarantees whether utilized or not. If you want to withdraw or terminate your annuity contract, your withdrawal may be subject to surrender charges or a market value adjustment. These charges are described in the annuity contract and prospectus/ statement of understanding. In addition, your contract with the annuity issuer may include specific guarantees and payment commitments. Those are obligations of the insurance company and are not guaranteed by RBC WM. For information, please consult the annuity product and underlying fund prospectuses which can be obtained from your Financial Advisor or directly from the insurance carrier. • Risk Relating to Alternative Investments. Alternative Investments have different features and risks from other types of investment products. Alternative Investments can be illiquid, volatile, and speculative, and they are not appropriate for all investors. Alternative Investments are generally less liquid than traditional mutual funds because there is no secondary market (with none expected to develop), may offer periodic or no redemption opportunities, require a significant notice period, and/or impose early redemption fees. Additional risks include: the manager’s investment strategies, which may include, but are not limited to, short-selling, leveraging, concentration, frequent trading, derivatives, non-U.S. securities, and certain transactions subject to credit/counter-party risk, volatility of returns, restrictions on transferring interests in the Alternative Investment, absence of information regarding valuations and pricing, complex tax structures and delays in tax reporting, less regulation than mutual funds, “clawbacks” or other restrictions that may require the return of capital previously distributed to you or the payment of additional capital, and investments in companies with short operating histories, few key operating principals and managers, and/or organized and operated outside of the United States. Alternative Investments may also have higher fees (including multiple layers of fees) compared to other types of investments. They may charge an asset-based fee as well as incentive fees based on net profits, which may create an incentive for a manager to make investments which are riskier or more speculative than those which might have been made in the absence of such an incentive, and any other applicable RBC WM Disclosure. Alternative Investments are intended for experienced and sophisticated investors who are willing to bear the high economic risks of the investment including the risk of losing all or a substantial portion of the investment. Individual Alternative Investments will have specific risks related to their investment strategies that vary from investment to investment. For more details on these and other features and risks, please carefully read the offering documents of the Alternative Investment (including risk disclosures), RBC WM’s Alternative Investment Disclosure Form, and your Client Account Agreement and Disclosures. • High-Yield Securities Risk. Certain strategies invest in securities and instruments that are issued by companies that are highly leveraged, less creditworthy, or financially distressed. These investments (known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties, and potential illiquidity. For more information see the “High-Yield Securities Disclosure” on our public website at www.rbcwm.com/disclosures. • Counterparty Risk. An account may have exposure to the credit risk of counterparties with which it deals in connection with the investment of its assets, whether engaged in exchange traded or off-exchange transactions or through brokers, dealers, custodians, and exchanges through which it engages. In addition, many protections afforded to cleared transactions, such as the security afforded by transacting through a clearing house, might not be available in connection with over-the-counter (“OTC”) transactions. Therefore, in those instances in which an account enters into OTC transactions, the account will be subject to the risk that its direct counterparty will not perform its obligations under the transactions and will sustain losses. • Derivatives Risk. Certain strategies may use derivatives. Derivatives, including forward currency contracts, futures, options and commodity-linked derivatives and swaps, may be riskier than other types of investments because they may be more sensitive to changes in economic and market conditions, and could result in losses that significantly exceed the investor’s original investment in the derivative. Many derivatives create leverage thereby causing a portfolio to be more volatile than it would have been if it had not been exposed to such derivatives. Derivatives also expose a portfolio to counterparty risk (the risk that the derivative counterparty will not fulfill its contractual obligations), including the credit risk of the derivative counterparty. Certain derivatives are synthetic instruments that attempt to replicate the performance of certain reference assets. Regarding such derivatives, an investor does not have a claim on the reference assets and is subject to enhanced counterparty risk. Derivatives may not perform as expected, so an investor may not realize the intended benefits. The possible lack of a liquid secondary market for derivatives and the resulting ability to sell or otherwise close a derivatives position could expose a portfolio to losses. Additionally, certain derivatives are subject to position limits imposed by regulators, and the investment adviser will not be able to obtain additional exposure if these limits are reached. When used for hedging, the change in value of a derivative may not correlate as expected with what is being hedged. In addition, given their complexity, derivatives expose an investor to risks of mispricing or improper valuation. RBC Wealth Management Advisory Programs Disclosure Document Page 33 of 46 26-25-5088800_25213 (09/26)  • Risks Relating to Structured Investments. Structured Investments are generally a combination of unsecured debt and other underlying assets. Since Structured Investments represent an unsecured debt obligation of the issuer, you should consider the creditworthiness of the company issuing the security, since downside protections and payment features are contingent upon the solvency of the issuer. The potential benefits of Structured Investments typically will not be fully realized unless held to maturity. For example, if sold prior to maturity, the sale will be subject to market prices and the principal may not be fully returned. There is no guarantee of secondary market price or interim liquidity, and the interim value of a Structured Investment could differ from the original issue price and the investments intrinsic value. Depending on the type of structure, risks of investing in a Structured Investment include, but are not limited to call risk, coupon risk, currency risk, liquidity risk, issuer credit risk, loss of principal risk, risks associated with the performance of underlying assets, and tax risk. Structured Investments are complex and are not appropriate for all investors. You should understand the complete terms, risks, tax consequences, and possible performance outcomes of investing in any Structured Investment before purchasing, as each structure is different and constructed for different investment objectives and market conditions. When considering a Structured Investment, you should review the accompanying prospectus, which will contain more complete information. • Risks Relating to Smaller Companies. Investments in smaller companies are generally riskier than investments in larger companies. The securities of smaller companies may trade less frequently and in smaller volumes than securities of larger companies. Securities of smaller companies tend to be less liquid than securities of larger companies. In addition, small companies are generally more vulnerable to economic, market and industry changes. As a result, the changes in value of their securities may be more sudden or erratic than in large capitalization companies, especially over the short term. Because smaller companies may have limited product lines, markets or financial resources or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than large capitalization companies. This may cause unexpected and frequent decreases in the value of an account’s investments. Finally, emerging companies in certain sectors may not be profitable and may not realize earning profits in the foreseeable future. Voting Client Securities (Proxy Voting) You have the right to vote proxies for securities held in your Program account(s). In general, for Programs other than RBC Advisor, you also have the option to delegate proxy voting authority as described below. If you maintain a Program account with a third-party custodian, you retain the authority and responsibility to vote proxies with respect to securities held in your Program account. In the Advisory Agreement, you indicate your proxy voting authority election for your Program account(s). • Client as proxy authority. For all Programs, you can retain the right to vote proxies with respect to the securities held in the account(s), or delegate that right to another third-party designated by you. If you retain proxy voting authority, we will forward to you (or another third-party designated by you) all proxy-related materials, annual and interim reports, and other issuer-related materials that RBC WM receives pertaining to the securities in your Program account(s). • Manager as proxy authority. For certain Programs, you can delegate your proxy voting authority to a manager to vote proxies with respect to the securities held in your Program account(s). If you delegate voting authority to a manager, we will forward all proxy-related materials, annual and interim reports, and other issuer-related materials that RBC WM receives pertaining to the securities in your Program account(s) to a third-party Investment Manager(s) or the third-party Overlay Manager, RBC WM as Portfolio Focus Manager or RBC WM as Overlay Manager, if applicable, to vote proxies on your behalf. When a client has delegated proxy voting authority to RBC WM, RBC WM further delegates such authority to an independent third-party proxy voting agent, currently Institutional Shareholder Services (“ISS”), as described below. We will not provide you with notice that we have received a proxy solicitation, nor will we or any third-party Investment Manager or proxy voting agent consult with you before casting a vote. Your designation of “Manager” is only valid if accepted by that designee. RBC WM, Investment Managers, and the Overlay Managers retain the right to rescind their acceptance of the proxy authorization. If an Investment Manager or the Overlay Manager elects to stop voting proxies, we will forward proxy voting materials to you (or a third-party agent designated by you), and if an Investment Manager or Overlay Manager elects to start voting proxies, we will send to them all proxy- related materials and you will not receive them. You may change your proxy voting election at any time upon written notice to us, in accordance with the terms of your Advisory Agreement. If you or RBC WM terminate a Program account, RBC WM will revert proxy voting authority to you (or another third-party selected by you). RBC Advisor In RBC Advisor, clients retain the right and authority to vote all proxies for securities. RBC WM does not have, and will not accept, authority to vote client securities held in RBC Advisor accounts. In the Advisory Agreement, if you designate “Manager” RBC Wealth Management Advisory Programs Disclosure Document Page 34 of 46 26-25-5088800_25213 (09/26)  to vote proxies for any RBC Advisor account, we will default proxy voting authority to you, “Client”, and in accordance with applicable law, we will forward to you (or a third-party agent designated by you) all proxy-related materials, annual reports, and other issuer-related materials that RBC WM receives pertaining to the securities in your RBC Advisor account(s). Portfolio Focus and RBC UP If you designate “Manager” as proxy authority for your account(s) in Portfolio Focus and/or RBC UP, RBC WM as Portfolio Focus Manager in Portfolio Focus, or RBC WM or Envestnet as Overlay Manager in RBC UP, will vote proxies on your behalf. When we vote proxies, we have a fiduciary responsibility to vote proxies in a manner that we believe is consistent with your best interest and in accordance with the policies and procedures adopted by RBC WM. We have retained ISS to provide fundamental research and independent voting recommendations based on its standard proxy voting guidelines, and to vote proxies in your account(s) on our behalf. The proxy voting guidelines set forth by ISS are reasonably designed to identify potential conflicts of interest when voting proxies on a client’s behalf. The engagement of ISS as our agent is not intended to be a delegation of our proxy voting responsibilities and does not relieve us of any fiduciary obligations with respect to the voting of proxies. RBC WM has implemented policies reasonably designed to identify potential material conflicts of interest to help us vote proxies without undue influence from individuals or groups who may have an economic interest in the outcome of a proxy vote. These policies include: • Causing the proxies to be delegated to an independent third-party; • Causing the independent third-party to use predetermined voting guidelines; • Causing proxies to be voted in accordance with recommendations of an independent third-party. While ISS uses its best efforts to vote proxies, there are instances when they do not vote proxies because voting is not practical or is not in the best interest of clients. For example, casting a vote on a foreign security may involve additional costs or may prevent, for a period of time, sales of shares that have been voted. Additionally voting may be restricted when a security is a privately held company or a preferred stock where ISS does not have a separate service contract to provide a vote recommendation, or the voting instructions require a vote from either a controlling shareholder or shareholder with personal interest. You may contact your Financial Advisor to request and obtain a copy of our proxy voting policies and procedures, ISS’ standard proxy voting guidelines, and records of how RBC WM voted proxies with respect to securities held in your Program account(s). Consulting Solutions and MAP If you designate “Manager” as proxy voting authority for your account(s) in Consulting Solutions and/or MAP, such designation of proxy voting authority is subject to acceptance by the applicable Investment Manager in its sole discretion. Pursuant to this designation, you (i) authorize the selected Investment Manager to receive the proxy-related materials, annual and interim reports, and other issuer-related materials for securities in your account(s), and (ii) delegate to the Investment Manager the proxy voting rights for those securities. If an Investment Manager has elected to not vote client proxies, you (or another third-party agent designated by you) will be responsible for voting proxies for the securities in your Program account(s). Retirement Accounts With respect to Retirement Accounts subject to Title I of ERISA, we shall have no responsibility or authority to vote proxies on behalf of such account. The voting of proxies is reserved to a named fiduciary of the plan as selected by you. Unless you indicate otherwise in the Advisory Agreement, RBC WM, the Investment Manager(s) selected by you and/ or the Overlay Manager(s) are expressly precluded from voting proxies on behalf of any Retirement Account subject to Title I of ERISA (although we may, in our capacity as a broker, act pursuant to the instructions of a named plan fiduciary). We deem the authority to vote proxies as expressly reserved to a named plan fiduciary and therefore, we have no obligation and will not accept any authority to take action on your behalf with respect to any proxy-related material. ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS To open a Program account, you must provide certain information to RBC WM regarding your risk tolerance, investment objectives, financial situation, and other important information. In managing your account(s), we rely on the completeness and accuracy of the information you provide, and it is your responsibility to promptly notify RBC WM if any of the information you provided changes. Except as otherwise agreed to in writing or as required or permitted by law, RBC WM will keep confidential all information concerning your identity, financial data, and investments. We share relevant client information with (1) the Investment Manager(s) and/or Overlay Manager(s) in order for such Investment Manager(s) and/or Overlay Manager(s) to adequately RBC Wealth Management Advisory Programs Disclosure Document Page 35 of 46 26-25-5088800_25213 (09/26)  manage your Program account(s), and (2) certain companies that we or your selected Investment Manager(s) and/or Overlay Manager(s) partner with to service your Program account(s). For MAP accounts, however, unless otherwise indicated, we generally do not provide client information to Investment Managers. Since clients enter into a separate agreement with their Investment Manager(s) in MAP, clients are solely responsible for providing their own information, and updates thereto, to any such Investment Manager(s) used through MAP, and for ensuring the accuracy and completeness of such information. We shall have no responsibility for the information a client provides to their Investment Manager(s) in MAP. ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS For the Programs that involve Investment Managers and Overlay Managers, RBC WM does not place restrictions on clients contacting and consulting directly with the Investment Managers or the Overlay Managers. However, unlike the Investment Managers, the Model Providers do not have direct investment advisory relationships with clients and may have their own restrictions on such contact and consultation. Clients are encouraged to review the Form ADV Part 2A brochure(s) or other similar disclosure documents of any Investment Manager(s), the Overlay Manager (Envestnet), and/or Model Provider(s) for information on whether they have any of their own restrictions on direct client communication. ITEM 9: ADDITIONAL INFORMATION Disciplinary Information The following is a summary of certain adverse legal and disciplinary events and regulatory settlements during the last 10 years that may be material to your decision of whether to retain us for your investment advisory needs. You can find additional information regarding these settlements in Part 1 of our Form ADV at www.adviserinfo.sec.gov. • In June 2025, RBC CM entered into a settlement (the “Settlement”) with the Securities Division of the Office of the Secretary of the Commonwealth of Massachusetts regarding allegations that RBC CM charged unreasonable commission for certain equity transactions, and did not reasonably supervise these transactions in violation of § 204(a) (2)(J) of the Massachusetts Uniform Securities Act. RBC CM agreed to pay restitution in an amount no less than $113,295.06, plus 6% compounded interest, to affected Massachusetts customers. RBC CM also agreed to provide restitution, plus 6% compounded interest, to affected customers of other jurisdictions that agree to the terms of an agreement (“Term Sheet”) between RBC CM and a multi-state group, including Massachusetts, executed contemporaneously with the Settlement. RBC CM agreed to pay an administrative fine in an aggregate amount not to exceed $1,095,000 to the jurisdictions agreeing to the terms of the Term Sheet, which includes $25,000 to be paid to Massachusetts. • On August 14, 2024, RBC CM entered into a settlement order with the SEC in connection with RBC CM’s recordkeeping practices concerning business-related electronic communications sent or received by firm personnel using non-approved channels or methods (“off-channel communications”). The SEC found that from at least June 2019 to August 2024, RBC CM willfully violated Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder in connection with RBC CM’s failure to maintain and preserve the substantial majority of off-channel communications of its personnel that were records required to be maintained under Exchange Act Rule 17a-4(b)(4) and/or Advisers Act Rule 204-2(a)(7); and therefore, failed to reasonably supervise its personnel within the meaning of Section 15(b)(4)(E) of the Exchange Act and Section 203(e)(6) of the Advisers Act. RBC CM admitted to the facts in the settlement order and acknowledged its conduct violated the federal securities laws. The SEC ordered RBC CM to cease and desist from committing or causing any violations and any future violations of Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2 thereunder, censured it for its conduct, ordered it to pay a civil monetary penalty in the amount of $45,000,000, and ordered it to comply with the undertakings enumerated in the settlement order. • RBC CM consented to FINRA sanctions and findings that its supervisory system did not provide certain customers with mutual fund sales charge waivers and fee rebates to which they were entitled through rights of reinstatement offered by mutual fund companies, which resulted in the payment of $264,939.44 in excess sales charges and fees by eligible customers. On July 2, 2024, RBC CM was censured, fined $75,000 and required to certify that it had remediated the issues and implement reasonably designed supervisory system, including written supervisory procedures (“WSPs”). The firm also made full restitution, plus interest, to the affected customers. • RBC CM consented to FINRA sanctions and findings that it sent trade confirmations to customers that contained inaccurate information. The findings stated that the firm sent its institutional customers confirmations for fixed income transactions, including certain municipal securities transactions, that inaccurately stated that the transactions were executed in an agency capacity, when they were executed in a principal capacity. The firm also sent its institutional customers trade confirmations that inaccurately stated that certain transactions that were solicited were unsolicited RBC Wealth Management Advisory Programs Disclosure Document Page 36 of 46 26-25-5088800_25213 (09/26)  and vice versa. In addition, the firm failed to deliver trade confirmations to customers that had requested electronic delivery of trade confirmations and failed to send trade confirmations for millions of dividend reinvestment program (“DRIP”) transactions. The findings also stated that the firm failed to establish, maintain, and enforce a supervisory system, including WSPs, reasonably designed to achieve compliance with trade confirmation requirements. The findings also included that the firm violated Regulation T promulgated by the board of governors of the federal reserve system under Section 7 of the Exchange Act by extending credit to certain customers of the firm and its introducing firms, which resulted in hundreds of incorrectly executed trades in those accounts and the frequent selling of the positions at issue to generate proceeds to cover the purchases. In connection with these transactions, customer accounts incurred commissions, markups, markdowns, and fees totaling $392,525.50, that they would not otherwise have incurred had the firm cancelled the trades. In addition, introducing firm customer accounts incurred $1,308 in fees in connection with these trades that they would not have incurred had the firm cancelled the trades. On April 29, 2024, RBC CM was censured, fined $375,000, ordered to pay $393,833.50 in restitution to customers, and required to certify that it has remediated the issues and implemented a supervisory system, including WSPs. • On November 2, 2023, RBC CM entered into a settlement with the SEC resulting in the SEC issuing an Order. RBC CM consented to the entry of the Order that found that RBC CM failed to make and keep books, records, and accounts, which, in reasonable detail, accurately and fairly reflected the transactions and dispositions of the assets of the issuer and failed to devise and maintain a system of internal account controls sufficient to provide reasonable assurance that transactions are recorded to permit preparation of financial statements in conformity with generally accepted accounting principles. The Order directs that RBC CM cease-and-desist from committing or causing any violations and any future violations of Sections 13(B) (2)(A) and 13(B)(2)(B) of the Exchange Act. On November 2, 2023, without admitting or denying the findings, RBC CM consented to the Order and was fined $6,000,000. • In May 2023, RBC CM entered into a settlement with the Commonwealth of Virginia’s State Corporation Commission’s Division of Securities and Retail Franchising (the “Division”) regarding allegations that it employed an investment adviser representative in the Commonwealth of Virginia without that person being duly registered with the Division, in violation of § 13.1-504 c (ii) of the Virginia Securities Act. RBC CM agreed to pay a $10,000 monetary penalty and $1,000 for the cost of the investigation. • In April 2023, without admitting or denying the findings, RBC CM reached a settlement with FINRA and consented to sanctions and the entry of findings that it failed to establish and maintain a supervisory system reasonably designed to achieve compliance with its suitability obligations in connection with syndicate preferred stock in brokerage accounts. The findings stated that while the firm’s procedures called for supervisors to closely examine representatives’ short-term trading of preferred stocks, the firm’s electronic surveillance of short-term trading in preferred stock was unreasonably designed, and it failed to monitor for that activity. Although the surveillance system had certain alerts that specifically monitored for short-term trading in other products, such as closed-end funds, it did not have any alerts that specifically monitored for short-term trading in preferred stock. The firm also did not have any other alerts that flagged the purchase and sale within 180 days of syndicate preferred stock. Certain of the firm’s registered representatives recommended that a number of the firm’s retail customers purchase syndicate preferred stocks, and then sold the positions within 180 days, and such customers sustained losses on these transactions. The firm earned $653,313 in selling concessions from these syndicate purchases and $128,643 in sales commissions from the subsequent sales. The firm conducted a substantial syndicate preferred stock business yet did not maintain a reasonable supervisory system to monitor whether its representatives recommended short-term trading of syndicate preferred securities that was unsuitable, including for the purpose of capturing sales concessions and commissions. The firm was censured, fined $300,000, ordered to pay $128,643.17, plus interest, in restitution to customers, ordered to pay $653,312.83, plus interest, in disgorgement, and required to certify that it has remediated the issues identified in this AWC and implemented a supervisory system, including WSPs, reasonably designed to achieve compliance with FINRA Rule 3110 regarding the issues identified in this AWC. • On March 3, 2022, RBC CM affiliate and registered investment adviser, CNR, reached a settlement with the SEC concerning CNR’s breach of its fiduciary duty relating to the use of proprietary Funds and certain share classes in advisory accounts. Those Funds generated fees for CNR and its affiliates, rather than competitor funds within the same asset classes that may not have generated such fees and created a conflict that was not disclosed. The SEC determined that CNR willfully violated sections 206(2) and 206(4) of the Advisers Act as well as Rule 206(4)-7 by failing to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. Under the terms of the settlement, CNR paid $30,361,804 in fines, disgorgement, and interest. • Without admitting or denying the findings, RBC CM consented to the sanctions and to the entry of findings that it failed to establish, maintain, and enforce a supervisory system, including WSPs, reasonably designed to achieve compliance with FINRA and Municipal Securities Rulemaking Board (“MSRB”) rules with respect to representatives’ recommendations of high-yield corporate and municipal bonds. The findings stated that the firm’s policies and procedures did not sufficiently address the suitability factors that representatives should consider before recommending high-yield bonds. On December 15, 2021, RBC CM was censured, fined $550,000, and ordered to pay $456,155, plus interest, in restitution to customers. RBC Wealth Management Advisory Programs Disclosure Document Page 37 of 46 26-25-5088800_25213 (09/26)  • On September 17, 2021, RBC CM entered into a settlement with the SEC resulting in the SEC issuing an Order. RBC CM consented to the entry of the Order which found that from 2014-2017, RBC CM engaged in improper conduct in connection with the allocation, purchase, and sale of certain new issue municipal bond offerings in violation of internal procedures, as well as MSRB and SEC rules. The Order found that RBC CM’s conduct violated MSRB and SEC rules. The Order censured RBC CM and required RBC CM to pay disgorgement of $552,440, prejudgment interest of $160,886.97, and $150,000 as a civil penalty to the SEC. Such payments were made by RBC CM on September 22, 2021. • The Virginia State Corporation Commission found that, from December 1, 2017, through November 27, 2020, RBC CM employed an investment adviser representative (“IAR”) who was registered in the District of Columbia but not Virginia and that RBC CM failed to enforce its WSPs regarding IAR registration. On September 8, 2021, RBC CM executed the settlement order which states that RBC CM neither admits nor denies the Virginia state corporation commission’s allegations and paid a $10,000 civil penalty. • It was found by the NYSE that RBC CM violated NYSE Rule 3110(a) and (b) (Supervision) by failing to establish and maintain a supervisory system and WSPs reasonably designed to detect and prevent errors in market on close orders. On July 6, 2021, RBC CM entered into a letter of acceptance, waiver and consent with the NYSE under which RBC CM consented to the sanctions and was censured and fined $10,000. • It was found that RBC CM violated SEC Rule 15c3-5(b) and (c)(1)(ii) and Rules 3.2 and 5.1 of the CBOE BZX Exchange, Inc., CBOE EDGA Exchange, Inc., CBOE BYX Exchange, Inc., and CBOE EDGX Exchange, Inc. due to the fact that the Firm’s financial risk management controls and supervisory procedures were not reasonably designed to (i) prevent the entry of erroneous orders, (ii) reject orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time, or (iii) reject duplicative orders. On March 30, 2021, without admitting or denying the findings, RBC CM was censured and fined $45,000 by CBOE BZX Exchange, Inc., $45,000 by CBOE EDGA Exchange, Inc., $70,000 by CBOE BYX Exchange, Inc. and $45,000 by CBOE EDGX Exchange, Inc. • The Massachusetts Securities Division found that RBC CM failed to adequately supervise its representatives with respect to concentration and suitability of master limited partnership energy and telecom positions in certain client accounts. On February 2, 2021, without admitting to any supervisory deficiencies, RBC CM agreed to the described sanctions and fines totaling $320,267.41.Without admitting or denying the findings, on December 15, 2020, RBC CM consented to the sanctions and to the entry of findings that it failed to establish and maintain a supervisory system reasonably designed to supervise representatives’ recommendations to customers to purchase particular share classes of 529 college savings plans. The findings stated that RBC CM did not provide adequate guidance to representatives regarding the importance of considering share class differences when recommending 529 plans and had no procedures requiring supervisors to review 529 plan share class recommendations for suitability. RBC CM updated its procedures to include such a requirement, but the updated procedures failed to adequately instruct supervisors to consider either the age of the beneficiary or the number of years until expected withdrawals, both critical factors in determining the suitability of the recommended share class. Also, RBC CM did not consistently provide supervisors with the information necessary to review the suitability of 529 plan share class recommendations. Later, RBC CM issued a company-wide compliance alert that provided guidance to representatives regarding 529 plan share class recommendations. RBC CM then updated its supervisory systems and procedures with respect to 529 share class recommendations. Among other things, RBC CM instructed supervisors to consider the age of the beneficiary when assessing the suitability of a representative’s 529 share class recommendation. RBC CM has agreed to pay restitution and interest relating to the sale of class C shares to certain 529 plan customers in the estimated amount of $839,803. • The SEC found that from at least July 2012 through August 2017, RBC CM disadvantaged certain retirement plan and charitable organization brokerage customers who maintained accounts at RBC CM (“Eligible Customers”) by failing to ascertain that they were eligible for a less expensive share class and recommending and selling them more expensive share classes in certain open-end Funds when less expensive share classes were available. RBC CM did so without disclosing that it would receive greater compensation from the Eligible Customers’ purchases of the more expensive share classes. Eligible Customers did not have sufficient information to understand that RBC CM had a conflict of interest resulting from compensation it received for selling the more expensive share classes. Specifically, RBC CM recommended and sold these Eligible Customers class A shares with an up-front sales charge, or class B or class C shares with a back- end contingent deferred sales charge (a deferred sales charge the purchaser pays if the purchaser sells the shares during a specified time period following the purchase) and higher ongoing fees and expenses, when these Eligible Customers were eligible to purchase load-waived class A and/or no-load class R shares. RBC CM omitted material information concerning its compensation when it recommended the more expensive share classes. RBC CM also did not disclose that the purchase of the more expensive share classes would negatively impact the overall return on the Eligible Customers’ investments, in light of the different fee structures for the different fund share classes. In making those recommendations of more expensive share classes while omitting material facts, RBC CM violated sections 17(a)(2) and 17(a)(3) of the Securities Act. These provisions prohibit, respectively, in the offer or sale of securities, obtaining money or property by means of an omission to state a material fact necessary to make statements made not misleading, and engaging in a RBC Wealth Management Advisory Programs Disclosure Document Page 38 of 46 26-25-5088800_25213 (09/26)  course of business which operates as a fraud or deceit on the purchaser. As a result of the conduct described above, RBC CM willfully violated sections 17(a)(2) and 17(a)(3) of the Securities Act. On April 24, 2020, RBC CM was censured and paid disgorgement of $2,607,676, prejudgment interest of $631,331, plus a civil monetary penalty of $650,000. • Without admitting or denying the findings, RBC CM consented to the sanctions and the entry of findings that RBC CM entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of RBC CM. The findings state that RBC CM ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In addition, for the calendar year 2018 RBC CM conducted 11 of 12 monthly origin code reviews late because RBC CM failed to enforce its procedures requiring timely origin code reviews. Between August 28, 2019, and October 2, 2019, RBC CM settled for a total of $100,000 across eight exchanges (NASDAQ PHLX LLC $7,138; NASDAQ Stock Markets/The NASDAQ Options Market $5,687; CBOE BZX Exchange, Inc. $28,271; NASDAQ ISE, LLC Fine $6,721; NYSE American LLC $4,098; NYSE ARCA, Inc. $5,509; CBOE Exchange, Inc.: $36,592; and CBOE C2 Exchange, Inc., $5,984). • FINRA found that from March 2008 to June 2016, RBC CM failed to make the statutorily required delivery of prospectuses to customers who purchased approximately 165,000 ETFs and notes and hundreds of thousands of open-end and closed- end mutual funds. RBC CM failed to design, implement, and enforce a reasonable supervisory system, procedures and set of controls to comply with prospectus delivery rules for Funds and as a result, failed to discover the delivery failures until FINRA’s investigation into the matter. On October 17, 2019, RBC CM was censured and fined in the amount of $2,900,000. • RBC CM self-reported to the SEC the violations described below pursuant to the Division of Enforcement’s Share Class Selection Disclosure Initiative (“SCSD Initiative”). The SEC found that RBC CM, during the period of January 1, 2014, through March 27, 2017, failed to make adequate disclosures, in its Form ADV or otherwise, regarding its Fund share class selection practices, and the 12b-1 fees it received, in connection with advisory account transactions. Specifically, at times during the relevant period, RBC CM purchased, recommended, or held in advisory accounts Fund share classes that charged 12b-1 fees instead of lower cost share classes in the same fund. The SEC found that RBC CM failed to adequately disclose the receipt of the 12b-1 fees and the associated conflict of interest, thereby willfully violating Sections 206(2) and 207 of the Advisers Act. On March 11, 2019, without admitting or denying the findings, the SEC issued, and the firm consented to the entry of an order (the “Order”) that censured RBC CM and directs it to cease-and-desist from committing or causing any violations and any future violations of Sections 206(2) and 207 of the Advisers Act. Additionally, the Order requires Respondent to pay disgorgement of $10,494,813.38, prejudgment interest of $1,220,581.34, and to comply with the other undertakings enumerated in the Order as part of the settlement. Other Financial Industry Activities and Affiliations Broker-Dealer Registrations RBC CM is registered with the SEC as a broker-dealer and investment adviser. Certain of RBC WM’s management personnel and all of its Financial Advisors and their supervisors are registered with FINRA as representatives of RBC CM in its capacity as a broker- dealer. Further, RBC CM is a member of the NYSE, FINRA, SIPC, and several other exchanges and self-regulatory organizations. Futures/Commodities-Related Registrations RBC CM is also registered with the Commodity Futures Trading Commission (“CFTC”) as a futures commission merchant and swap firm. Material Relationships with Related Persons In addition to sponsoring the Programs, RBC CM sponsors other non-wrap investment advisory programs and engages in a broad range of brokerage and other financial services. These services include public and private investment banking and underwriting, retail and institutional brokerage and trading, institutional research and numerous other brokerage, advisory and financial services. Clients of RBC CM may include Investment Managers and Overlay Managers available in the Programs. We have multiple affiliated entities engaged in many different business activities. The business interests of our affiliates may not align with the interests of our brokerage services. Consequently, our firm may be subject to pressure from our affiliates to protect their business interests. This pressure creates a conflict of interest because it incentivizes us to make recommendations to you, or refrain from making recommendations to you, in a manner which best protects those business interests. We, our related persons, and affiliates may purchase for our own accounts securities that are recommended to Program clients. RBC WM and our affiliates may give advice and take action in performing our duties to other clients that differs from advice given, or the timing and nature of action taken, with respect to you. Nonpublic Information In the course of our respective investment banking or other activities, we and our affiliates may, from time to time, acquire confidential or material nonpublic information about corporations or other entities or their securities that may prevent us or them, for a period, from purchasing or selling particular securities in your Program account. We and our affiliates will RBC Wealth Management Advisory Programs Disclosure Document Page 39 of 46 26-25-5088800_25213 (09/26)  not be permitted to divulge or to act upon any such information with respect to our or our affiliates’ advisory or brokerage activities, including activities with regard to your Program account. Restrictions on Certain Securities Transactions From time to time, restrictions on certain securities transactions are imposed by RBC CM to address the potential for self- dealing and conflicts of interest that arise in connection with RBC CM ’s broker-dealer and investment banking businesses. RBC CM has adopted various procedures to guard against insider trading that include an “Information Barrier” procedure, pursuant to which information known within one area of RBC CM (e.g., investment banking) is not permitted to be distributed to other areas (e.g., investment advisory), and the use of a restricted list and various other monitoring lists. These investment banking or other activities will from time to time compel RBC CM to forgo investing in (or liquidating) the securities of companies with which these relationships exist. These restrictions may adversely impact the investment performance of an advisory client’s account. RBC GAM – U.S. RBC GAM – U.S. is an affiliate of RBC CM. RBC GAM – U.S. is a federally registered investment adviser that provides portfolio management services to institutional separate accounts, registered investment companies, pooled vehicles, and portfolio management services for wrap fee accounts and Model Portfolios offered by other Providers. RBC CM makes RBC GAM – U.S. available as an Investment Manager in the Consulting Solutions Program, a Model Provider in RBC UP, and permits clients to select RBC GAM – U.S. in MAP. In the Cash Sweep Program, you may have a balance in the RBC BlueBay U.S. Government Money Market Fund (TIMXX), managed by RBC GAM – U.S., due to it formerly being offered as a Cash Sweep Option. A lower cost share class of the same RBC BlueBay U.S. Government Money Market Fund (TUGXX) is also available outside of the Cash Sweep Program. TUGXX is subject to eligibility requirements for Retirement Accounts. For amounts invested in shares of the RBC GAM – U.S. managed money market fund, our affiliate RBC GAM – U.S. will receive fees for managing and servicing the fund. RBC GAM – U.S. will also pay RBC WM 12b-1 fees, which provides us with another incentive to use this money market fund instead of another fund that does not pay us the same or any revenue share. We address this conflict of interest by proper disclosure and by rebating or not charging omnibus, management, and/or 12b-1 fees to Retirement Accounts, including IRAs and Retirement Accounts. City National Bank In certain instances, we, through our Financial Advisors, will refer clients to CNB for certain banking products and services, or CNB will refer clients to us for brokerage and other investment services. In such cases, the referring party will, as permitted by applicable law, receive fees and compensation in connection with these products and services in connection with any such referral. The cash sweep program used by CNB for otherwise uninvested cash uses a proprietary fund that is managed by RBC WM. Where a Program client utilizes the CNB cash sweep program, there is a conflict of interest for RBC WM because the larger the uninvested cash balance in the Program client’s account, the more compensation RBC WM and CNB receive from CNB’s cash sweep program (and the proprietary fund managed by RBC WM). This creates an incentive for RBC WM to recommend or direct investments that result in cash being invested through the cash sweep program of CNB. RBC Rochdale RBC Rochdale is a subsidiary of CNB. RBC Rochdale is a federally registered investment adviser that provides investment management services to high-net-worth individuals, families, and foundations. RBC Rochdale may also serve as investment adviser and/or sub-adviser to Funds that RBC CM may recommend. This is a conflict of interest as we are incented to recommend Funds subadvised by RBC Rochdale or third-party Funds sub-advised by RBC Rochdale. This conflict of interest is addressed by proper disclosure and by rebating or not charging certain fees to Retirement Accounts, including IRAs and Retirement Accounts subject to ERISA. In addition, clients are permitted to select RBC Rochdale as their Investment Manager in MAP. RBC USA Holdco Corporation RBC CM, RBC GAM – U.S. and CNB are wholly-owned subsidiaries of RBC USA Holdco Corporation, which is a wholly owned indirect subsidiary of RBC. RBC Global Asset Management (UK) Limited GAM UK is a wholly owned indirect subsidiary of RBC and an affiliate of RBC CM. GAM UK serves as sub-adviser to certain U.S. registered Funds for which RBC GAM – U.S. or other third parties serve as the investment adviser. Such Funds may be recommended by RBC CM. This is a conflict of interest as we have an incentive to recommend Funds that are sub-advised by our affiliates over other products. To the extent permitted by applicable law, this conflict is addressed by proper disclosure and by not assessing the RBC WM Advice Fee or the Overlay Manager Fee component of the Program Fee, when RBC WM acts as Overlay Manager, to the value of these Funds held in Retirement Accounts, including IRAs and Retirement Accounts subject to ERISA. In addition, RBC CM makes GAM UK available as a Model Provider in RBC UP. RBC Wealth Management Advisory Programs Disclosure Document Page 40 of 46 26-25-5088800_25213 (09/26)  Trust and Estate Settlement Services Clients can select CNB, a nationally chartered bank and trust company, or its subsidiary RBC Trust Company (Delaware) Limited (“RBC Trust”), a Delaware chartered trust company as professional trust and estate settlement service providers. RBC WM and its Financial Advisors are generally prohibited from serving as trustees. Clients can also select TrustCorp America (“TCA”), a Washington, D.C. chartered trust company, as a professional trust and estate settlement service provider. RBC CM has a minority interest in TCA. For more information, see the “City National Referral Disclosure Statement” on our public website at www.rbcwm.com/disclosures. Cash Sweep Program RBC WM and Affiliated Banks receive financial benefits in connection with Cash Sweep Options managed or held by such Affiliated Banks. See Item 4, “Cash Balances and the Cash Sweep Program,” for a description of the Cash Sweep Options and related conflicts of interest. Lending Programs Royal Bank of Canada and RBC Bank receive financial benefits in connection with Lending Programs managed or held by Royal Bank of Canada and RBC Bank. See Item 4, “Securities-Based Lending” for a description of the Lending Programs and related conflicts of interest. Other Material Relationships Marketing and Operational Support Payments RBC WM receive cash payments and/or other financial benefits from certain Funds, ETPs, UITs, Alternative Investments, insurance companies, Investment Managers, Model Providers, and/or Envestnet (“Marketing Support”). Marketing Support is used to offset compliance and product management costs, for training and education programs, due diligence meetings, conferences, and/or to provide our employees with business entertainment, expense reimbursement for travel associated with these meetings and conferences, financial assistance in covering the cost of certain marketing and sales events, and small gifts. RBC WM’s existing or prospective clients also receive related financial benefits, such as seminars, education programs and small gifts. Marketing Support cash payments received by RBC WM vary and may be paid based on a percentage of client assets in certain securities or investment products, and/or based on a flat dollar amount. RBC WM does not receive payments from mutual fund companies based on a percentage of mutual fund assets held in advisory Retirement Accounts. RBC WM receives payments from certain Fund companies which are used in part to offset administrative and operational costs RBC WM incurs in connection with providing certain sub-accounting and sub-transfer agent services in distributing Funds and provides a financial benefit to RBC WM (“Operational Support”). These costs include sending shareholder statements, maintaining shareholder records, and performing regulatory mailings. RBC WM rebates Operational Support payments received from mutual fund companies to clients with Retirement Accounts where RBC WM has discretionary authority. Marketing Support and/or Operational Support payments create a conflict of interest because we are incentivized to utilize companies and recommend securities and investment products for which we earn greater compensation over companies, securities, and investment products that do not make such payments. We address this conflict through disclosure and by selecting companies, securities and investment products based on merit, qualitative and quantitative evaluations, performance, and risk management practices and not based on the amount of revenue we receive. Further, we determine compensation to your Financial Advisor generally based on a percentage of assets in the Program(s) without regard to these Marketing Support and/or Operational Support arrangements. In general, Funds and ETPs of companies that make Marketing Support and/or Operational Support payments to RBC WM have higher expense ratios than Funds and ETPs of companies that do not make such payments. The receipt of Marketing Support and/or Operational Support payments from Fund and ETP companies by RBC WM is one of multiple factors that RBC WM considers when deciding which Funds and share classes or ETPs to make available to clients. RBC WM has a conflict of interest in choosing a Fund or an ETP (with higher expense ratios) of companies that make the above-referenced payments to RBC WM for selling/distributing their Funds and/or ETPs. A higher expense ratio will adversely affect investment performance. We address this conflict by not making our Financial Advisors aware of the specific financial arrangements and by not providing Financial Advisors any additional compensation in connection with the receipt of these payments by RBC WM. These conflicts of interest are also addressed by appropriate disclosure in this brochure. For a list of Fund families from which RBC WM receives payments described herein, please see “Mutual Fund and ETF Arrangements” at www.rbcwm.com/disclosures. Data Analytics RBC WM provides the opportunity for asset managers and other product issuers to purchase data specific to assets held and sales generated by our Financial Advisors. Data provided includes those related to mutual funds, interval funds, ETFs and separately managed accounts (which include Model Portfolios provided by non-discretionary Investment Managers and RBC Wealth Management Advisory Programs Disclosure Document Page 41 of 46 26-25-5088800_25213 (09/26)  Investment Strategies managed by Investment Managers on a discretionary basis). It does not include any client specific data. This data helps firms in establishing and maintaining efficiencies in their product development, distribution and wholesaling efforts. Fees collected may differ by asset manager. This creates a conflict of interest for us because we have an incentive to offer products from asset managers that choose to purchase data. We mitigate this conflict by making the purchase of data analytics optional and by not making the purchase of data a determining factor in the selection of products available to our clients. This fee is not shared with your Financial Advisor. Money Market Mutual Fund Payments RBC WM makes available certain money market mutual funds (“money markets”) for purchase in brokerage and advisory accounts. These money market mutual funds are separate from cash sweep options otherwise available and are purchased and redeemed in a manner consistent with the order entry process of open-end mutual funds. RBC WM receives compensation from certain fund companies which may have been generated from the fund in the form of management fees, shareholder service fees, support services fees, administration fees, supplemental payments or other similar fees or expenses. This compensation is used in part to offset costs associated with servicing client accounts. The payments to RBC WM vary by fund company. As a result, RBC WM has a conflict of interest in offering money markets and share classes in which we receive these payments. RBC WM mitigates this conflict through disclosure and by not providing financial incentives to our Financial Advisors based on money market strategy selection. RBC WM does not receive payments from Fund companies for assets in money markets held in Program Retirement Accounts. Federated Investment Counseling Federated Investment Counseling (including its Federated Hermes CW Henderson division) is an unaffiliated investment adviser registered with the SEC. As of the date of this brochure, Federated Investment Counseling (and one or more of its Investment Strategies and/or Model Portfolios, as applicable) is available for selection as an Investment Manager in Consulting Solutions and as a Model Provider or Investment Manager in RBC UP. In addition, Federated Investment Management Company is the investment adviser for the only unaffiliated money market fund available as a Cash Sweep Option for advisory clients. The Federated Hermes Treasury Obligations Fund (TOAXX) is the Cash Sweep Option RBC WM makes available to qualified Retirement Accounts and is a secondary Cash Sweep Option for non-qualified Retirement Accounts in RBC Insured Deposits. Cash balances in accounts managed by Federated Investment Counseling as Investment Manager in Consulting Solutions or invested in a Federated Investment Counseling Model Portfolio or Investment Strategy in RBC UP, will be invested in any such client’s selected Cash Sweep Option, which may be the Federated Hermes Treasury Obligations Fund (TOAXX). As discussed in Item 4, clients pay the Program Fee on the total value of the assets in their Program account, including cash balances. As a result, you should be aware that if Federated Investment Counseling is the discretionary Investment Manager for your Consulting Solutions account or RBC UP account Sleeve, or the Model Provider that delivers its Model Portfolio in which your RBC UP account is invested, you will pay Federated Investment Counseling advisory fees on all assets, including cash balances. If the Cash Sweep Option for your Program account is the Federated Hermes Treasury Obligations Fund (TOAXX), you will also pay Federated Hermes applicable money market mutual fund fees and expenses on these same cash balances, as described above in the section titled “Cash Balances and the Cash Sweep Program.” Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics and Personal Trading RBC WM has adopted an Investment Adviser Code of Ethics (the “IA Code of Ethics”) in accordance with Rule 204A-1 of the Advisers Act, which applies to all RBC WM employees, contingent workers, contract workers and interns (“Covered Persons”), with limited exceptions. The IA Code of Ethics sets forth the standards of business conduct applicable to RBC WM and its Covered Persons (i.e., to act with integrity, honesty, and professionalism and to always act in the best interests of our clients) and is designed to ensure that RBC WM and its Covered Persons comply with applicable federal and state securities laws and regulations. The IA Code of Ethics also highlights that as an investment adviser and fiduciary, RBC WM and its Covered Persons have an affirmative duty to always act in the best interest of our advisory clients, which means their interests must always come first. This means that when acting in an investment advisory capacity, Covered Persons are responsible to: (i) put client interests before their own; (ii) act with utmost good faith; (iii) provide full and fair disclosure of all material facts; (iv) not mislead clients; and (v) disclose all potential, perceived, and/or actual conflicts of interest to clients. The IA Code of Ethics also includes guidelines regarding personal securities transactions of, and the maintenance of personal securities accounts by, its Covered Persons (with the exception of interns) in accordance with the RBC WM’s policies on outside securities accounts, employee/employee-related accounts, and the personal trading policy specific to Financial Advisors in the Portfolio Focus Program (which contains additional requirements and restrictions on such Financial Advisors with respect to personal securities trading in employee and employee-related accounts). More specifically, the RBC Wealth Management Advisory Programs Disclosure Document Page 42 of 46 26-25-5088800_25213 (09/26)  IA Code of Ethics outlines RBC WM requirements contained in such policies, including that Covered Persons and their immediate family members (i) maintain their personal securities accounts and accounts in which they have a beneficial interest at RBC WM, unless RBC WM has given its prior express written permission to open and/or maintain an account outside of RBC WM, (ii) report their personal securities transactions and holdings to RBC WM, and (iii) obtain pre-approval for investments in private placements and initial public offerings, among others. In addition, the IA Code of Ethics also contains information on standards relating to prohibited and illegal activities associated with the possession of material non-public information (e.g., further disclosure, trading), the administration and enforcement of the IA Code of Ethics, and maintenance of certain records relating to the IA Code of Ethics. As part of RBC WM’s annual Compliance questionnaire process, Covered Persons are required to certify to their receipt and review of, and compliance with, the IA Code of Ethics. A copy of the IA Code of Ethics is available to clients or prospective clients upon request. Participation or Interest in Client Transactions As a full-service broker-dealer, on an ongoing basis and as permitted by applicable law, we may, when appropriate: • act as broker or agent, effect securities transactions for compensation for you; • recommend to you that you buy or sell securities or investment products in which we or a related person or a family member of an employee has some financial interest; • buy or sell for ourselves securities that we also recommend to you; or • sell or convert Fund shares or other unbilled assets, which will subject proceeds to the Program Fee. We have adopted internal policies and procedures with respect to conflicts of interest between us and our clients. Pursuant to these policies and procedures, we, when engaging in the activities enumerated above, treat your orders fairly and do not give our own orders preference over your orders. As required by applicable law and/or exchange rules, including, but not limited to, the Advisers Act, we obtain the consent of affected clients in advance of any transactions in which we will be engaging in the activities referenced above. When we engage in the activities mentioned above, all statements and/ or confirmations of such transactions contain the disclosures required by applicable law and exchange rules. Securities activities are monitored daily to detect and prevent employees from trading ahead of client accounts. RBC WM and its affiliates are not obligated to effect any transaction that they believe would violate federal or state law, or the regulations of any regulatory or self-regulatory body. RBC CM or its Affiliate(s) in Underwriting Syndicate; RBC WM Distribution of Securities If RBC CM or its affiliate(s) is a member of the underwriting syndicate from which a security is purchased by an unaffiliated Investment Manager, and allocated to your account, we or our affiliates could directly or indirectly benefit from such purchase. If RBC CM participates in the distribution of new issue securities that are purchased for a client’s account by an unaffiliated Investment Manager, RBC CM will receive a fee to be paid by the issuing corporation to the underwriters of the securities and ultimately to RBC CM, which will be deemed additional compensation to us, if received by us. Principal Transactions We generally will not purchase a security from or sell a security to a client advisory account from our own account (i.e., as “principal”). In the very limited circumstances that we permit executing a trade as principal in non-retirement accounts, we are paid by marking the price up or down and we retain that difference, which is a benefit to us and a conflict of interest. We mitigate this conflict of interest in our Programs by prohibiting principal trades in advisory accounts where we direct the trade (other than certain trade corrections) except where all of the following are true: 1) there is no additional compensation to your Financial Advisor as a result of the principal trade; 2) the security price can be determined at the time of the trade; 3) in accordance with applicable law, rule or regulation, we obtain your prior written consent to engage in the principal trade transaction; and 4) we obtain a competing bid or offer for the transaction where one is available. In Consulting Solutions and MAP, we permit third-party Investment Managers to direct trades with RBC CM’s institutional trade desk on behalf of non- retirement accounts. You will receive a trade confirmation notice for each such principal trade disclosing that we acted in a principal capacity, even if you have elected to suppress trade confirmations. Agency Cross Transactions Agency cross trades and internal cross trades are generally prohibited for Program accounts. For MAP, it shall be your responsibility to so limit each Investment Manager with respect to any broker or dealer other than RBC CM. Best Execution It is the duty of the entity with brokerage discretion under a Program to seek the best net price and execution on securities trades for client accounts. If we sell a security to you or buy a security from you, we will use all reasonable efforts to ensure that you obtain the best net price and execution on the purchase or sale based on prevailing inter-dealer market prices. In some circumstances, the change in market price may result in financial benefit to us. We may consider it appropriate to RBC Wealth Management Advisory Programs Disclosure Document Page 43 of 46 26-25-5088800_25213 (09/26)  use our own execution services to effect purchases and sales of securities for investment advisory clients. We may receive brokerage commissions in connection with such transactions and, in accordance with Section 11(a) of the Exchange Act, may execute transactions for investment advisory accounts over which we have discretion on the floors of securities exchanges of which we are a member. Mark-ups and mark-downs charged by a dealer unaffiliated with us may be included in the price of certain transactions. Payment for Order Flow, Order Routing and Rebates For options orders, we receive payments in the form of rebates and credits. We receive payments from option market centers in return for routing exchange-listed equity and index options orders to those centers when the rebates and credits we receive from those centers are in excess of the fees that those centers charge us for such orders. Any remuneration that we receive for directing options trades to any market center will not accrue to your account. RBC WM contracts with a third-party vendor, to provide execution metrics that RBC WM uses to evaluate execution quality across various markets and firms. These payments for order flow create a conflict of interest for RBC WM as it incentivizes us to route orders to the market center that pays the most. RBC WM mitigates this conflict by making routing decisions based on the quality of execution and not payment for order flow, and by ensuring payment rates do not differ between market centers and not sharing these payments with the Financial Advisors or those involved with the execution of the order. We also mitigate these conflicts by disclosing them to you and by establishing policies and procedures that limit the value, frequency, and nature of these types of incentives. For information with respect to RBC’s handling of customer orders, see “SEC Order Handling Disclosures” at www.rbcwm.com/disclosures. You can request a written copy of this information from your Financial Advisor. Trade Errors From time to time, inadvertent administrative errors may occur in processing transactions, resulting in one or more erroneous securities transactions for a client’s account. If this occurs in an account, the error will be corrected, and the account will be restored to the same economic position had the error never occurred. Through this process, a profit may be realized, or a loss suffered in connection with correcting this error. Neither losses nor gains realized will be passed on to the client. RBC WM will retain amounts remaining after errors are corrected. As a result, trade corrections can result in a financial benefit to RBC WM or its affiliated broker-dealers. Trade Aggregation and Allocation Your Financial Advisor may aggregate trades/orders of equity or other certain securities to be sold or purchased in accounts over which he or she has investment discretion, consistent with our duty to seek best execution for our clients. Trades/orders are aggregated and allocated in a manner that is equitable and consistent with our fiduciary duties to our clients. Each participating account receives the average price for the aggregated order. Aggregated orders may include RBC WM employee and/or employee-related accounts. An aggregated order may not receive sufficient securities to fill all of the accounts in the order. Aggregated orders that only partially fill and include both client accounts and RBC WM employee or RBC WM employee-related accounts will be allocated pro rata or randomly to the client accounts first. Only after client accounts are filled will the remainder of the partially filled aggregated order be allocated pro rata or randomly to the RBC WM employee and/ or employee-related accounts. If participating accounts are unable to be assigned shares on a pro rata basis, an unbiased and random allocation will be used. In Portfolio Focus, if an aggregated order involves fixed income securities, Financial Advisors have the option to designate which client accounts are allocated portions of the order after it has been placed. In doing so, your Financial Advisor will allocate an order based on certain factors, such as client investment objectives or available cash in an account, which will result in differential treatment of similarly positioned clients with the same objectives. In addition, the Overlay Managers have discretion to aggregate orders into a block trade and execute at an average price. Depending on the size of these orders and the liquidity of the individual security the execution of the block may occur over more than one day. Review of Accounts When you open a Program account, your Financial Advisor(s) and their supervisors (or supervisors’ authorized delegate) will review your account(s) to confirm the account type and that the Program and Investment Strategy are suitable and appropriate based on your Advisory Risk Profile and any other information you have provided to us for your account. As a Program client, your Financial Advisor will provide you with the opportunity to engage in periodic reviews of your account(s). These periodic reviews of your Program account(s) typically occur on an annual basis; however, our Program guidelines allow both you and/or RBC WM to extend the timing of these reviews for certain periods of time as suitable and appropriate. The RBC Advantage team conducts periodic review of your Program account(s) on a biennial basis. These reviews provide, among other things, the opportunity to evaluate and assess your individual circumstances, financial situation, and important information about your Program account(s) as it pertains to your financial goals. These reviews are an important part of your advisory relationship with us as they validate that the information you provide is complete, accurate and that your Program account(s) remain appropriate. RBC Wealth Management Advisory Programs Disclosure Document Page 44 of 46 26-25-5088800_25213 (09/26)  RBC WM conducts periodic monitoring and supervisory reviews to confirm Program accounts comply with applicable Program guidelines including, but not limited to, level of trade activity, cash, security and/or sector concentration, ineligible securities, and asset allocation relative to Advisory Risk Profile. Program guidelines may change at our discretion or be waived under certain circumstances. If your investment activity or holdings deviate from our Program guidelines your Financial Advisor may make a recommendation to bring your account within the guideline. If you decide not to take the recommended action your account may be terminated from the advisory Program which will revert such account to a client- directed brokerage account, subject to standard, trade-by-trade commissions. Please note, our monitoring and review of your account(s) is not a substitute for your continued review of your account(s). You are responsible for contacting your Financial Advisor if you have questions, if any information you’ve previously provided to us has changed or if any information is inaccurate. Reports to Program Clients RBC WM will provide you with the following trade confirmations and account statements: • trade confirmations reflecting all transactions effected with or through us (other than cash sweep transactions) unless designated otherwise by you, in accordance with applicable law, rules and regulations; and • Periodic account statements as described in your Client Account Agreement. In the Advisory Agreement, for accounts enrolled in any Program other than RBC Advisor, you will elect whether you wish to receive trade confirmations on a daily or monthly basis for your account(s). RBC Advisor accounts can only receive trade confirmations on a trade-by-trade daily basis. At any time, you may request a copy of the trade confirmation for transactions that appear on the monthly transaction summary statement, as well as any subsequent transaction, or previous transaction effected through RBC WM at no additional cost. If you or RBC WM terminate a Program account, RBC WM will revert the frequency of trade confirmations to daily. Unless you have appointed a Third-Party Custodian for your Program account(s)s, we will generally provide you with periodic reports containing information on the performance of your Program account(s) (each, a “Portfolio Review”). The Portfolio Review may include the performance of the account in terms of rate of return and compare the account’s performance to that of certain appropriate benchmarks or indices. Portfolio Reviews provide historical information regarding an account and should not be relied upon as predictive of future performance. If you utilize a Third-Party Custodian for your Program account(s) assets, you understand that you will receive more limited information and reporting, including limitations on the information included in any Portfolio Reviews which will not include the assets of Program accounts using a Third-Party Custodian. Further, any Portfolio Review and other reports or statements provided by us for your Program account(s) using a Third-Party Custodian, will be based on information provided by the Third-Party Custodian. We will use and rely on this information to perform certain activities that can include calculating the Program Fee, monitoring Program accounts in relation to their Advisory Risk Profile, and for other purposes. We are not responsible for verifying the accuracy of the information provided by any Third-Party Custodian and are not responsible for any losses or errors if caused by, or in any way related to, our reliance on such information from, and the acts or omissions of, such Third-Party Custodian with respect to the applicable Program account(s). Client Referrals and Other Compensation We have referral agreements with independent third parties (each, a “Promoter”) whereby a Promoter will refer prospective clients to us for investment advisory services. Under one of these arrangements, we will pay the Promoter for these referrals by sharing with the Promoter a portion of the Program Fee (generally about 25%, although it can be higher than 25%, depending on facts and circumstances) that we receive from a referred client that opens an account in one of the Programs. Under a separate arrangement, we will pay the Promoter a one-time flat fee of up to $695, based on the potential level of investable assets for each referral, with such fee payable regardless of whether the referred party opens an account with us. This arrangement presents a conflict of interest for us and our Financial Advisors because it has the potential to incentivize a recommendation that such prospective clients become clients in order to recoup the cost of the referral payment. We receive referral fees from third-party or affiliated investment advisers and lending institutions for successful client referrals made by our Financial Advisors. The lending institution pays a referral fee pursuant to a referral agreement between us and the lending institution. The investment adviser shares a portion of the advisory fee it receives from the client with us pursuant to a referral agreement between us and the investment adviser. In the case where a Financial Advisor receives compensation for a client referral, there is a monetary incentive for us and the Financial Advisor to recommend that party over other parties that do not pay us referral compensation. With referrals to affiliates, our firm may be subject to pressure from those affiliates to protect their business interests. This pressure creates a conflict of interest because it incentivizes us to make recommendations to you, or refrain from making recommendations to you, in a manner which best protects those business interests. RBC Wealth Management Advisory Programs Disclosure Document Page 45 of 46 26-25-5088800_25213 (09/26)  Our Financial Advisors are eligible to receive compensation for referrals of clients and prospects to CNB for certain banking products and services. However, CNB may not be the lowest cost service provider to which our Financial Advisors could refer you. Compensation in the form of a production credit will be awarded to the Financial Advisor based on the type of banking product and service selected. This credit is calculated as a percentage of the net revenue generated by the relationship and/or originated mortgage amount over a set period that varies by product. The Financial Advisor’s receipt of referral compensation creates a conflict of interest because it provides an incentive for the Financial Advisor to refer clients to CNB as opposed to other service providers that do not pay for such referrals. An RBC WM employee or an affiliate may also refer a client to an RBC WM Financial Advisor. As an incentive, the referring employee will receive a percentage, or a portion of the fees paid by the client for selected services. In addition, Financial Advisors are eligible to receive a one-time payment to refer existing client accounts to the RBC Advantage team. The referring employee’s role in the ongoing client relationship, if any, will vary depending on each client’s particular situation. The amount of the referral fee paid to us by a third-party investment adviser or by us to an employee providing a referral varies depending on the facts and circumstances. The client acknowledges the referral fee arrangement by signing the investment adviser’s consent and disclosure document. Additionally, RBC WM has arrangements with certain donor advised funds for the referral of clients or prospects that have indicated an interest in establishing and maintaining a donor advised fund. Neither RBC WM nor its financial advisors receive a referral fee for such arrangement. However, donor advised funds that partner with RBC WM generally invest the referred client assets in Programs that are advised and serviced by the referring Financial Advisor which creates an incentive to refer clients to donor advised funds with which RBC WM has a referral arrangement. We seek to address this conflict of interest through disclosure, and by treating Program assets owned and administered by such donor advised funds and Program assets owned directly by clients as separate and distinct advisory relationships in accordance with all applicable regulatory requirements. Financial Information We are not required to include a balance sheet in this brochure because we do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. We do not have any financial conditions that are reasonably likely to impair our ability to meet our contractual commitments to clients. RBC CM, RBC WM and their predecessors have not been the subject of a bankruptcy petition during the past 10 years RBC Wealth Management Advisory Programs Disclosure Document Page 46 of 46 © 2026 RBC Wealth Management, a division of RBC Capital Markets, LLC, registered investment adviser and Member NYSE/FINRA/SIPC. All rights reserved. 26-25-5088800_25213 (09/26) 

Advisory Programs Disclosure Document (Broker Dealer) Form ADV, Part 2A Appendix 1, Wrap Fee Programs Brochure September 30, 2026 This wrap fee program brochure provides information about the qualifications and business practices of RBC Wealth Management (“RBC WM”), a division of RBC Capital Markets, LLC (“RBC CM”). If you have any questions about the contents of this brochure, please contact us at (800) 759-4029. 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. Additional information about RBC CM and RBC WM is available on the SEC’s website at www.adviserinfo.sec.gov. Registration with the SEC does not imply a certain level of skill or training. RBC Clearing & Custody 250 Nicollet Mall | Minneapolis, MN 55401-1931 (800) 759-4029 | www.rbcclearingandcustody.com PLEASE RETAIN A COPY OF THIS DOCUMENT FOR YOUR RECORDS Investment and insurance products offered through RBC Clearing & Custody are not insured by the FDIC or any other federal government agency, are not deposits or other obligations of, or guaranteed by, a bank or any bank affiliate, and are subject to investment risks, including possible loss of the principal amount invested. © 2026 RBC Clearing & Custody, a division of RBC Capital Markets, LLC, registered investment adviser and Member NYSE/FINRA/SIPC. All rights reserved. 26-25-5088800_25213-CS (09/26) HNW_NRG_B_Inset_NoMask ITEM 2: MATERIAL CHANGES This Form ADV Part 2A wrap fee programs disclosure brochure (the “Brochure“), dated September 30, 2026, contains the following material changes and other updates from the previously amended Brochure dated June 30, 2026. For more details on any specific update, please see the item in this Brochure referred to in the summary below. • Beginning in Item 4, under the “Services, Fees and Compensation” section, we have replaced the term “Introducing Firm” with “Broker Dealer” to describe the brokerage firm you have engaged to provide investment advisory and other services to you, and this new term is reflected throughout the rest of the Brochure. • In Item 4, the subsection of the RBC Unified Portfolio Program overview titled “Rebalancing of Assets” has been updated to clarify the three rebalancing frequency options (quarterly, annually, or no rebalance), the timing of initial and subsequent account rebalancing, and the circumstances that can result in unscheduled rebalancing of a client’s RBC Unified Portfolio account. • In Item 4, under “RBC Unified Portfolio,” we have updated the subsection formerly titled “Overlay Manager Discretionary Authority” with the new heading “Investment Manager and Overlay Manager Discretionary Authority,” and the addition of language explaining how the services and investment strategies selected determine discretionary authority between the Overlay Manager and the selected Investment Manager(s) for a client’s RBC Unified Portfolio account. • In Item 4, under “RBC Unified Portfolio,” we have updated the disclosures under the subsection titled “Tax Management” relating to clients electing Tax Management services in RBC Unified Portfolio. The updated language clarifies that clients that request the Overlay Manager consider realized gains from assets held outside their RBC UP account when seeking losses to offset gains for the current tax year (“External Gains to Offset”) will need to reset this number every calendar year by contacting their Financial Professional. • In Item 4, section titled “Eligible Investments; Fund Share Class Selection,” subsection titled “Funds,” we have updated our disclosure as follows: If your Program account includes a share class that is not available in the Program, we may grant an exception for you to continue to hold your existing Fund shares (in the cheaper share class), but you cannot purchase any additional shares of that share class. In such case, you will need to work with your Financial Professional to select an alternate Fund. In RBC Unified Portfolio, if an exception has been granted for you to retain Fund shares that are not available in the Program and such Fund is included in your target investment allocation, your Overlay Manager (RBC CM or Envestnet) may make additional purchases of such Fund in the share class that is available in the Program. • Information Cash Sweep Program conflicts of interest, previously spread throughout the Brochure, is now consolidated in Item 4 section titled “Cash Balances and the Cash Sweep Program,” subsection titled “Cash Sweep Program Conflicts of Interest.” Further, this section has been revised to add clarity. • In Item 6, the disclosures under the section titled “Related Persons as Investment Manager, Model Provider, and/or Overlay Manager, and Associated Conflicts of Interest” have been updated to add clarity around certain Investment Strategies available in both the Consulting Solutions and RBC Unified Portfolio Programs, including the fees clients pay, and we retain, in each of these Programs and the conflicts of interest that arise relating to our Financial Advisors recommending the use of such Investment Strategies in one of these Programs over the other. • In Item 9, under the section titled “Other Financial Industry Activities and Affiliations,” we have enhanced the following language related to nonpublic information under the new subsection title: “Nonpublic Information.” The updated language is as follows: Nonpublic Information In the course of our respective investment banking or other activities, we and our affiliates may, from time to time, acquire confidential or material nonpublic information about corporations or other entities or their securities that may prevent us or them, for a period, from purchasing or selling particular securities in your Program account. We and our affiliates will not be permitted to divulge or to act upon any such information with respect to our or our affiliates’ advisory or brokerage activities, including activities with regard to your Program account. • In Item 9, under the section titled “Participation or Interest in Client Transactions,” we have added the following new subsection which contains the following language: RBC CM or its Affiliate(s) in Underwriting Syndicate; RBC WM Distribution of Securities If RBC CM or its affiliate(s) is a member of the underwriting syndicate from which a security is purchased by an unaffiliated Investment Manager, and allocated to your account, we or our affiliates could directly or indirectly benefit from such purchase. If RBC CM participates in the distribution of new issue securities that are purchased for a client’s account by an unaffiliated Investment Manager, RBC CM will receive a fee to be paid by the issuing corporation to the underwriters of the securities and ultimately to RBC CM, which will be deemed additional compensation to us, if received by us. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 2 of 36 26-25-5088800_25213-CS (09/26)  ITEM 3: TABLE OF CONTENTS ITEM 1: COVER PAGE .............................................................................................................................................................................. 1 ITEM 2: MATERIAL CHANGES ................................................................................................................................................................. 2 ITEM 3: TABLE OF CONTENTS ................................................................................................................................................................ 3 ITEM 4: SERVICES, FEES AND COMPENSATION ................................................................................................................................... 4 Services ............................................................................................................................................................................................................. 5 Advisory Programs ........................................................................................................................................................................................... 6 RBC Advisor Program ................................................................................................................................................................................. 6 RBC Unified Portfolio Program ................................................................................................................................................................... 6 Consulting Solutions Program ..................................................................................................................................................................... 9 Other Disclosures Relating to the Programs ................................................................................................................................................. 9 Funding Program Accounts ......................................................................................................................................................................... 9 Withdrawals from Program Accounts ........................................................................................................................................................ 10 Eligible Investments; Fund Share Class Selection .................................................................................................................................... 10 Cash Balances and the Cash Sweep Program ......................................................................................................................................... 10 Harvesting Gains or Losses ...................................................................................................................................................................... 13 Securities-Based Lending ......................................................................................................................................................................... 13 Fees and Compensation ................................................................................................................................................................................ 14 Fees .......................................................................................................................................................................................................... 14 Calculation of Program Fees; Valuation of Account Assets ...................................................................................................................... 16 Payment of Program Fee .......................................................................................................................................................................... 16 Offset of Certain Fees to Retirement Accounts ......................................................................................................................................... 17 Comparing Costs ............................................................................................................................................................................................ 17 Additional Fees and Expenses ...................................................................................................................................................................... 17 Compensation to Broker Dealer .................................................................................................................................................................... 20 ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ........................................................................................................... 20 ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION ........................................................................................................ 21 Selection of Investment Managers and Model Providers ........................................................................................................................... 21 Monitoring and Review of Investment Managers and Model Providers .................................................................................................... 21 Related Persons as Investment Manager, Model Provider, and/or Overlay Manager, and Associated Conflicts of Interest ............... 22 Removal of an Investment Strategy, Model Portfolio, Overlay Manager, or Fund .................................................................................... 22 RBC CM Acting as Portfolio Manager ........................................................................................................................................................... 23 Performance-Based Fees and Side-by-Side Management ....................................................................................................................... 23 Methods of Analysis, Investment Strategies and Risk of Loss .................................................................................................................. 23 Voting Client Securities (Proxy Voting) ...................................................................................................................................................... 26 ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS .......................................................................................... 28 ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS ................................................................................................................. 28 ITEM 9: ADDITIONAL INFORMATION ..................................................................................................................................................... 28 Disciplinary Information ................................................................................................................................................................................. 28 Other Financial Industry Activities and Affiliations ..................................................................................................................................... 31 Broker-Dealer Registrations ...................................................................................................................................................................... 31 Futures/Commodities-Related Registrations ............................................................................................................................................ 31 Material Relationships with Related Persons ............................................................................................................................................ 31 Other Material Relationships ..................................................................................................................................................................... 33 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................................................................... 34 Code of Ethics and Personal Trading ........................................................................................................................................................ 34 Participation or Interest in Client Transactions .......................................................................................................................................... 34 Review of Accounts ........................................................................................................................................................................................ 35 Financial Information ................................................................................................................................................................................. 36 RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 3 of 36 26-25-5088800_25213-CS (09/26)  ITEM 4: SERVICES, FEES AND COMPENSATION RBC Capital Markets, LLC (“RBC CM”), an indirect, wholly owned subsidiary of the Royal Bank of Canada (“RBC”), is a registered investment adviser and broker-dealer with the U.S. Securities and Exchange Commission (“SEC”) and is a member of the Financial Industry Regulatory Authority (“FINRA”), the New York Stock Exchange (“NYSE”), and other major securities exchanges. RBC CM, through its RBC Wealth Management (“RBC WM”) division, offers clients (“you” or “your”) products and services in its capacity as investment adviser, including portfolio management, and as sponsor of various wrap fee advisory programs. For purposes of this brochure, RBC CM and RBC WM will collectively be referred to as “RBC CM,” the “Firm,” “we,” “us,” or “our.” This brochure provides information about RBC CM and the services it offers through its RBC Clearing and Custody division (“RBC C&C”) to broker dealers, registered investment advisers, and as applicable, their affiliates, (collectively, the “Broker Dealer”).Pursuant to an agreement between the Broker Dealer and RBC CM, RBC CM provides clearing and custody services and makes certain advisory programs of RBC WM available to such Broker Dealers for recommendation to their clients, as they deem suitable and appropriate. The RBC CM-sponsored advisory wrap-fee programs available to Broker Dealers for recommendation to their clients (each, a “Program,” and collectively, the “Programs”) are RBC Advisor (“RBC Advisor”), RBC Unified Portfolio (“RBC UP”), and Consulting Solutions (“Consulting Solutions”), each described below in Item 4. the Programs, the fees you will pay, our role in relation to that of the Broker Dealer, other business activities and financial industry affiliations of the Firm, and the economic and other arrangements we have that create conflicts of interest. This brochure describes the Programs as they are intended to be used by Broker Dealers with their clients. It is important to note, however, that RBC CM, including its affiliates, is not responsible for compliance programs, including with respect to the Broker Dealer’s responsibilities and regulatory obligations in the use of the Programs. As such, while RBC CM provides access to the general structure and investment options of the Programs to Broker Dealers, all responsibility for client suitability and providing investment advice and recommendations that are in your fiduciary best interest (e.g., recommending an advisory account, a specific Program, an investment strategy, specific investment vehicle, and/or an investment manager, etc.), in accordance with the Investment Advisers Act of 1940, as amended (the “Advisers Act”), lies with your Broker Dealer. RBC CM provides the Program services under a “wrap fee” arrangement. This means that the fee you pay in the Programs covers the investment advisory services of RBC CM as well as certain trade execution, custody, and other brokerage services for a single fee. A description of services and fees that are included in, and excluded from, the wrap fee you pay is included in the Advisory Agreement and described below. In this brochure, the term “Investment Manager” refers to a client’s affiliated or unaffiliated discretionary investment adviser that manages client accounts in accordance with one or more of their investment strategies (each, an “Investment Strategy”) available in the applicable Program., For certain Programs, the Investment Manager may be RBC CM or its affiliates, including (but not limited to) RBC Global Asset Management (U.S.) Inc. (“RBC GAM – U.S.”). In RBC UP, the term “Overlay Manager” refers to either RBC CM or Envestnet Asset Management, Inc. (“Envestnet”) and the term “Model Provider” refers to RBC CM and affiliated or unaffiliated non-discretionary investment advisers that provide their model portfolio(s) (each, a “Model Portfolio”) for implementation in RBC UP. ”). The term “Funds” includes open-end mutual funds, exchange-traded funds (“ETFs”), exchange-traded notes (“ETNs”), and certain interval funds, unless otherwise specified. Interval funds are a type of closed-end mutual fund that does not trade on a secondary market. Rather, the fund only provides periodic offers to repurchase a limited number of shares. As a result, shareholders may not have access to the invested assets for extended periods of time. Refer to the Interval Fund Disclosure for more information. For purposes of this brochure, the term “Retirement Account” will be used to cover (i) “employee benefit plans” (as defined under Section 3(3) of Employee Retirement Income Security Act of 1974, as amended (“ERISA”), which include pension, defined contribution, profit-sharing and welfare plans sponsored by private employers, as well as similar arrangements sponsored by governmental or other public employers which are generally not subject to ERISA; and (ii) individual retirement accounts (each, an “IRA”) as described in the Internal Revenue Code of 1986, as amended (the “Code”). RBC CM does not act as a fiduciary for any Broker Dealer client’s Retirement Account subject to ERISA or the Code, except in its capacity as Overlay Manager, if applicable. The Form ADV Part 2A brochure for each Investment Manager, Model Provider, and the third-party Overlay Manager (Envestnet) available in applicable Programs is also available at the SEC’s website at www.adviserinfo.sec.gov. Assets Under Management As of June 30, 2026, we had $345,747,567,752 in assets under management, $263,708,872,591 of which was managed on a discretionary basis and $82,038,695,161 of which was managed on a non-discretionary basis. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 4 of 36 26-25-5088800_25213-CS (09/26)  Services The Programs are customized advisory programs whereby Program services are provided pursuant to your investment advisory agreement(s) with RBC CM and your Broker Dealer. It is the responsibility of your Broker Dealer to work with you to analyze and define your investment objectives, financial circumstances, risk tolerance to develop and/or select an investment strategy. To open and enroll an account in any of the Programs described herein, clients and their Broker Dealer are required to enter into a written investment advisory agreement with RBC CM known as the Advisory Master Services Agreement. RBC CM discontinued the use of its pre-existing “Single Program Agreement” for opening new Program accounts (but some existing Program accounts may have been opened using that Single Program Agreement). The Single Program Agreement and the Advisory Master Services Agreement shall be collectively referred to herein as the “Advisory Agreement.” As discussed in Item 5, the Advisory Agreement governs the terms of a client’s current and future Program account(s) and relationships with RBC CM and outlines the services to be provided to the client’s account(s) in a Program. As part of the Program account opening process, Broker Dealers are responsible for working with their clients to determine their risk profile, which is intended to encompass the client’s risk tolerance, investment objective(s), investment time horizon, and financial situation (when referred to collectively, the “Advisory Risk Profile”). Broker Dealers provide Advisory Risk Profiles to RBC CM. It is each client’s responsibility to verify that the information they provide to their Broker Dealer is, and continues to be, complete and accurate, and to notify their Broker Dealer promptly if any of their information and circumstances change. Based on the Advisory Risk Profile and other client information provided to the Financial Professional during the account opening process, each client will work with their Financial Professional to select a Program. The Broker Dealer is responsible for providing instructions to RBC CM regarding client enrollment and investment decisions. Except as provided in Item 6 below, RBC CM has no discretionary authority to select a Program, strategy, or services on behalf of clients. Pursuant to the Advisory Agreement, and as further discussed below, clients pay a quarterly, asset-based, wrap fee (the “Program Fee”) for investment advisory, brokerage execution, and other services rendered under a Program, to RBC CM, typically based on the value of their Program account(s) regardless of the number of trades placed. In certain circumstances, a client’s Broker Dealer or RBC CM may require the client to sign additional documentation relating to Program Fee. The services generally covered by the Program Fee include the investment advisory services provided by the Broker Dealer, and Program management services provided by RBC CM (and depending on the Program, investment advisory services provided by the Investment Manager, Model Provider, and/or Overlay Manager), as well as trade execution, clearing, custody, and other administrative and account reporting services provided by RBC CM. Please see the detailed discussion of fees and other costs below under “Fees and Compensation” in Item 4. Reasonable Investment Restrictions For all Programs except RBC Advisor (a non-discretionary Program, described below), clients can request that certain reasonable investment restrictions be placed on the management of their Program account(s). Reasonable investment restrictions include restrictions on the purchase and/or sale of certain securities or categories of securities related to a financial sector or industry (e.g., fossil fuels, tobacco). Such restrictions are subject to acceptance by Broker Dealer, RBC CM, and, where applicable, the Investment Manager(s) and/or the Overlay Manager(s) as reasonable, in each of their sole discretion. It should be noted that any reasonable investment restrictions will not apply to the underlying portfolio of any Fund, UIT, the sub-accounts of annuities, or other similar securities that are held or purchased in a Program account. When an account is terminated from a Program, any previously accepted, client-imposed investment restrictions for that account will no longer be in effect. Where reasonable investment restrictions have been accepted, they can be implemented in various ways, including, but not limited to, increasing the relative proportions of other securities in a portfolio to replace the restricted securities and/ or selecting alternate securities. Any investment restrictions clients impose on the management of their Program account(s) can limit the Broker Dealer’s, the Investment Manager’s, and/or the Overlay Manager’s ability to make investments or take advantage of opportunities. Clients are responsible for notifying their Financial Professional, who will in turn notify RBC CM of any changes to their investment restrictions. RBC CM will then notify the Overlay Manager and/or Investment Manager of any changes to the investment restrictions. Custody RBC CM will act as custodian for the assets and securities held in a Program account(s). RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 5 of 36 26-25-5088800_25213-CS (09/26)  Advisory Programs RBC Advisor Program RBC Advisor is a non-discretionary investment advisory Program where you receive ongoing investment advice and recommendations from your Financial Professional but retain final decision-making authority over the investing activity in your accounts. In RBC Advisor, your Broker Dealers is responsible for working with you to determine a suitable investment strategy that’s consistent with your Advisory Risk Profile. You are responsible for approving your selected investment strategy. RBC CM determines which securities are eligible for recommendation in the RBC Advisor Program, which include equities, fixed income, Funds and/or other investments. In identifying and selecting eligible investments, we use various sources of information including, but not limited to, data provided by unaffiliated third parties, research materials, prospectuses, financial publications, and other public filings and reports. Because you exclusively receive investment advice through your Broker Dealer and its Financial Professional(s), RBC CM does not assume responsibility for the performance of the securities selected by you or your Financial Professional, or for the conduct or particular recommendations made by your Broker Dealers or its Financial Professionals. For more information regarding the investment advisory services provided by your Broker Dealer, please contact your Financial Professional and/or refer to your Broker Dealer’s Form ADV 2A Brochure. As further discussed below in “Fund Share Class Selection; Eligibility and Classification of Certain Investments” in Item 4, while RBC CM has no discretionary authority with respect to RBC Advisor accounts, if you have transferred in a Fund share class that is not eligible for the Program, RBC CM can convert the ineligible Fund share class to an eligible share class of the same Fund without notification to you. Certain annuities for which you have paid a commission may appear on your account statement for informational purposes only. In such cases, these annuities are not considered advisory assets covered under the Advisory Agreement and are not subject to the Program Fee. RBC Unified Portfolio Program The RBC UP Program is a “unified managed account” program in which a single client account can invest in all or some of the following investment products (each, an “Investment Product”), which may or may not be affiliated with RBC CM: eligible Funds, closed-end funds, Model Portfolios managed and provided by Model Providers and/or Investment Strategies managed by Investment Managers. The different Investment Products are held in “sleeves” (each, a “Sleeve”) in a single RBC UP account. Except for Sleeves managed by Investment Managers, Sleeves are managed on a discretionary basis by the Overlay Manager. The Overlay Manager for an RBC UP account will either be RBC CM or Envestnet, a third-party portfolio manager that is not affiliated with RBC CM. In addition to providing discretionary account management, each Overlay Manager provides portfolio implementation, coordination, and other services as specified below. This discretionary authority includes the authority to implement any Model Portfolio(s), Fund(s) and/or closed-end fund(s) you have selected for your RBC UP account, subject to any reasonable investment restrictions, you have requested, and which have been accepted by the Overlay Manager. The Overlay Manager will not have discretionary authority over Sleeves managed by Investment Managers. The Overlay Manager for your RBC UP account will be determined by the specific services you elect to receive in the Program. If you elect tax management services (“Tax Management”) and/or responsible investing screens services (“Screens”), each as further described below, your account will be managed by Envestnet as Overlay Manager. If you do not select Tax Management or Screens, your account will be managed by RBC CM as Overlay Manager. Recommendation of Investment Strategy You will work with your Financial Professional to determine the investment strategy and target investment allocation for your RBC UP account. The target investment allocation for your RBC UP account will ultimately be comprised of the specific Investment Product(s) that you select from those available in the Program and a target allocation to each such Investment Product. The target investment allocation and Investment Product(s) selected for your account will be provided to the Overlay Manager and/or Investment Manager(s). You can change the target investment allocation and/or Investment Products for your account by notifying your Financial Professional, who will in turn notify the Overlay Manager and/or Investment Manager(s) of the change. RBC CM will send you written confirmation of such change. As further discussed below under “Eligible Investments; Fund Share Class Selection,” if your target investment allocation includes a Fund share class that is ineligible for the Program, we can update your allocation to the eligible share class of the same Fund without notification to you. If your target investment allocation includes a Fund or closed-end fund that becomes closed to all purchases, or if you do not want to purchase additional shares of a fund included in your target investment allocation, you may apply an “alternate RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 6 of 36 26-25-5088800_25213-CS (09/26)  fund”. When an alternate fund is applied, no additional shares of the fund will be purchased; however, your Overlay Manager can sell existing shares of the fund. All additional shares will be invested in the alternate fund. Investment Manager and Overlay Manager Discretionary Authority Investment Managers have discretionary authority over the implementation of their respective Investment Strategies. As such, if you select one more Investment Strategies, the Investment Manager(s) will execute trades in your account’s applicable Sleeve in accordance with the Investment Strategy that you have selected, subject to any investment restrictions you have requested, and which have been accepted by RBC CM and the Investment Manager. The Overlay Manager has discretionary authority over Model Portfolios, Funds and closed-end funds. If your account is comprised of one or more Model Portfolios, the Overlay Manager will manage your RBC UP account in accordance with such Model Portfolios, and any updates thereto, as provided and communicated by the respective Model Providers to the Overlay Manager. While implementing the Model Portfolio, the Overlay Manager will take into account any reasonable investment restrictions as discussed above, or client elected services as discussed below. The Model Portfolios, and changes to the Model Portfolios, are typically implemented by the Overlay Manager as soon as practicable after they are received from the Model Provider. Therefore, reasonable delays may occur between the receipt of Model Portfolio revisions, and the resulting execution of securities transactions by the Overlay Manager for client accounts. Depending on the circumstances (including the extent to which Model Portfolios are widely distributed, the timing in which the Overlay Manager receives revisions to the Model Portfolios and acts on them, and the trading activity in the securities contained in the Model Portfolios),transactions in client accounts can be subject to significant market impact prior to execution. For example, the implemented Model Portfolio can receive less favorable execution prices, particularly if the overall trading in the securities is large in relation to the securities’ trading volume. Rebalancing of Assets You will choose from three rebalancing frequencies for your RBC UP account: quarterly, annually, or no rebalance. If quarterly or annually is selected, the Overlay Manager will execute trades and coordinate with any Investment Managers, as needed, to bring your account as close to your target investment allocation as practicable. Your first scheduled rebalance will occur one quarter or one year, as applicable, from the date your account is enrolled in RBC UP. If your rebalancing frequency is changed from no rebalance to quarterly or annually, your account will be rebalanced at the time of the change and the rebalance date will be set to the next quarter or year, as applicable. If you select no rebalance, the account will only be rebalanced upon request. Regardless of the selected rebalance option, your account can be rebalanced at any time when deemed necessary or appropriate by the Overlay Manager to implement the allocation and investments selected or due to other factors that include, but are not limited to, contributions, withdrawals, updates to any Model Portfolio(s) and/or Investment Strategy(s). Any unscheduled rebalance of your account will reset the next rebalance date to the next quarter or a year, as applicable. If you have elected to receive Tax Management (described below), Envestnet will evaluate the trade-off between rebalancing the account and the tax consequences of any client specified limits. If your account is not tax-exempt, the sale, redemption, or exchange of investments may result in taxable gains or losses. We will not be liable for any tax consequences or Fund redemption fees (see the Fund’s prospectus) that result from rebalancing. In general, any contributions or withdrawals of assets to or from your account will be applied to the target investment allocation. Tax Management You can elect Tax Management if you are utilizing an equity or Fund Model Portfolio, or any combination thereof. If you elect Tax Management, Envestnet will develop a tax strategy for your account based on the information and instructions, including any limits you provide to your Financial Professional and your Financial Professional forwards to Envestnet. The tax strategy Envestnet develops is provided solely in connection with your account. Neither Envestnet nor RBC CM provide tax advice or tax planning services of any kind; clients are urged to consult with their own personal tax advisors for advice specific to their situation. If you elect Tax Management, please consider the following: • Tax Management is limited in scope and is not designed to eliminate taxes in the account. Envestnet can, in light of other considerations in an account, effect transactions even though they may generate tax liabilities, including short-term taxable income, or exceed any of the limits or mandates identified by the client. Envestnet makes no guarantee that tax liability in the account will be reduced or that any indicated limits or mandates will be met. • The use of limits to restrict the amount of capital gains realized can severely restrict trading in the account and could result in substantial deviations from your target investment allocation. Limits should only be imposed on the account after you have consulted with your own personal tax advisor. The limits specified will be used annually until you instruct your Financial Professional to instruct Envestnet otherwise. If you elect Tax Management, your account can perform better or worse than similarly invested accounts that did not elect Tax Management. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 7 of 36 26-25-5088800_25213-CS (09/26)  • You may request that Envestnet consider realized gains from assets held outside of your RBC UP account when seeking losses to offset gains for the current tax year (“External Gains to Offset”) by contacting your Broker Dealer. The External Gains to Offset number you provide expires at the end of each calendar year; therefore, you must contact your Broker Dealer to reset this number for each calendar year. • When providing Tax Management, Envestnet avoids net short-term capital gains where possible, but does not limit net long-term capital gains. • If your account is funded with positions that have long-term capital gains and you have not set a long-term capital gain limit, then all long-term tax lots of securities that are not included in your equity Model Portfolio(s) will be sold, which will cause you to incur long-term capital gains. • If Fund Model Portfolios, or Envestnet’s Quantitative Portfolios, are included in your target investment allocation, existing Fund positions held in your account may be able to be retained for tax reasons, regardless of whether they are part of such Fund Model Portfolios, or Envestnet Quantitative Portfolios. The Fund positions that are retained may have a higher cost. However, if you are not invested in Fund Model Portfolios or Envestnet Quantitative Portfolios, any existing Fund positions held in your account that are not included in your target investment allocation will be sold upon Program account opening regardless of tax consequences. • You may cancel Tax Management at any time. Cancelling Tax Management may result in the recognition of significant taxable capital gains or losses. If you cancel Tax Management, but your account maintains or enrolls in Screens, Envestnet will continue to act as Overlay Manager. If you cancel Tax Management, and your account is not enrolled in Screens, RBC CM will become your Overlay Manager. • Significant investment allocations to certain Fund Model Portfolios may result in less effective Tax Management. For example, Envestnet has less flexibility in managing a client’s tax strategy where a client is invested in a Fund Model Portfolio with frequent, tactical changes, thereby making it difficult to evaluate the portfolio’s tracking error. • Accounts that include Investment Products not eligible for Tax Management (e.g., Funds, closed-end funds and/or bond Model Portfolios, Investment Strategies) may still elect Tax Management, but Tax Management will not be applied to those Investment Products. Envestnet performs an automated year-end tax loss harvest review. For accounts with Tax Management that have net realized gains for the year, securities in equity Model Portfolios are reviewed for harvesting. Starting with the largest percentage loss tax lots that are available to sell (i.e., there is no known wash sale or other sale restriction on the tax lot or security), Envestnet will harvest losses until the account’s net realized gains are eliminated, or all available tax lots with losses greater than 10% are harvested. The sales proceeds are invested in other Model Portfolio holdings and/or cash. This review process typically occurs in early December and is intended to harvest losses while minimizing the impact to the integrity of the investment allocation. Envestnet’s ability to harvest losses is dependent on account circumstances and market environment, among other factors. If your account is enrolled in Tax Management, you may not separately request that Envestnet harvest gains or losses in your account. Except when Envestnet’s Quantitative Portfolios are included in your investment allocation, Envestnet will only seek to harvest losses from equity Model Portfolios and Fund Model Portfolios. Envestnet will not seek to harvest losses from Funds, closed-end funds, or bond Model Portfolios. When the equity Model Portfolios in a client’s target investment allocation are solely Envestnet’s Quantitative Portfolios, and they comprise at least 35% of the client’s total target investment allocation, the client can select Envestnet’s “Portfolio Diversification Solution,” an additional Tax Management service. Envestnet’s “Portfolio Diversification Solution” is a Tax Management service designed to transition a client’s current holdings to their target investment allocation over a longer period of time (subject to any maximum imposed by Envestnet) than might otherwise be allowed based on Envestnet’s standard tracking error thresholds. For these purposes, tracking error measures the difference between the performance of Model Portfolios when used in accounts with Tax Management and when used in accounts without Tax Management. With Envestnet’s Portfolio Diversification Solution, there are no limits on the initial tracking error provided that the selected tax budgets will allow full transition to the target investment allocation within the determined time period. Tracking error will be higher at the beginning of the transition and will decline over time as capital gains are realized and the client’s investments become increasingly more in line with the target investment allocation. You should consult your own personal tax advisor before enrolling in Tax Management and providing any tax information to your Financial Professional and Envestnet. For more information on Tax Management, please refer to Envestnet’s ADV which is available upon request or at the SEC’s website: www.adviserinfo.sec.gov. Responsible Investing Screens Screens are available to you if you are utilizing an equity Model Portfolio. Clients may restrict their accounts from investing in certain securities or industries by selecting Screens for their account(s). Envestnet relies on third-party data research providers for industry and socially responsible classifications of individual securities, and Envestnet and RBC CM make RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 8 of 36 26-25-5088800_25213-CS (09/26)  no guarantee as to the accuracy of such third parties’ classification. The third-party data research providers of these classifications apply different definitions and criteria from other similar providers, which can generate different responsible investing ratings, when applied, could result in the restriction of different securities (i.e., there is no single industry definition or uniformly applied criteria that inform the Screens). If a third-party data research provider changes the classification of an individual security, Envestnet will make reasonable efforts to implement those changes in a timely manner. Envestnet may implement restrictions by, for example, increasing the relative proportions of other securities to replace the restricted securities and/or selecting alternate securities. Many of the Screens have both a “Best in Class” and “Strict” restriction. Best in Class restrictions are designed for investors seeking to achieve alignment between their values and the prudent management of their investments, while Strict restrictions are designed for investors who want to integrate more stringent environmental/social criteria into their investments by minimizing exposure to companies with specific products, services, and/or operations that do not meet the investor’s personal values criteria. Screens will only be applied to equity Model Portfolios and not to other Investment Products held in a Program account. The application of Screens can cause an account to underperform or overperform when compared to other similarly invested accounts that have not elected Screens. Consulting Solutions Program In the Consulting Solutions Program, your Financial Professional will assist you in selecting one or more Investment Managers and one or more of their Investment Strategies (each, an “Investment Strategy”) from those RBC CM has made available in this Program. Upon consultation with you, your Financial Professional will provide you with recommendations regarding Investment Managers and their Investment Strategy or Investment Strategies that they believe are suitable and consistent with your Advisory Risk Profile. The Investment Managers made available to clients through this Program include both RBC CM affiliated and non-affiliated Investment Managers who meet the Firm’s eligibility requirements for participation as detailed below in Item 6: “Portfolio Manager Selection and Evaluation.” In Consulting Solutions, you are responsible for the ultimate selection of the Investment Manager and Investment Strategy. The Investment Manager has discretionary authority over your account and will implement the investment decisions for your account in accordance with the selected Investment Strategy, subject to any investment restrictions you have requested, and which have been accepted by the Investment Manager. In Consulting Solutions, the Advisory Agreement that you sign is between you, your Broker Dealer, and RBC CM; you do not sign a separate agreement with the Investment Manager. Several direct indexing Investment Strategies are available in Consulting Solutions. Investment Managers who offer direct indexing Investment Strategies typically require that accounts enrolled in such Investment Strategies they manage be set to a Highest Cost, First Out (“HIFO”) tax lot accounting method. If you elect to enroll your account and invest in a direct indexing Investment Strategy, RBC CM will change the tax lot accounting method of your account to HIFO upon your written consent before your enrollment in such direct indexing Investment Strategy (if it was not already set to HIFO). If you terminate the Investment Strategy or your Consulting Solutions account, the tax lot accounting method for your account will remain HIFO unless you provide written instruction to RBC CM to change the tax lot accounting method for your account. Other Disclosures Relating to the Programs The following disclosures generally apply to all the Programs, unless noted otherwise. Funding Program Accounts You can fund your Program account by depositing cash and/or securities acceptable to RBC CM (subject, for Retirement Accounts, to any limitations imposed under the retirement plan documents, ERISA, or the Code, as applicable). The investment of assets in a Program account will only occur when all operational requirements have been met. Deposits of cash and/or securities into Consulting Solutions or RBC UP accounts will be invested by the Investment Manager or the Overlay Manager, as applicable, as soon as reasonably practicable. The management of a new Program account will begin after RBC CM has accepted the account into a Program and, as applicable, after the Investment Manager or Overlay Manager has accepted the account. At the time of Program enrollment, account acceptance could be delayed or rejected if the account is underfunded, funded with ineligible securities, and/or for other operational reasons. If you fund your Consulting Solutions or RBC UP account with securities, the Investment Manager or Overlay Manager (which may be RBC CM), as applicable, will liquidate the securities on your behalf, or request that your Broker Dealer liquidate the securities on your behalf, and allocate the proceeds in accordance with the Investment Strategy or Investment Products you have selected. Depending on the type of security involved, liquidation may result in redemption charges and/or taxable gains or losses. RBC CM will not be liable for any lost opportunity profits that may result from investing or liquidating deposits. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 9 of 36 26-25-5088800_25213-CS (09/26)  Withdrawals from Program Accounts Withdrawals from a Program account will be taken first from any free credit cash balances and then from cash balances in your Cash Sweep Option. If the liquidation of securities is required to effect a withdrawal, trades will be implemented as soon as practicable, although they may be delayed depending on market volatility, the Program in which your account is enrolled, and/or the types of securities held in your account. Frequent withdrawals from your Program account may affect the performance and the investment objective of your account. Taxable gains and losses may be realized as result of your withdrawal instructions. RBC CM reserves the right to terminate a Program account if a withdrawal or series of withdrawals results in the account assets falling below the Program minimum. Eligible Investments; Fund Share Class Selection Your Broker Dealer and/or RBC CM may restrict the purchase or holding of certain investments in Program accounts. If a Program account is funded with investments deemed to be ineligible, your Broker Dealer, the Investment Manager and/or Overlay Manager, as applicable, will generally liquidate such investments, or in the case of Funds, RBC CM will convert such investments to an eligible share class of the same Fund without notice to you. Alternatively, you may instruct your Broker Dealer to move such investments to an eligible account. Your account may incur certain transaction charges as a result. Funds In identifying and selecting Funds eligible in the Programs, we may use many sources of information and analysis about Funds, including data provided by third parties. We determine which Fund share classes are available in the Programs based on a number of factors, including, but not limited to, availability, eligibility requirements, and payment of Operational Support and/or Marketing Support to us (as described below in the “Fund Fees and Expenses” section). We do not always make the lowest cost share class available to you. Lower cost share classes may be available to you elsewhere, including, but not limited to, through other broker-dealers or registered investment advisers to which RBC CM provides clearing, custody, and execution services. Where RBC CM offers a lower cost share class than the designated eligible share class for the Programs, in certain circumstances, RBC CM may grant exceptions for clients to hold their existing share class and for institutional clients to purchase the lower cost share class option. In accordance with applicable regulations, we will make a Fund’s current prospectus accessible to you when you purchase shares of the Fund through us. Fund companies can offer various share classes of a Mutual Fund which allows investors to access the same strategy or portfolio of assets through different types of shares within the same Mutual Fund, each with a unique fee structure, investment requirement, and suitability for different investors. Some share classes may be cheaper than the share classes available in the Program. If your Program account includes a share class that is not available in the Program, we may grant an exception for you to continue to hold your existing Fund shares (in the cheaper share class), but you cannot purchase any additional shares of that share class. In such case, you will need to work with your Financial Professional to select an alternate Fund. In RBC Unified Portfolio, if an exception has been granted for you to retain Fund shares that are not available in the Program and such Fund is included in your target investment allocation, your Overlay Manager (RBC CM or Envestnet) may make additional purchases of such Fund in the share class that is available in the Program. If your account is not tax-exempt, the redemption or exchange of Fund shares can result in taxable gains or losses. RBC CM does not provide tax, legal or accounting advice and, therefore, you should consult your own personal tax, legal or accounting advisors for such advice. We are not liable for any tax consequences or redemption fees that can result from rebalancing. Compensation differences between product types may create a conflict of interest for RBC CM and Financial Professional as there may be an incentive to make products available that pay higher compensation. For a discussion of fees and certain conflicts of interest associated with Fund share class selection, please see the section below titled, “Fund Fees and Expenses.” Please see the section above titled “Eligible Investments; Fund Share Class Selection” for more information. Cash Balances and the Cash Sweep Program Events such as deposits, the sale of securities, and/or other similar activity can generate uninvested cash balances in your account. Pursuant to your brokerage account agreement with RBC CM (the “Customer Account Agreement”), you have the option to have uninvested cash balances in your account(s) automatically deposited, on a daily basis, into an interest- bearing deposit account, a specified money market mutual fund, or a non-sweep cash investment alternative (each, a “Cash Sweep Option,” and collectively, the “Cash Sweep Options”). Upon notice to you, RBC CM may add, remove, or change the Cash Sweep Options available to you through the Cash Sweep Program (hereinafter, the “Cash Sweep Program”). As discussed below, the different available Cash Sweep Options are subject to eligibility requirements and restrictions. You should review your Customer Account Agreement and related Cash Sweep disclosures for details regarding the Cash Sweep Options. For additional information and disclosures on the Cash Sweep Options discussed here, refer to the links under “Cash Management” on our public website at www.rbcclearingandcustody.com/disclosures. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 10 of 36 26-25-5088800_25213-CS (09/26)  The Cash Sweep Options available to you will depend, in part, on the type of account you have opened. You should consider the investment objectives, risks, charges, and expenses of the Cash Sweep Option(s) available to you before selecting that option. Please read any related disclosures, including prospectuses (as applicable), carefully before investing to make sure the Cash Sweep Option is appropriate for your goals and risk tolerance. Non-Retirement Accounts Cash held in non-retirement accounts will be swept into the Cash Sweep Option you choose. The available Cash Sweep Options for non-retirement accounts are: • RBC Insured Deposits. RBC Insured Deposits is a Cash Sweep Option that automatically deposits, or “sweeps,” available cash balances in your Program account into interest-bearing deposit accounts (“Deposit Accounts”) established for you at participating depository institutions (“Program Banks”), whose deposits are insured by the FDIC up to applicable limits, subject to bank capacity (“Deposit Limit”). The Program Banks include unaffiliated, third-party banks and two affiliated banks, RBC Bank (Georgia), N.A. (“RBC Bank”) and City National Bank (“CNB”) (together, “RBC Affiliate Banks” or “Affiliate Banks”). Funds in RBC Insured Deposits are not subject to market risk and potential value loss, but they are subject to the risk of a Program Bank’s failure. RBC CM is not an FDIC-insured depository institution. FDIC insurance available in RBC Insured Deposits is subject to certain conditions and FDIC insurance only protects against the failure of a bank. A list of Program Banks is available at www.rbcclearingandcustody.com/rbc-insured-deposits-program-banks. The RBC Insured Deposits terms and conditions are available at www.rbcclearingandcustody.com/rbc-insured-deposits. More information regarding FDIC insurance is available at http://www.fdic.gov. In the event a Program Bank fails, deposits at each Program Bank are eligible for FDIC coverage up to applicable limits. However, deposits at each Program Bank are not protected by the Securities Investor Protection Corporation (“SIPC”) or any excess coverage purchased by RBC CM. Cash balances in RBC Insured Deposits in excess of applicable limits (“Excess Funds”) are swept into one or more other banks (“Excess Banks”), which will accept funds without limitation and without regard to the FDIC limit, which may be RBC Affiliate Banks. Currently, the primary Excess Bank is CNB. • GAM Money Market Fund. A money market fund managed by our affiliate, RBC GAM – U.S. (“GAM Money Market Fund”), subject to eligibility and applicable minimum amounts. • Credit Interest Program. The Credit Interest Program (“CIP”) is a non-sweep cash alternative and represents our direct obligation to repay the invested amount, on demand, plus interest. We invest and use CIP assets as free credit balances for our benefit, and we periodically adjust the interest rate payable on CIP accounts. We use these funds in the ordinary course of our brokerage business, subject to the requirements of Rule 15c3-3 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). The difference between amounts earned by us from our investments and the rate we pay to CIP account holders is our profit. Cash invested in the CIP is protected by SIPC up to $250,000 per account on claims for cash. SIPC protects against the custodial risk (and not a decline in market value) when a brokerage firm fails by replacing missing cash up to the $250,000 limit. Retirement Accounts Cash balances held in Retirement Accounts will be swept into an unaffiliated money market fund, the Federated Hermes Treasury Obligations Fund (the “Federated Money Market Fund”). You may access the most recent Federated Money Market Fund prospectus by contacting your Financial Professional or by accessing Federated Investment Management Company’s website at www.federatedinvestors.com/products/mutual-funds/treasury-obligations/as.do. Money Market Funds in the Cash Sweep Program As described above, the money market funds offered in the Cash Sweep Program are the GAM Money Market Fund and the Federated Money Market Fund. Money market funds will usually pay a higher rate of interest on cash balances than RBC Insured Deposits or the Credit Interest Program. Other financial institutions may offer cash sweep options that pay you a higher rate of interest than is available in our Cash Sweep Program. You can also receive higher rates on cash balances outside of the Cash Sweep Program by investing directly in money market funds or other cash alternatives; however, such investments must be directed by you and will not be invested automatically. For more information about the Cash Sweep Options available to you, please refer to your Customer Account Agreement, which can be found at www.rbcclearingandcustody.com/disclosures and/or the prospectuses of the Federated Money Market Fund and/or GAM Money Market Fund. Interest Rates In RBC Insured Deposits, interest rates are tiered based on the total RBC Insured Deposits balance in your account. Balances are reviewed daily to determine the appropriate interest rate tier for each account. Current RBC Insured Deposits interest rates are set forth on our public website under “Program Interest Rates” at www.rbcclearingandcustody.com/rbc-insured- deposits. Interest rates are variable and subject to change without notice. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 11 of 36 26-25-5088800_25213-CS (09/26)  Cash Sweep Program Conflicts of Interest RBC CM has a conflict of interest in offering the Cash Sweep Options because RBC CM and/or our affiliates receive compensation or benefits from cash balances swept to these Cash Sweep Options in addition to the Program Fee assessed on Program accounts. This conflict of interest is greater when higher cash balances are maintained in your account. This creates an incentive for RBC CM to offer these Cash Sweep Options and to encourage deposits in these specific Cash Sweep Options. At times, however, your Financial Professional and/or the Investment Manager(s) or Model Provider(s) may believe that it is in your best interest to maintain assets in cash, particularly for defensive purposes in volatile markets. We address these conflicts of interest through proper disclosure and by also offering in RBC Insured Deposits the ability to opt-out of having your deposits maintained at Affiliate Banks. • The Program Fee. We charge the Program Fee on cash balances in your Program account(s) and we and/or our affiliates receive benefits from amounts invested in the Cash Sweep Options. This means that we and/or our affiliates earn two levels of fees on the same cash balances in your account. • RBC Affiliate Banks. RBC Affiliate Banks pay RBC CM an annual per- account fee for each account enrolled in RBC Insured Deposits. RBC CM receives such fees in addition to the Program Fee you pay to RBC CM. This creates a conflict of interest for us because we have an incentive for you to maintain and direct uninvested cash in your account into Deposit Accounts at our Affiliate Banks where they use such deposits to generate additional revenue for themselves. Our Affiliate Banks make a profit on the difference, or “spread,” between the interest they pay and other costs they incur on deposits, and the interest or other income they earn using the deposits for loans, investments, and the purchase of other assets. Our Affiliate Banks can change the interest rate they pay on deposits at any time, and we can increase the amount of the fee we retain, both of which can change the amount of interest you receive on cash balances. Because the amount of interest paid to clients in RBC Insured Deposits is deducted from the revenue Affiliate Banks earn on these deposits, RBC CM has a conflict of interest in that the less interest paid to you, the more revenue our Affiliate Banks earn on those assets. Further, RBC CM receives internal accounting credits for cash balances deposited into our Affiliate Banks that help us meet our internal profitability goals as reported to our mutual parent company, which positively affects the amount of bonus paid to senior executives. For RBC Insured Deposits cash balances placed with our Affiliate Banks, including amounts that exceed total FDIC program coverage and are placed at CNB in its capacity as the primary Excess Bank, our Affiliate Banks will receive a stable source of deposits at a cost that is less than other funding sources available. By being designated as the Primary Excess Bank in RBC Insured Deposits, our Affiliate Banks will receive substantial additional deposits to use in their businesses to increase their profitability. We address these conflicts of interest through proper disclosure and by offering clients the ability to opt-out of having their Deposit Accounts maintained at Affiliate Banks. • Third-Party Program Banks. Third-party Program Banks holding deposits through RBC Insured Deposits pay RBC CM a fee based on a percentage of the average daily balance of the assets placed with them The amount of fees retained by RBC CM will affect the interest rate you earn on your deposits. The fee retained by RBC CM is larger than the amount of interest you receive. The Program Banks can change the interest rate they pay on deposits, and we can increase the amount of the fee we retain, both of which can change the amount of interest you receive on your deposits. Therefore, RBC CM has a conflict of interest in that the less interest you receive on your deposits, the more in fees we retain on those cash balances. • Credit Interest Program. For CIP, we invest and use cash balances as free credit balances for our benefit. We use the free credit balances in the ordinary course of our brokerage business, subject to the requirements of Rule 15c3-3 under the Exchange Act. Under these arrangements, we invest CIP cash balances and generally earn interest or a return based on short-term market interest rates prevailing at the time. We periodically adjust the interest rate we pay you on CIP cash balances, and the spread between the interest earned by us from our investments and the interest rate we pay you on CIP cash balances will be favorable to us. We address these conflicts of interest through proper disclosure and by making CIP unavailable to Retirement Account clients. • Money Market Funds. For amounts invested in the Federated Money Market Fund, the fund pays RBC CM service fees in the form of a recordkeeping fee and a shareholder servicing fee. This provides us with an incentive to use money market funds that pay us such fees instead of other funds that do not. These money market funds typically pay you a lower yield than money market funds that do not pay us recordkeeping or shareholder servicing fees. We address this conflict of interest by proper disclosure. For amounts invested in shares of GAM Money Market Fund, RBC GAM – U.S. is an affiliate of RBC CM and RBC GAM – U.S. receives fees for managing and servicing the fund. RBC GAM – U.S. also pays RBC CM 12b-1 fees, which provides us with another incentive to use this money market fund instead of another fund that does not pay us the same or any revenue share. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 12 of 36 26-25-5088800_25213-CS (09/26)  • Recurring Distributions. In non-retirement accounts, you may also elect to automatically distribute accrued dividends, interest, capital gains, and return on capital payments from your account on a recurring basis. RBC CM invests and uses such cash balances as free credit from the date of deposit until the funds are distributed from your account, which is a benefit to us. You do not earn interest on free credit cash balances. Additional information regarding RBC CM’s use of free credit cash balances can be found in the Credit Interest Program section of the Customer Account Agreement between you and RBC CM. • Differential Interest Rates by Business Channel. You may receive a different interest rate in RBC Insured Deposits from clients who enroll through a different business channel. This creates a conflict of interest because clients receive a lower interest rate on their RBC Insured Deposits cash balances in business channels where RBC CM retains a higher fee on such cash balances. Please see the Cash Management section of our public website at www.rbcclearingandcustody.com/disclosures for more information regarding RBC CM’s Cash Sweep Program. Harvesting Gains or Losses Except for RBC UP accounts enrolled in Tax Management provided by Envestnet, you can request that the Overlay Manager or Investment Manager harvest gains or losses in your RBC UP or Consulting Solutions account. Such requests are subject to acceptance by the Overlay Manager or Investment Manager. To request harvesting of gains or losses for your account in either of these Programs, you can notify your Financial Professional, who will in turn notify the Overlay Manager or Investment Manager. You must make such request each time, and for each account, that you desire gain or loss harvesting. Through the notification of your direction to the Overlay Manager or Investment Manager for your account, you are providing independent instructions to said Overlay Manager or Investment Manager to sell and to then either reinvest the loss sale proceeds in one or more replacement securities or retain the proceeds in cash. Gain sale proceeds will be reinvested in the account in accordance with the applicable asset allocation, as determined by the Overlay Manager or Investment Manager. You can typically request gain or loss harvesting (i) for specified securities, (ii) for specified tax lots, (iii) in a specified total amount, or (iv) in the maximum amount available, subject to each Investment Manager’s and Overlay Manager’s own policies and/or ability and willingness to accommodate such requests. It is important to note that the Investment Manager or the Overlay Manager may reject your request for tax harvesting in whole or in part, at its discretion. In addition, tax harvesting services may not be available for certain Investment Strategies, and the availability of tax-harvesting functionality may be limited due to technology-related and other factors. Please be aware that gain or loss harvesting is an intricate, nuanced strategy that may not be appropriate in all situations and may adversely impact investment performance. Neither RBC CM (including its affiliates) nor the Investment Managers or Overlay Managers provide any tax advice or make any guarantee that tax harvesting will be successful or produce any specific outcome. As such, you should consult your own independent tax, accounting and/or legal professionals before requesting gain or loss harvesting. In addition, when harvesting gains or losses, please keep the following in mind: • If a replacement security increases in value during any applicable wash sale period, such increase can result in a short- term capital gain to you when sold upon expiration of the applicable wash sale period. • There is no guarantee that harvesting requests received late in a calendar year will be completed before year-end. • There is no guarantee that harvesting will achieve any particular result. Tax management or “harvesting” is not tax advice and may not achieve the intended results. • If utilizing harvesting, your account holdings and performance can differ from other similarly invested accounts that do not utilize harvesting. • Harvesting requests only apply to the specific account for which the request is made. If you buy or sell securities in an account that overlaps with the securities sold in another account and such sale generates a loss, this loss may be disallowed under the IRS wash sale rules. • Withdrawing sale proceeds generated from harvesting will likely result in the rebalance of your account and the realization of additional capital gains or losses. Securities-Based Lending Clients have the opportunity to borrow money through lending programs, including RBC Express Credit (“Margin”) offered by RBC CM and RBC Credit Access Line (“CAL”) offered by Royal Bank of Canada and RBC Bank, bank affiliates of RBC CM, collectively referred to as “Lending Programs,” subject to eligibility requirements. In these Lending Programs, the client’s loan is secured by investments and other assets in their account(s) at RBC CM, including those held in Program accounts. Retirement Accounts, including those subject to Title I of ERISA and IRAs, are not eligible for participation in the Lending Programs. To participate in a Lending Program, you agree to maintain securities and/or other assets (“Collateral”) in your account that have a value at least equal to the amount required by its terms (“Maintenance Requirement”). Various factors may RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 13 of 36 26-25-5088800_25213-CS (09/26)  be considered in determining your Maintenance Requirement(s), including the value, liquidity, and concentration of the Collateral. Not all securities are eligible to be used as Collateral. If the Collateral declines in value, certain actions may be taken to maintain the Maintenance Requirement, including selling securities or other assets in your account. Due to market volatility, debt you incur can exceed the value of the Collateral you deposit in your account. You will be required to deposit additional cash or securities, or pay down your loan, should the value of your Collateral decline below the percentage equity you must maintain for your Maintenance Requirement, or should the percentage equity you must maintain for your Maintenance Requirement increase. Through the Lending Programs, RBC CM and certain Broker Dealers receive interest on loans RBC CM extends on Margin or through CAL. RBC CM is permitted to lend or utilize securities on Margin and may receive compensation in connection with the use of such securities. This compensation creates a conflict of interest because it incentivizes RBC CM, and the Broker Dealer to make these Lending Programs available to you as discussed in Item 4 “Compensation to Broker Dealer and its Financial Professionals.” Additionally, Broker Dealer clients with balances in a Lending Program may be charged a different interest rate from clients who have balances in the same program through a different business channel. This creates a conflict of interest because RBC CM retains a higher percentage of the revenue received on loans in business channels that charge clients a higher interest rate. RBC Express Credit (Margin) In this Lending Program, we charge you interest on credit extended to you for the purpose of purchasing, carrying, or trading in securities or commodities or otherwise using eligible securities in your accounts held with us as Collateral. Margin interest rates are determined using a base lending rate plus a sliding scale of percentages according to the size of your Margin debit balance. RBC CM, and generally your Broker Dealer, receive a portion of the interest earned by RBC CM. The use of Margin in your Program account will impact the Program Fee you pay as further discussed in the section titled, “Calculation of Program Fees” in Item 4 below. RBC Credit Access Line (CAL) In this Lending Program, you have access to a securities-based line of credit through Royal Bank of Canada and RBC Bank. Interest rates can vary depending on factors such as your creditworthiness and the amount of credit for which you are eligible, as determined by Royal Bank of Canada and RBC Bank. Interest you pay on your CAL is paid to Royal Bank of Canada and/or RBC Bank. RBC CM, and generally your Broker Dealer, receive a portion of the interest and transactions fees earned by Royal Bank of Canada and/or RBC Bank on your CAL. For more information about these Lending Programs, please refer to “Risks Related to Securities-Based Lending” in Item 6 below and the “RBC Credit Access Line,” “RBC Express Credit”, and “Schedule of Fee” disclosures available at www.rbcclearingandcustody.com/disclosures. Fees and Compensation Fees In the Programs, you will pay the “Program Fee,” which is comprised of the Introducing Firm Fee, the Program Sponsor Fee, and for certain Programs, the Investment Manager Fee, the Model Provider Fee, and/or the Overlay Manager Fee (each as defined and described below). Each of these is expressed as a percentage rate. The Program Fee will not exceed 3.0%. • Introducing Firm Fee. In all Programs, you pay an “Introducing Firm Fee” to your Broker Dealer for the services they provide in the Programs. The Introducing Firm Fee rate is determined between you and your Financial Professional. • Program Sponsor Fee. In all Programs, you pay a “Program Sponsor Fee” to RBC CM which covers the services RBC CM provides as sponsor of the Programs, as well as services related to the custody of account assets, trade execution, clearing and settlement, account reporting and other administrative services. The Program Sponsor Fee typically ranges from 0.00% to 0.40% of Program account assets under management. • Investment Manager Fee. In the Consulting Solutions Program, and the RBC UP Program when utilizing Investment Strategies managed by any Investment Manager(s), you will pay a fee for the investment management services of any Investment Manager (the “Investment Manager Fee”). • Overlay Manager Fee. In the RBC UP Program, you will pay a fee for the services of the Overlay Manager (the “Overlay Manager Fee”). • Model Provider Fee. In the RBC UP Program, as applicable, you will pay a fee for the Model Portfolio(s) provided by any Model Provider(s) (the “Model Provider Fee”). You will receive written confirmation of the Program Fee for your account upon enrollment in a Program, and each time you and your Financial Professional agree to any changes. In certain circumstances, RBC CM and/or your Financial Professional may require you to sign additional documentation relating to the Program Fee (or a component thereof) for your account(s). RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 14 of 36 26-25-5088800_25213-CS (09/26)  Information and ranges for Investment Manager Fees, Model Provider Fees, and Overlay Manager Fees are included below. These fee rates may increase or decrease from time to time which will impact the relevant fee component of your total Program Fee. In such case, your Introducing Firm Fee may increase or decrease, however your total Program Fee will not change. If you change your Investment Manager, Model Provider, or Overlay Manager, the relevant components of your total Program Fee may increase or decrease based on the Investment Manager, Model Provider, or Overlay Manager selected by you. In such case, we will notify you in writing of any change to your Program Fee. Program Fee Components and Ranges by Program The Program Fee is established at the account level. The Program Fee components depend on the Program in which your account is enrolled, and therefore, the Program Fee can vary between Program accounts, as follows: • RBC Advisor. The Program Fee consists of the Introducing Firm Fee and Program Sponsor Fee. • Consulting Solutions. The Program Fee consists of the Introducing Firm Fee, Program Sponsor Fee, and the Investment Manager Fee. Investment Manager Fees you pay range from an annual rate of 0.00% to 0.50% of Program account assets under management and vary by Investment Manager and Investment Strategy. We pay a portion of the Investment Manager Fee to each Investment Manager, which typically ranges from 0.00% to 0.50% of Program account assets. Such amount is determined by the specific Investment Strategies of each Investment Manager currently available in the Program, the services provided by each Investment Manager, the total assets managed by each Investment Manager, and fee negotiations with the Investment Manager, as set forth in an agreement between RBC CM and each such Investment Manager. In some cases, fees we pay to Investment Managers may be lower than the amount of the Investment Manager Fee you pay us. Additionally, we negotiate fee schedules with some Investment Managers, which reduce the effective fee rate we pay to Investment Managers as the total amount of Program assets managed by those Investment Managers increases. Any difference in Investment Manager Fees charged to clients and the percentage of such fees we ultimately pay to the Investment Managers are retained by us. Fees retained by us are not passed on to the Financial Professionals. The fees we pay Investment Managers may change from time to time and such change may impact the total Program Fee we charge you. That is, if we negotiate a lower Investment Manager Fee for the Investment Strategy of an Investment Manager in which your Program account is invested, we may similarly decrease the Investment Manager Fee you pay us as part of the Program Fee. If we renegotiate an existing Investment Manager’s current fee rate, we will notify affected clients of any increase to the Investment Manager Fee. • RBC UP. The Program Fee consists of the Introducing Firm Fee, the Program Sponsor Fee, the Overlay Manager Fee and, as applicable, the Model Provider Fee and/or the Investment Manager Fee. When RBC CM acts as Overlay Manager, the Overlay Manager Fee is 0.05% and is in addition to the Program Sponsor Fee paid to us. When Envestnet acts as Overlay Manager, the Overlay Manager Fee is 0.10% and includes Envestnet’s Tax Management and/or Screens services, if selected. As noted above in Item 4, the Overlay Manager Fee will be assessed on all assets in the account, regardless of whether Tax Management and/or Screens are applied to all or some of those assets. When Envestnet is the Overlay Manager, we pay a portion of the Overlay Manager Fee to Envestnet that ranges from an annual rate of 0.00%-0.08% of account assets under management. We retain any difference between the Overlay Manager Fee of 0.10% that you pay and the portion of such fee we ultimately pay to Envestnet. The Model Provider Fee component of the Program Fee varies by Model Provider, Model Portfolio and type of account (i.e., Retirement Accounts investing in affiliated Model Portfolios), and ranges from 0.00% to 0.65% annually of the market value of an account’s assets allocated to a Model Portfolio, as set forth in an agreement between RBC CM and each Model Provider. If more than one Model Portfolio and/or Investment Strategy is included in your RBC UP account, RBC CM employs a Sleeve-level billing methodology to calculate the amount of each Model Provider Fee and/or Investment Manager Fee. The amount will be determined by calculating the value invested in each Model Portfolio and/or Investment Strategy, or Sleeve, multiplied by the applicable Model Provider Fee for each Model Portfolio and/or Investment Manager Fee for each Investment Strategy in your RBC UP account at the time of each billing event. We pay each Model Provider and Investment Manager a portion of the Model Provider Fee or Investment Manager Fee you pay us. Any difference in the Overlay Manager Fee, Model Provider Fee and/or Investment Manager Fee paid by clients and the percentage of such fees that we ultimately pay to the Overlay Manager, Model Provider and/or Investment Manager are retained by us. Your Program Fee may be higher or lower than (i) the fees and commissions you would pay in a brokerage account; (ii) the fees of other clients depending on considerations such as the size of your account, the types of securities, services provided, and other relevant criteria; and (iii) the cost of similar services offered through other Broker Dealers or financial institutions. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 15 of 36 26-25-5088800_25213-CS (09/26)  Calculation of Program Fees; Valuation of Account Assets Typically, the Program Fee is charged quarterly, in advance, based on the market value of the assets in a Program account, including securities, cash, money market funds, Cash Sweep Program balances, and/or Credit Interest Program balances as of the last business day of the preceding calendar quarter. We include the full market value of assets purchased on Margin in the calculation of your Program Fee and do not reduce the market value of your account by your Margin debit balance. Because the Program Fee is assessed on the market value of assets in your account at the end of a quarter, the total amount of the Program Fee billed each quarter will generally change as Program assets increase or decrease in the Program account. Exchange-traded securities will be valued at the last trade price, or if unavailable, the last known bid price as provided by a third-party vendor. Over -the-counter and illiquid securities will be valued using the broadest and most representative market available. Securities for which market quotations are not readily available will be valued at the known current bid price. If updated pricing is not available from the third-party vendor within 45 days or RBC CM determines the price received from the third-party vendor does not reasonably reflect the last trade price, last known bid price or current market value, as applicable, the price of the security will be removed from the system. All other securities are valued by an independent third- party retained by us or, if unavailable, by a valuation statement provided by the issuer, which will remain unchanged for one year from the date on the valuation statement or until an updated statement is received. Securities where the price cannot be determined will be excluded from the Program Fee charged by RBC CM. Funds To compute the value of assets held in a Program account, we value Fund shares at their respective net asset values as reported on the valuation date by each Fund. Dividends In non-retirement accounts, if you have elected to automatically distribute accrued dividends, interest, capital gains, and return on capital payments from your account on a recurring basis, the proceeds of these payments will not be assessed a Program Fee from the date these payments are made to the date of distribution. Deposits, Withdrawals and Changes Program Fees are prorated for any billing period that is less than a complete quarter. Deposits to or withdrawals from a Program account of cash and/or securities with a value equal to or greater than $10,000 will be billed on a pro-rated basis. Deposits and withdrawals on the same day will offset each other, and the net amount will be used to calculate on a daily basis an additional Program Fee or refund to your account. In each case, the additional Program Fee or refund will be calculated based on the applicable fee rate times the amount of the increase or decrease, pro-rated based on the number of days from the date of the triggering event to the last day of the calendar quarter. If there is any change in your Overlay Manager, Model Provider, Model Portfolio, Investment Manager, Investment Strategy or investment allocation in your account before the end of a quarter, we will use the market valuation from the date of the change to adjust only the portion(s) of the Program Fee (e.g., Overlay Manager Fee, Model Provider Fee, Investment Manager Fee) affected by such change on a pro-rated basis. At the time of such account change, the market value of your account may be higher or lower than the market value of your account at the time your quarterly Program Fee was calculated. As a result, the prorated Model Provider Fee, Overlay Manager Fee, and/ or Investment Manager Fee portion of the Program Fee may be higher or lower than when originally calculated. Each of Broker Dealer and RBC CM reserve the right to correct errors in calculations of Program Fees that were charged to you by debiting or crediting your account, as applicable, without prior notice to you. Additionally, RBC CM reserves the right to increase any components of the Program Fee upon thirty (30) days’ advance written notice to you. Fees Upon Termination You, Broker Dealer, or RBC CM can terminate your Program account in accordance with the notice and other provisions contained in the Advisory Agreement. If a Program account is terminated prior to the last day of the quarter, we will refund you the prorated portion of the Program Fee you paid, calculated based upon the days remaining in the quarter. The termination of a Program account will terminate the Advisory Agreement for that account and, where RBC CM was the Overlay Manager, we will no longer be acting as a fiduciary to you with respect to that account. Payment of Program Fee The Program Fee will be deducted on a quarterly basis directly from your Program account unless you affirmatively elect, verbally or in writing, to be billed directly, or to have the Program Fee deducted from another account with your Broker Dealer for which RBC CM is custodian, provided that the account is not a custodial account (e.g., UGMA/UTMA account) or a Retirement Account, as permitted by applicable law. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 16 of 36 26-25-5088800_25213-CS (09/26)  If you have elected to be invoiced for the Program Fee and the Program Fee is not paid within sixty (60) days of the date of the invoice, RBC CM will instead debit your applicable Program account for the invoiced amount of the Program Fee due. Offset of Certain Fees to Retirement Accounts With respect to Retirement Accounts in the Consulting Solutions and RBC UP Programs, if you hold RBC GAM – U.S. Funds, including the RBC BlueBay Access Capital Community Investment Fund, RBC BlueBay Destra International Event-Driven Credit Fund, or Funds subadvised by RBC Rochdale, LLC (“RBC Rochdale”), we will rebate the net management fee charged by the Fund company to you. For other affiliated Funds and/or Funds sub-advised by an affiliate of ours (e.g., RBC GAM –U.S. ), the Program Sponsor Fee, and the Overlay Manager Fee when RBC CM acts as Overlay Manager in RBC UP, will not be assessed on the value of these Funds held in Consulting Solutions and/or RBC UP Retirement Accounts. Unless required by applicable law, the credit or offset will not apply to other Fund expenses such as transfer agency fees and shareholder servicing fees, or actual distribution, shareholder servicing and other fees paid to RBC CM and its affiliates. Additionally, RBC CM has a conflict of interest in offering and recommending proprietary and affiliated Funds in the Programs over non-proprietary and/or non-affiliated Funds because we and/or our affiliates receive the fees and expenses charged by such Funds rather than a non-affiliate. For more information see “Fees to RBC Affiliates” on our public website at www. rbcclearingandcustody.com/en-us/legal/. Comparing Costs You may pay more or less in a Program than you might otherwise pay if you purchased the services separately, through other firms, or if you chose to purchase the same or similar securities in a brokerage account without the investment advisory services through the Programs. Factors to consider with respect to the cost of a Program include but are not limited to: the cost of the services if provided and charged separately; the Program Fee rate charged in the Program; and the trading activity in your Program account. When making cost comparisons, you should be aware that the combination of investment management, custodial, consulting, and brokerage services available through a Program may not be available separately or may require multiple accounts, agreements, and fees. In addition, certain Investment Strategies, Overlay Managers, and/or Model Portfolios may not be available to clients outside of a Program either because of minimum account size requirements, fee schedules, geographic availability, or other factors. When assessing the overall cost of a Program, you should also consider that a Program account with low trading volumes, high cash balances, and/or significant fixed income positions could receive similar services at a lower cost in a brokerage account. If a Program account is actively traded through the Broker Dealer and RBC CM, the Program Fee may be less expensive than separately paying investment management fees, consulting fees, and trading and execution costs. In addition, investments that have no upfront fees or commissions, such as no-load Funds, may be available to you outside of a Program account at no additional cost. As discussed below in Item 4 under “Fund Fees and Expenses,” fees charged in connection with certain investments in your Program account, such as management and other fees charged by Funds, are not included in the Program Fee and will result in higher total costs than if you invested in such securities outside of a Program account. Additional Fees and Expenses The Program Fee (including all components described above) does not cover or include any of the following additional fees and expenses, where applicable: • Fees charged to you by your Broker Dealer; • commissions, “mark-ups,” “mark-downs,” and dealer spreads, if any, (i) that RBC CM or its affiliates receive when acting as principal in certain transactions where permitted by law, rule, or regulation, or (ii) that other broker-dealers receive when acting as principal in certain transactions effected through RBC CM and/or its affiliates acting as agent, which • is typically the case for dealer market transactions (e.g., fixed income, over-the-counter equity, and foreign exchange (“FX”) conversions in connection with purchases or sales of non-US dollar-denominated securities and with payments of principal and interest dividends on such securities); • underwriting commissions, investment banking, and other fees where RBC CM is a member of an underwriting syndicate; • certain other costs or charges that may be imposed by third parties including, among other things, bid-ask spreads, odd- lot differentials, exchange fees, transfer taxes, foreign custody fees, supplemental transaction fees, regulatory fees and other fees or taxes that may be imposed pursuant to law, rule, or regulation; • RBC CM’s usual and customary transaction charges on the liquidation of investments deemed ineligible for the Programs; • any contingent deferred sales charges, redemption charges, or other fees and expenses imposed by certain Funds or alternative investments (see Fund prospectus or private placement memorandum (“PPM”), as applicable, for details); RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 17 of 36 26-25-5088800_25213-CS (09/26)  • check reordering costs and fees; • short-term trading charges for purchases and corresponding redemptions of certain Fund shares (see Fund prospectus for details) made within a short period of time; • costs and expenses of UITs (e.g., organization costs, operating expenses, portfolio supervision, bookkeeping, trustee, and other administrative fees, etc.); • fees and charges specific to annuities linked to your Program account, which may include but are not limited to, administrative and termination/distribution charges, mortality and expense risk charges, expenses for underlying investment options and optional rider/benefit fees; • RBC Express Credit (margin) or RBC Credit Access Line (CAL) interest, or interest on other debit account balances; • non-sponsored alternative investment processing and maintenance fees; • safekeeping fees for physical securities; • American Depositary Receipt (“ADR”) pass-through fees; • additional costs incurred when purchasing foreign securities that are assessed by the foreign exchange, including, but not limited to, exchange fees, taxes, conversion fees and currency translation costs. For example, when “ordinary shares” are purchased on a foreign exchange (which may charge a fee or tax on the trade) and are converted to ADRs, the depository bank may charge a fee to convert the ordinary shares to ADRs and in doing so, there may be currency translation costs associated with the conversion; • additional costs when investing in foreign securities and utilizing foreign tax relief and reclamation services; • fees charged by RBC CM related to reporting and filing unrelated business taxable income in Retirement Accounts; and • any fees/expenses associated with RBC Insured Deposits. Fund Fees and Expenses Funds pay fees and expenses that are ultimately borne by clients (including, but not limited to, management fees, brokerage costs, administrative, and custody fees), as detailed in each Fund’s prospectus. Program clients that are holding or investing in Funds will pay two levels of investment advisory fees: 1) investment management fees charged by the Fund companies, and 2) Program Fees to your Broker Dealer, RBC CM as Program sponsor, the Investment Managers, the Model Providers, and/or the Overlay Manager. Some of the fees and expenses are paid to and, where permitted under applicable regulatory requirements, retained by us and/or the Broker Dealer for advisory and/or other services. Funds eligible for the Programs will be subject to the Program Fee which could also subject you to a higher overall cost. Outside of the Cash Sweep Program, RBC CM may, without notice to you, convert Funds in your Program account to a lower cost share class of the same Fund offered by RBC CM or make changes to your investment model or allocation in the event a lower cost share class of the same Fund is or becomes available through RBC CM. However, if you purchased a Fund from RBC CM with an up-front sales charge, typically in a brokerage account outside of the Programs, and subsequently transfer such Fund shares into an advisory Program account, those Fund shares will not be subject to the Program Fee for two or more years from the date of initial purchase. Fund shares purchased at other financial institutions may be converted to the appropriate share class in a Program account and subject to the Program Fee immediately whether you paid an up-front sales charge or other compensation or not. RBC CM may also elect not to convert certain Fund shares if, for example, there is no equivalent share class available in the Programs, or such conversion could subject you to additional sales or other charges, or in certain other circumstances, as determined by us. Additionally, if you have a systematic buy or sell transaction established for a Fund that is ineligible for the Program selected, the transaction may be rejected resulting in your trade(s) not being fulfilled. Prior to enrolling in the Programs, you should review the costs and impact of converting your Fund share classes and discuss this with your Financial Professional. If you do not want your Funds converted, or your investment model/allocation updated, you should discuss leaving those holdings in or transferring those holdings to a non-Program account. Under certain circumstances, your account may be invested in a Fund share class with a 12b-1 fee. This fee, which is also known as a distribution fee, is an operational expense used to pay for marketing and distribution expenses and is therefore included in the Fund’s expense ratio. 12b-1 fees are part of the overall Fund expense ratio, which is paid by you through deduction of assets in the Fund’s daily net asset value calculation. 12b-1 fees may vary by share class, with certain share classes having lower or no 12b-1 fees. Typically, the 12b-1 fee is paid to your Broker Dealer as ongoing compensation for a period of time, as outlined in the applicable prospectus, creating an incentive for your Broker Dealer to recommend a Fund and a share class that pays a 12b-1 fee as opposed to a Fund or share class that does not. Excluding the Cash Sweep Program, RBC CM addresses this conflict of interest by (1) limiting offerings of share classes that pay a 12b-1 fee in the Programs, and (2) crediting any 12b-1 fees that RBC CM receive back to you rather than paying such fee to the Broker Dealer. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 18 of 36 26-25-5088800_25213-CS (09/26)  Funds and certain other investments will be accompanied by a prospectus or other offering document that contains important information about each such Fund, including investment objectives, risks, and applicable fees and expenses. Clients should read each Fund’s prospectus carefully and consider all the information in it before investing. If, and to the extent that your account is invested in a Fund managed by an affiliate of ours, you will indirectly pay two levels of advisory and other fees to us in connection with such balances (i.e., the investment management fees charged by the Fund companies, and the Program Fee). We address this conflict through disclosure and by subjecting the affiliated Funds to the same selection and evaluation standards as non-affiliated Funds. Further, in Retirement Accounts, if you hold Funds subadvised by RBC Rochdale, the management fee charged by the Fund company will be rebated to you. For other RBC CM affiliated Funds subadvised by RBC Rochdale, the Program Sponsor Fee payable to RBC CM, and when RBC CM acts as the Overlay Manager in RBC UP, the Overlay Manager Fee component of the Program Fee, will not be assessed to the value of such Funds maintained in Retirement Accounts. You should read the Fund’s prospectus carefully prior to selecting a Fund. Trading Away and Associated Costs We generally anticipate most Investment Managers and the Overlay Managers will effect substantially all portfolio trades for Program accounts with or through us. This arrangement creates an incentive for us to make available Investment Managers or Model Providers with lower portfolio turnover rates. There are certain Investment Managers, including those offering certain fixed income strategies, that have historically directed most, if not all, their trades to outside broker dealers. RBCCM makes information on Investment Managers’ trading practices in this regard available via the “Investment Managers and Trading Practices” link at RBC CM’s legal disclosure website, www.rbcclearingandcustody.com/disclosures. The information we provide in this regard is based solely on the historical information provided to us by the Investment Managers. We do not make any representations regarding their future trading practices. If Investment Managers trade away from RBC CM with other broker dealers, you should understand that commissions, mark- ups, spreads, and other transactional charges for such trades are charged to you by the executing broker-dealer (and passed along to you by RBC CM). Accordingly, the Program Fee you pay does not cover such costs charged by other broker-dealers; the Program Fee covers these costs only when the transactions are executed by RBC CM. The executing broker-dealer may net these commissions, mark-ups, spreads and other transactional charges into the overall purchase or sale price of the trades, and these commissions, mark-ups, spreads and other transactional charges are not delineated on your RBC CM trade confirmation, monthly transaction summary or statement. RBC CM does not restrict an Investment Manager’s ability to trade away, as the responsibility to determine the suitability of trading away from RBC CM and for best execution is that of the Investment Manager. RBC CM does not evaluate whether an Investment Manager is meeting its best execution obligations when trading away. You should understand that RBC CM is not a party to transactions that are not executed through or with us, and therefore, we are not able to negotiate the price or transaction-related charge(s) with the executing broker-dealer. While the costs associated with equity trades done away are typically in the form of commissions and other transactional charges that are disclosed and accessible to RBC CM, the additional costs associated with fixed income trades are not identified separately because they are incorporated into the net price of the trade. Additional information on trade-away practices of Investment Managers in Consulting Solutions is available via at: www.rbcclearingandcustody.com/disclosures. Note, before selecting an Investment Manager for any Program described in this brochure, you should carefully review all material related to that Investment Manager, including any disclosure on whether the Investment Manager uses broker- dealers other than RBC CM to effect any trades and any additional trading costs (brokerage commissions or other charges) associated with executing trades with such other broker dealers. You should consider this information (i.e., an Investment Manager’s trading practices and any associated additional costs and expenses), when assessing the overall costs of a Program and a particular Investment Manager and/or Investment Strategy. Foreign Tax Relief and Reclamation Services For clients who invest in international securities, we utilize a third-party vendor that provides foreign tax relief and reclamation services on behalf of clients. For more information, please see “Foreign Tax Relief and Reclamation Overview” on our public website at www.rbcclearingandcustody.com/disclosures. Tax Considerations The payment of the Program Fee as described above may produce income tax results different from those resulting from the payment of brokerage commissions or other transactional charges on a per trade basis. If you are not a tax-exempt entity, the sale, redemption, or exchange of investments may result in taxable gains or losses. Further, it is your responsibility to ensure that the payment method selected, and subsequent treatment of the related expenses, complies with applicable tax laws and other regulations. In addition, careful consideration should be given prior to purchasing investments or selecting strategies that may utilize “tax-advantaged” investments in certain qualified accounts. This may result in no additional tax benefits at the expense of performance. Neither RBC CM, nor its affiliates or employees provide legal, accounting or tax advice. All legal, accounting or tax decisions regarding your accounts and any transactions or investments entered into in RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 19 of 36 26-25-5088800_25213-CS (09/26)  relation to such accounts, should be made in consultation with your independent advisors. No information, including but not limited to written materials provided by RBC CM or its affiliates or employees, should be construed as legal, accounting or tax advice. Compensation to Broker Dealer Advisory Fees For information on how your Broker Dealer compensates its advisory personnel and financial professionals, please see your Broker Dealer’s ADV brochure or other similar disclosure documents, or contact your Financial Professional. Broker Dealers are compensated based on the market value of billable assets in your Program account. In certain instances, your account could contain assets that are not included in the billable value of the account. Therefore, this is a conflict of interest as your Broker Dealer could have a financial incentive to sell these assets and purchase assets that would be included in the billable value of the account and directly impact compensation. Securities-Based Lending Through Lending Programs (i.e., RBC Express Credit or RBC Credit Access Line), RBC CM and the Broker Dealer receive additional compensation based on the amount of loan balance outstanding. This additional compensation presents a conflict of interest for us because it creates an incentive for us to make affiliated Lending Programs available to you in the Programs. This conflict of interest is addressed by appropriate disclosure. Revenue Sharing Arrangements RBC CM has revenue sharing arrangements with certain Broker Dealers in connection with the Lending Programs and RBC Insured Deposits, which reduce revenue to RBC CM, and result in RBC CM receiving different fees across business channels. The different compensation structures and differential payments across business channels create a conflict of interest for us because they provide an incentive for us to recommend those business channels that pay us more compensation. ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS To open an account in any of the Programs and receive the investment advisory and other related services described in this brochure, you must enter into the Advisory Agreement with your Broker Dealer and RBC CM. The Advisory Agreement expressly acknowledges the parameters of our investment advisory relationship with you, describes the services we will provide to you, and details the terms and conditions of the Program. The Advisory Agreement governs the relationship with your Broker Dealer and RBC CM with respect to the terms of your existing and future Program accounts. Each of the Programs generally requires a certain minimum amount of assets to open an account in that Program. However, RBC CM has the discretion to accept accounts that are below the Program minimums. RBC CM reserves the right to terminate a Program account if the account assets fall below the Program minimums set forth below. • RBC Advisor: $25,000. • RBC UP: Depending on services and Investment Products selected, minimums range from $2,500-$500,000. • Consulting Solutions: $100,000-$600,000 for equity strategies; $100,000-$500,000 for fixed income strategies, subject to minimum account requirements imposed by the applicable Investment Manager. RBC CM provides investment advisory services to individuals, foundations, endowments, employee benefit plans, trusts, estates, educational institutions, corporations, businesses, government entities and other entities. The Programs are generally available for both non-retirement and Retirement Accounts, including IRAs. When providing services to clients who are subject to ERISA, we may rely on various Prohibited Transaction Exemptions (“PTEs”) available under ERISA, including PTE 84-14, which is only available to qualified professional asset managers (the “QPAM Exemption”). On March 5, 2024, the French Court of Appeal rendered a judgment of conviction (the “Conviction”) against Royal Bank of Canada Trust Company (Bahamas) Limited (“RBCTC Bahamas”), an affiliate of RBC CM, and other parties regarding a charge of complicity in estate tax fraud relating to actions taken relating to a trust for which RBCTC Bahamas serves as trustee. In 2016, RBC was granted an exemption by the U.S. Department of Labor that allowed RBC and its current and future affiliates to continue to qualify for the QPAM Exemption under ERISA despite the conviction of RBCTC Bahamas in the French proceeding for a temporary one-year period from the date of conviction. In 2025, the Department of Labor granted RBC an exemption providing longer-term relief, which is effective from August 12, 2025, through March 4, 2030. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 20 of 36 26-25-5088800_25213-CS (09/26)  ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION Selection of Investment Managers and Model Providers In RBC UP and Consulting Solutions, we consider and select only Investment Managers and Model Providers that meet our eligibility requirements. In identifying and choosing Investment Managers and Model Providers, we evaluate the financial and organizational stability of the firm and product, historical performance results, experience, and other factors. Based on the evaluation, Investment Managers and Model Providers are categorized by their respective investment styles. Each Model Portfolio and Investment Strategy added to the RBC UP and/or Consulting Solutions Programs, as applicable, are further categorized by the level of conviction RBC CM has in the Investment Manager and/or Model Provider and their respective Investment Strategy or Model Portfolio. Information that we gather regarding Investment Managers and Model Providers is believed to be reliable and accurate, but we do not independently verify it. We conduct periodic reviews of Envestnet and our own Overlay Manager function to evaluate adherence to Model Portfolios and investment allocations selected by you. As described above in Item 4, you will establish an Advisory Risk Profile for your Program account. For Programs in which you select an Investment Manager(s) or Model Provider(s), your Financial Professional will consult with you regarding investment alternatives consistent with your Advisory Risk Profile. You then can select one or more Investment Managers (and their Investment Strategy(ies)) and/or Model Providers (and their Model Portfolio(s)). When required to do so by law or as otherwise agreed to with an Investment Manager, we will provide you with a copy of each Investment Manager’s and/or the Overlay Manager’s written disclosure statement (Part 2A of its Form ADV or other comparable document) at the time of Program enrollment. Monitoring and Review of Investment Managers and Model Providers On a quarterly basis, we monitor and review the Investment Managers we make available in Consulting Solutions and RBC UP, and the Model Providers we make available in RBC UP, to determine whether they continue to meet the standards and requirements of RBC CM. This evaluation may involve, among other things, a review of investment discipline and trends in investment philosophies. Comparisons are made to other accounts and to standard industry market statistics. These initial and ongoing due diligence reviews are conducted by the RBC Global Manager Research team (“GMR”). The level of review applied by GMR depends on RBC CM’s conviction in each Investment Manager and Model Provider and their respective Investment Strategies and Model Portfolios. For the highest conviction Investment Strategies and Model Portfolios, this review is based on both the investment style descriptions offered by the Investment Managers and Model Providers (qualitative factors) and analysis performed by GMR (quantitative factors). GMR’s ratings and opinions for the highest conviction Investment Strategies and Model Portfolios are available to Broker Dealers. These ratings and opinions are updated annually or more frequently, as needed. Investment Strategies and Model Portfolios not deemed highest conviction are reviewed quarterly based primarily on quantitative factors. A quantitative score (“Score”) is assigned to each Investment Strategy and Model Portfolio based on multiple factors related to the firm and product, investment professionals, investment approach and performance and weights assigned to the individual factors selected. Investment Strategies and Model Portfolios not deemed to be the highest conviction must meet these predefined Scores to be added and maintained in RBC UP and Consulting Solutions. If a Score cannot be calculated, the same factors are reviewed manually, instead of systematically, until a Score can be calculated. For cases where a Score cannot be produced, GMR will continue to qualitatively monitor the applicable Investment Strategies and Model Portfolios and provide annual updates as needed to the RBC CM Managed Account Investment Committee. Scores are not assigned to the RBC CM Portfolio Advisory Group (“PAG”) Model Portfolios. Each of the PAG Model Portfolios is reviewed quarterly by an internal oversight committee led by GMR to determine if it continues to align with its stated investment objective. Through our monitoring process, the level of conviction in an Investment Strategy or Model Portfolio may change, and therefore, the level of review applied may also change. If you would like information regarding RBC CM’s conviction in a particular Investment Strategy or Model Portfolio, please contact your Financial Professional. The level of conviction we have in an Investment Strategy or Model Portfolio is not indicative of its quality nor is it a basis for how the Program Fee is determined. Watch List As part of our monitoring process, RBC CM maintains a watch list of Investment Strategies and Model Portfolios for which there may be developments of potential concern. Such developments may include the Investment Managers’ or Model Portfolios’ adherence to management style, consistency with client objectives, unexplained poor performance, or other matters that come to our attention. The watch list provides us with the means to review and communicate developments related to Investment Managers and Model Providers in RBC UP and Consulting Solutions. Placement of Investment Managers and/or Model Providers on the watch list initiates a probationary period that allows us adequate time to better assess the effects — negative or positive — stemming from the developments in question. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 21 of 36 26-25-5088800_25213-CS (09/26)  Performance • Investment Manager and Model Provider. For all Investment Strategies and Model Portfolios, we produce product profiles containing reported historical performance available to Broker Dealers to provide to you. These product profiles include the Investment Manager’s or Model Provider’s reported performance and generally present 10 years of an investment strategy’s performance history. • Fund Performance. We utilize the Fund’s published performance for review purposes. • Portfolio Advisory Group (PAG). We create performance composites for each PAG Model Portfolio and make them available to your Broker Dealer to provide to you. These composites are comprised of the RBC UP Sleeves invested in each such Model Portfolio. We make product profiles for each PAG Model Portfolio available to Financial Professionals to provide to you. These product profiles include our calculated composite performance. Your Financial Professional may provide you with information to allow you to compare this PAG performance data with your account and/or Sleeve performance. Removal of an Investment Strategy, Model Portfolio, Overlay Manager, or Fund Upon written notice to affected clients, we may remove an Investment Strategy or Model Portfolio from RBC UP or Consulting Solutions if our rating and/or opinion of the Investment Strategy or Model Portfolio materially changes. This will most commonly be a result of fundamental developments that are determined to be detrimental to the potential longer-term success of the Investment Manager, Model Provider, or underlying investment strategy (e.g., departure of key personnel, performance, etc.). In such event, we will promptly notify your Broker Dealer, who will in turn consult with you to reallocate applicable account assets to a new Investment Manager or Model Provider. In the event RBC CM removes an Investment Strategy from Consulting Solutions, and you do not reallocate applicable account assets prior to the termination of the Investment Strategy, we may terminate your Program account. In RBC UP, when RBC CM removes a Model Portfolio or Investment Strategy selected for your account, if you do not select a new Model Portfolio or Investment Strategy before the removal date, we will move your assets to an available Investment Strategy or Model Portfolio which we deem, in our sole discretion, to be consistent with the removed Model Portfolio or Investment Strategy. If an appropriate replacement Model Portfolio or Investment Strategy is not available, we will move your assets to an appropriate Fund and/or closed-end fund. In RBC UP, we will provide information to your Broker Dealer regarding a Fund that is no longer eligible for the Program. Your Financial Professional will work with you to select a suitable replacement investment. In RBC UP, we may change the Overlay Managers upon advance written notice to the affected clients. Related Persons as Investment Manager, Model Provider, and/or Overlay Manager, and Associated Conflicts of Interest If you invest in certain Programs described in this brochure, your account may be managed by an Investment Manager that is an affiliate of ours (also referred to as a related person), or that is a client of an affiliate of ours. In addition, we, or our affiliates (or clients of our affiliates) may act as Model Providers. Related persons or their clients acting as Investment Managers or Model Providers are subject to the same eligibility, review, and removal procedures as non-affiliated Investment Managers and Model Providers, as described above. When related persons or their clients act as Investment Managers or Model Providers for Program clients, certain conflicts of interest exist (see Item 9, Material Relationships with Related Persons for more information on conflicts of interest). In some cases, the same Investment Strategies are available in both Consulting Solutions and RBC UP. However, the fees associated with these Investment Strategies may differ depending on the Program. Generally, for fixed income Investment Strategies available in both Consulting Solutions and RBC UP, the Investment Manager Fee is the same. However, for equity Investment Strategies available in both Consulting Solutions and RBC UP, the RBC UP Model Provider Fee is generally lower than the Consulting Solutions Investment Manager Fee due to the specific services provided in each Program. Consulting Solutions client accounts are separately managed to an Investment Strategy by the Investment Managers in the Program on a discretionary basis. In contrast, in RBC UP, implementation of, and updates to, Model Portfolios are managed by us or Envestnet as Overlay Manager on a discretionary basis. When we act as Overlay Manager in RBC UP, we retain the 0.05% Overlay Manager Fee that we charge which can give us an incentive to promote RBC UP over Consulting Solutions, particularly where an investment strategy is available in both Programs. Any difference in fees paid by you and fees we pay to the Investment Managers, Model Providers or the Overlay Managers are retained by us. This fee differential for certain equity investment strategies is larger in Consulting Solutions than in RBC UP. When fee differentials are retained by us, we do not pay any part of the retained fees to Broker Dealers. Therefore, Broker Dealers do not have a direct financial incentive to recommend using investment strategies in one Program over the other. Additionally, our Cash Sweep Program creates a conflict of interest for us because we have an incentive for you to maintain and direct otherwise uninvested cash in your account to Deposit Accounts of our Affiliate Banks and third-party banks, RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 22 of 36 26-25-5088800_25213-CS (09/26)  where RBC CM earns a fee on such cash balances and RBC CM and our affiliates can use such deposits to generate additional revenue. Please see the above Cash Sweep Program Conflicts of Interest section in Item 4 for additional details. More information regarding the Cash Sweep Program is available in the Cash Management section of our public website at www.rbcclearingandcustody.com/disclosures. In the Programs, you may be able to invest in Funds and other investment products affiliated with RBC CM. Certain conflicts of interest among the issuer, Fund, the Fund manager, and/or the broker or agent may exist as described in the applicable prospectus. Where we are affiliated, through common ownership and control by the RBC, with a Fund, Fund manager, issuer or agent, we have an incentive to make our proprietary or affiliated product available over an unaffiliated product, such that the fees and expenses charged by the Fund, Fund manager, issuer or agent are earned by us or our affiliate, rather than a non-affiliate. You may invest in an Investment Manager and/or Model Provider affiliated with RBC CM. We have an incentive to make our affiliated Investment Managers and Model Providers available because RBC CM and its affiliates receive greater revenue. RBC GAM – U.S. RBC GAM – U.S. acts as an Investment Manager in Consulting Solutions and as a Model Provider in RBC UP. This is a conflict of interest as we are incented to make RBC GAM – U.S. available as a Model Provider and Investment Manager over non- affiliates. This conflict of interest is addressed by proper disclosure. If you select RBC GAM – U.S. as your Investment Manager in Consulting Solutions, or as your Model Provider in RBC UP, RBC GAM – U.S. and RBC CM will each collect separate advisory fees. RBC Global Asset Management (UK) Limited RBC Global Asset Management (UK) Limited (“GAM UK”) acts as a Model Provider in RBC UP. This is a conflict of interest as we are incented to recommend GAM UK over non-affiliates. This conflict of interest is addressed by proper disclosure. If you select GAM UK as your Model Provider in RBC UP, GAM UK and RBC CM will each collect separate advisory fees. RBC CM Acting as Portfolio Manager As discussed above in Item 4, RBC CM acts as the Overlay Manager in RBC UP. Our participation in a Program creates an incentive for us to make such Program available where we are the Portfolio Manager over other qualified and suitable Portfolio Managers. Where RBC CM serves as the Overlay Manager in RBC UP, we charge and retain the Overlay Manager Fee component of the Program Fee you pay. PAG independently analyzes research from its research providers and makes such information available to Broker Dealers. The research that is produced by PAG is intended to provide a broad and extensive array of fundamental research in the marketplace by focusing on key analysts, recommendations, and trends within their research sources, including those of RBC CM as well as through nationally recognized correspondents. Using such research data provided by PAG, RBC CM also creates equity Model Portfolios for use in RBC UP. RBC CM does not receive a Model Provider Fee for providing these Model Portfolios. While PAG’s research is independent, RBC CM has a conflict of interest when selecting Funds for inclusion in a model portfolio because we have an incentive to use certain Funds over others. Specifically, we have an incentive to select 1) Funds for which we receive additional compensation from the investments in such Funds, and/or 2) Funds managed by an affiliate of RBC CM which results in compensation to any such affiliate. We mitigate this conflict of interest by disclosure and subjecting RBC CM’s Model Portfolios to review by an internal oversight committee on a regular basis, consistent with the standards employed when reviewing and selecting those of unaffiliated and affiliated Investment Managers and Model Providers, as further detailed in Item 6. Selection of Investment Managers and Model Providers. Performance-Based Fees and Side-by-Side Management RBC CM does not charge performance-based fees in the Programs. However, certain Funds available in the Programs may be subject to performance-based fees or varying expense charges imposed by the Fund manager. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies The methods of analysis used and investment strategies available in each Program are described above in the “Services, Fees and Compensation” and the “Portfolio Manager Selection and Evaluation” sections. We obtain information from various sources including financial publications, company press releases and securities filings, research and due diligence material prepared by RBC CM, our affiliates and other third parties, rating or timing services, regulatory reports, third-party data, and research providers, professionals and other public sources. Your Broker Dealer may use research, model portfolios, and/or asset allocation recommendations provided by RBC CM, our affiliates and/or third parties to make recommendations to you. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 23 of 36 26-25-5088800_25213-CS (09/26)  Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. There is no guarantee of performance for any investment strategy implemented or recommended by your Broker Dealer, and the value of a client’s investments will fluctuate due to market conditions and other factors. Investments are subject to various risks, including, but not limited to, market, liquidity, currency, economic, and political risk, and will not necessarily be profitable. Past performance does not predict or guarantee any level of future performance. For the strategies used in the Programs, equities, Funds, options, and fixed income securities are the primary investments. Below are certain material risk factors associated with the Programs and the strategies utilized in the Programs. There are certain other risk factors described throughout this brochure. For more details on material risk factors associated with Investment Strategies, Model Portfolios, and/or the services of the unaffiliated Overlay Manager in applicable Programs, please refer to each Investment Manager’s, Model Provider’s, and/or the Overlay Manager’s Form ADV Part 2A brochure and/or other similar disclosure documents. In addition, always read the prospectus or other offering documents for a full description of risks associated with a particular investment. You are urged to consult with your Broker Dealer to discuss the risks associated with any investment strategy, particular investments, securities, and/or transactions recommended or effected in your Program account(s). Some of the material risks associated with investments available in the Programs are as follows: • Market Risk. The value of securities owned by an investor may go up or down, sometimes rapidly or unpredictably, due to factors affecting certain industries and/or securities markets generally. • Interest Rate Risk. Fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. • Economic Conditions Risk. The economic, political, or financial developments will, from time to time, result in periods of volatility or other adverse effects that could negatively impact your account. • Credit Risk. Investors could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. • Liquidity Risk. Investors would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments and interval funds have higher liquidity risk than securities traded on exchanges, fixed income securities or open-end mutual funds. • Risks Relating to Equities. The price may rise or fall, sometimes rapidly or unpredictably, because of changes in a company’s financial condition. These price movements can result from economic changes or macro factors such as the economic performance of a particular country, interest rate movements, and international developments. Sector or industry developments as well as changes in government regulations may affect equity prices. • Risk Relating to Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures, and the investor may lose income. • Risks Relating to Specific Styles. Different types of stocks tend to shift in and out of favor depending on market and economic conditions. To the extent a portfolio emphasizes a value or growth style of investing, a portfolio runs the risk that undervalued companies’ valuations will never improve or that growth companies may be more volatile than other types of investments, respectively. • Risks Relating to Securities-Based Lending. Certain Program accounts may be eligible for Margin or other types of securities-based lending as part of RBC CM’s brokerage services. The extension of credit may be obtained through Lending Programs described above. Prior to enrolling in any of the Lending Programs, you should carefully review the agreement and disclosures for such Lending Program and ensure that you understand the risks associated with leveraging your account. You must carefully consider: Whether or not you can afford, and want, to assume the additional risks that losses in your account may be significantly greater than if you decide not to invest with borrowed funds (i.e., not to use leverage). Leveraging your account may increase your risks and make your investment objectives more difficult to realize you may lose more than your original investment; You will pay interest on the outstanding loan balance; thus, the use of leverage will increase your costs of investing; RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 24 of 36 26-25-5088800_25213-CS (09/26)  Since the Program Fee is calculated as a percentage of the net market value in a Program account, the use of Margin to purchase additional securities in a Program account will increase the net market value of the Program account by the value of such additional securities purchased with the proceeds of the Margin loan (and will not be offset by the amount of the client’s Margin debit held in an account outside of a Program). This will result in a higher Program Fee that you pay to us and your Broker Dealer. This will result in additional compensation to RBC CM, Broker Dealer; RBC CM, or a third-party lender, can force the sale of Program assets to satisfy collateral requirements without notice to you; Neither RBC CM nor our affiliates will act as an investment adviser to you with respect to the liquidation of securities held in a Program account to meet collateral requirements. These liquidations will be executed in our capacity as broker-dealer and creditor and may, as permitted by and in accordance with applicable laws, rules, and regulations, including the Advisers Act, result in executions on a principal basis in your account; and Under these circumstances, RBC CM cannot guarantee a favorable price on the sale of Program assets or that the liquidations align with your investment strategy or Advisory Risk Profile. RBC CM is permitted to lend or utilize Margin securities in its possession and receives compensation in connection with the use of such securities. The costs you pay associated with the Lending Programs is not included in the Program Fee and will result in additional compensation to RBC CM and/or our affiliates and your Broker Dealer. For more information, please see the “Margin Disclosure Statement” under “RBC Express Credit” on our public website at www.rbcclearingandcustody.com/disclosures. • Risks Relating to Money Market Funds. An investment in a money market fund is neither insured nor guaranteed by the FDIC or any other government agency. Although money market funds seek to preserve the value of your investment at $1.00 per share, there is no assurance that will occur, and it is possible to lose money if the fund value per share falls. Moreover, in some circumstances, money market funds may be forced to cease operations when the value of a fund drops below $1.00 per share. If this happens, the fund’s holdings are liquidated and distributed to the fund’s shareholders. This liquidation process is likely to take a month or more. During that time, these funds would not be available to you to support purchases, withdrawals and, if applicable, check writing or other money movement debits from your account. • Concentration Risk. To the extent a client concentrates their investments by investing a significant portion of their assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub-sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub-sectors. An individual sector, industry, or sub sector of the market may be more volatile and may perform differently than the broader market. The several industries that constitute a sector may not all react in the same way to economic, political, or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub-sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. • Risks Relating to Foreign Securities and Emerging Markets. Investments in securities of foreign issuers denominated in foreign currencies are subject to risks in addition to the risks of securities of U.S. issuers. These risks include political and economic risks, civil conflicts and war, greater volatility, expropriation and nationalization risks, sanctions or other measures by the United States or other governments, currency fluctuations, higher transactions costs, delayed settlement, possible foreign controls on investment, liquidity risks, and less stringent investor protection and disclosure standards of some foreign markets. Events and evolving conditions in certain economies or markets may alter the risks associated with investments tied to countries or regions that historically were perceived as comparatively stable becoming riskier and more volatile. These risks are magnified in countries in emerging markets, which may have relatively unstable governments and less-established market economies than those of developed countries. Emerging markets may face greater social, economic, regulatory, and political uncertainties. These risks make emerging market securities more volatile and less liquid than securities issued in more developed countries. For more information, see the “Risks Related to Foreign Securities and Foreign Currencies section” in the Customer Account Agreement and Disclosure, available on our public website at www.rbcclearingandcustody.com/disclosures. • High Yield Securities Risk. Certain strategies invest in securities and instruments that are issued by companies that are highly leveraged, less creditworthy, or financially distressed. These investments (known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties, and potential illiquidity. For more information see the “High-Yield Securities Disclosure” on our public website at www.rbcclearingandcustody.com/disclosures. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 25 of 36 26-25-5088800_25213-CS (09/26)  • Counterparty Risk. An account may have exposure to the credit risk of counterparties with which it deals in connection with the investment of its assets, whether engaged in exchange traded or off-exchange transactions or through brokers, dealers, custodians, and exchanges through which it engages. In addition, many protections afforded to cleared transactions, such as the security afforded by transacting through a clearing house, might not be available in connection with over-the-counter (“OTC”) transactions. Therefore, in those instances in which an account enters into OTC transactions, the account will be subject to the risk that its direct counterparty will not perform its obligations under the transactions and will sustain losses. • Derivatives Risk. Certain strategies may use derivatives. Derivatives, including forward currency contracts, futures, options and commodity-linked derivatives and swaps, may be riskier than other types of investments because they may be more sensitive to changes in economic and market conditions, and could result in losses that significantly exceed the investor’s original investment in the derivative. Many derivatives create leverage thereby causing a portfolio to be more volatile than it would have been if it had not been exposed to such derivatives. Derivatives also expose a portfolio to counterparty risk (the risk that the derivative counterparty will not fulfill its contractual obligations), including the credit risk of the derivative counterparty. Certain derivatives are synthetic instruments that attempt to replicate the performance of certain reference assets. Regarding such derivatives, an investor does not have a claim on the reference assets and is subject to enhanced counterparty risk. Derivatives may not perform as expected, so an investor may not realize the intended benefits. The possible lack of a liquid secondary market for derivatives and the resulting ability to sell or otherwise close a derivatives position could expose a portfolio to losses. Additionally, certain derivatives are subject to position limits imposed by regulators, and the investment adviser will not be able to obtain additional exposure if these limits are reached. When used for hedging, the change in value of a derivative may not correlate as expected with what is being hedged. In addition, given their complexity, derivatives expose an investor to risks of mispricing or improper valuation. • Risks Relating to Structured Investments. Structured Investments are generally a combination of unsecured debt and other underlying assets. Since Structured Investments represent an unsecured debt obligation of the issuer, you should consider the creditworthiness of the company issuing the security, since downside protections and payment features are contingent upon the solvency of the issuer. The potential benefits of Structured Investments typically will not be fully realized unless held to maturity. For example, if sold prior to maturity, the sale will be subject to market prices and the principal may not be fully returned. There is no guarantee of secondary market price or interim liquidity, and the interim value of a Structured Investment could differ from the original issue price and the investments intrinsic value. Depending on the type of structure, risks of investing in a Structured Investment include, but are not limited to, call risk, coupon risk, currency risk, liquidity risk, issuer credit risk, loss of principal risk, risks associated with the performance of underlying assets, and tax risk. Structured Investments are complex and are not appropriate for all investors. You should understand the complete terms, risks, tax consequences, and possible performance outcomes of investing in any Structured Investment before purchasing, as each structure is different and constructed for different investment objectives and market conditions. When considering a Structured Investment, you should review the accompanying prospectus, which will contain more complete information. • Risks Relating to Smaller Companies. Investments in smaller companies are generally riskier than investments in larger companies. The securities of smaller companies may trade less frequently and in smaller volumes than securities of larger companies. Securities of smaller companies tend to be less liquid than securities of larger companies. In addition, small companies are generally more vulnerable to economic, market and industry changes. As a result, the changes in value of their securities may be more sudden or erratic than in large capitalization companies, especially over the short term. Because smaller companies may have limited product lines, markets or financial resources or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than large capitalization companies. This may cause unexpected and frequent decreases in the value of an account’s investments. Finally, emerging companies in certain sectors may not be profitable and may not realize earning profits in the foreseeable future. Voting Client Securities (Proxy Voting) You have the right to vote proxies for securities held in your Program account(s). In general, for Programs other than RBC Advisor, you also have the option to delegate proxy voting authority as described below. In the Advisory Agreement, you indicate your proxy voting authority election for your Program account(s). • Client as proxy authority. For all Programs, you can retain the right to vote proxies with respect to the securities held in the account(s), or delegate that right to another third-party designated by you. If you retain proxy voting authority, we will forward to you (or another third-party designated by you) all proxy-related materials, annual and interim reports, and other issuer-related materials that RBC CM receives pertaining to the securities in your Program account(s). • Manager as proxy authority. For certain Programs, you can delegate your proxy voting authority to a manager to vote proxies with respect to the securities held in your Program account(s). If you delegate voting authority to a manager, we will forward all proxy-related materials, annual and interim reports, and other issuer-related materials that RBC RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 26 of 36 26-25-5088800_25213-CS (09/26)  CM receives pertaining to the securities in your Program account(s) to a third-party Investment Manager(s) or Overlay Manager (i.e., Envestnet or RBC CM), if applicable, to vote proxies on your behalf. When a client has delegated proxy voting authority to RBC CM, RBC CM further delegates such authority to an independent third-party proxy voting agent, currently Institutional Shareholder Services (“ISS”), as described below. We will not provide you with notice that we have received a proxy solicitation, nor will we or any third-party Investment Manager or proxy voting agent consult with you before casting a vote. Your designation of “Manager” is only valid if accepted by that designee. Investment Managers and the Overlay Managers retain the right to rescind their acceptance of the proxy authorization. If an Investment Manager or the Overlay Manager elects to stop voting proxies, we will forward proxy voting materials to you (or a third-party agent designated by you),and if an Investment Manager or Overlay Manager elects to start voting proxies, we will send to them all proxy-related materials and you will not receive them. You may change your proxy voting election at any time upon written notice to us, in accordance with the terms of your Advisory Agreement. If you or RBC CM terminate a Program account, RBC CM will revert proxy voting authority to you (or another third-party selected by you). RBC Advisor In RBC Advisor, clients retain the right and authority to vote all proxies for securities. RBC CM does not have, and will not accept, authority to vote client securities held in RBC Advisor accounts. In the Advisory Agreement, if you designate “Manager” to vote proxies for any RBC Advisor account, we will default proxy voting authority to you, “Client”, and in accordance with applicable law, we will forward to you (or a third-party agent designated by you) all proxy-related materials, annual reports, and other issuer-related materials that RBC CM receives pertaining to the securities in your RBC Advisor account(s). RBC UP If you designate “Manager” as proxy authority for your account(s) in RBC UP, RBC CM or Envestnet as Overlay Manager, will vote proxies on your behalf. When we vote proxies, we have a fiduciary responsibility to vote proxies in a manner that we believe is consistent with your best interest and in accordance with the policies and procedures adopted by RBC CM. We have retained ISS, to provide fundamental research and independent voting recommendations based on its standard proxy voting guidelines, and to vote proxies in your account(s) on our behalf. The proxy voting guidelines set forth by ISS are reasonably designed to identify potential conflicts of interest when voting proxies on a client’s behalf. The engagement of ISS as our agent is not intended to be a delegation of our proxy voting responsibilities and does not relieve us of any fiduciary obligations with respect to the voting of proxies. RBC CM has implemented policies reasonably designed to identify potential material conflicts of interest to help us vote proxies without undue influence from individuals or groups who may have an economic interest in the outcome of a proxy vote. These policies include: • Causing the proxies to be delegated to an independent third party; • Causing the independent third party to use predetermined voting guidelines; • Causing proxies to be voted in accordance with recommendations of an independent third party. While ISS uses its best efforts to vote proxies, there are instances when they do not vote proxies because voting is not practical or is not in the best interest of clients. For example, casting a vote on a foreign security may involve additional costs or may prevent, for a period of time, sales of shares that have been voted. Additionally voting may be restricted when a security is a privately held company or a preferred stock where ISS does not have a separate service contract to provide a vote recommendation, or the voting instructions require a vote from either a controlling shareholder or shareholder with personal interest. You may contact your Broker Dealer to request and obtain a copy of our proxy voting policies and procedures, ISS’ standard proxy voting guidelines, and records of how RBC CM voted proxies with respect to securities held in your Program account(s). Consulting Solutions If you designate “Manager” as proxy voting authority for your account(s) in Consulting Solutions, such designation of proxy voting authority is subject to acceptance by the applicable Investment Manager in its sole discretion. Pursuant to this designation, you (i) authorize the selected Investment Manager to receive the proxy-related materials, annual and interim reports, and other issuer-related materials for securities in your account(s), and (ii) delegate to the Investment Manager the proxy voting rights for those securities. If an Investment Manager has elected to not vote client proxies, you (or another third-party agent designated by you) will be responsible for voting proxies for the securities in your Program account(s). RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 27 of 36 26-25-5088800_25213-CS (09/26)  Retirement Accounts With respect to Retirement Accounts subject to Title I of ERISA, we shall have no responsibility or authority to vote proxies on behalf of any such account. The right to direct the voting of proxies is reserved to a named fiduciary of the plan as selected by you. Unless you indicate otherwise in the Advisory Agreement, RBC CM, your Broker Dealer, the Investment Manager(s) selected by you, and/or the Overlay Manager(s) are expressly precluded from voting proxies on behalf of any Retirement Account subject to Title I of ERISA (although we may, in our capacity as a broker, act pursuant to the instructions of a named plan fiduciary). We deem the authority to vote proxies as expressly reserved to a named plan fiduciary and therefore, we have no obligation and will not accept any authority to take action on your behalf with respect to any proxy-related material. ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS We share relevant client information with (1) the Investment Manager(s) and/or Overlay Manager(s) in order for such Investment Manager(s) and/or Overlay Manager(s) to adequately manage your Program account, and (2) certain companies that we or your selected Investment Manager(s) and/or Overlay Manager(s) partner with to service your Program account(s). ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS Your Broker Dealer, through RBC CM, shall serve as the liaison for communications between you and the Investment Managers and/or Overlay Managers. However, unlike the Investment Managers, the Model Providers do not have direct investment advisory relationships with clients and may have their own restrictions on such contact and consultation. Clients are encouraged to review the Form ADV Part 2A brochure(s) or other similar disclosure documents of any Investment Manager(s), the Overlay Manager (Envestnet), and/or Model Provider(s) for information on whether they have any of their own restrictions on direct client communication. ITEM 9: ADDITIONAL INFORMATION Disciplinary Information The following is a summary of certain adverse legal and disciplinary events and regulatory settlements during the last 10 years that may be material to your decision of whether to retain us for your investment advisory needs. You can find additional information regarding these settlements in Part 1 of our Form ADV at adviserinfo.sec.gov. • In June 2025, RBC CM entered into a settlement (the “Settlement”) with the Securities Division of the Office of the Secretary of the Commonwealth of Massachusetts regarding allegations that RBC CM charged unreasonable commission for certain equity transactions, and did not reasonably supervise these transactions in violation of § 204(a) (2)(J) of the Massachusetts Uniform Securities Act. RBC CM agreed to pay restitution in an amount no less than $113,295.06, plus 6% compounded interest, to affected Massachusetts customers. RBC CM also agreed to provide restitution, plus 6% compounded interest, to affected customers of other jurisdictions that agree to the terms of an agreement (“Term Sheet”) between RBC CM and a multi-state group, including Massachusetts, executed contemporaneously with the Settlement. RBC CM agreed to pay an administrative fine in an aggregate amount not to exceed $1,095,000 to the jurisdictions agreeing to the terms of the Term Sheet, which includes $25,000 to be paid to Massachusetts. • On August 14, 2024, RBC CM entered into a settlement order with the SEC in connection with RBC CM’s recordkeeping practices concerning business-related electronic communications sent or received by firm personnel using non-approved channels or methods (“off-channel communications”). The SEC found that from at least June 2019 to August 2024, RBC CM willfully violated Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder in connection with RBC CM’s failure to maintain and preserve the substantial majority of off-channel communications of its personnel that were records required to be maintained under Exchange Act Rule 17a-4(b)(4) and/or Advisers Act Rule 204-2(a)(7); and therefore, failed to reasonably supervise its personnel within the meaning of Section 15(b)(4)(E) of the Exchange Act and Section 203(e)(6) of the Advisers Act. RBC CM admitted to the facts in the settlement order and acknowledged its conduct violated the federal securities laws. The SEC ordered RBC CM to cease and desist from committing or causing any violations and any future violations of Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2 thereunder, censured it for its conduct, ordered it to pay a civil monetary penalty in the amount of $45,000,000, and ordered it to comply with the undertakings enumerated in the settlement order. • RBC CM consented to FINRA sanctions and findings that its supervisory system did not provide certain customers with mutual fund sales charge waivers and fee rebates to which they were entitled through rights of reinstatement offered by mutual fund companies, which resulted in the payment of $264,939.44 in excess sales charges and fees by eligible RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 28 of 36 26-25-5088800_25213-CS (09/26)  customers. On July 2, 2024, RBC CM was censured, fined $75,000 and required to certify that it had remediated the issues and implement reasonably designed supervisory system, including written supervisory procedures (“WSPs”). The firm also made full restitution, plus interest, to the affected customers. • RBC CM consented to FINRA sanctions and findings that it sent trade confirmations to customers that contained inaccurate information. The findings stated that the firm sent its institutional customers confirmations for fixed income transactions, including certain municipal securities transactions, that inaccurately stated that the transactions were executed in an agency capacity, when they were executed in a principal capacity. The firm also sent its institutional customers trade confirmations that inaccurately stated that certain transactions that were solicited were unsolicited and vice versa. In addition, the firm failed to deliver trade confirmations to customers that had requested electronic delivery of trade confirmations and failed to send trade confirmations for millions of dividend reinvestment program (“DRIP”) transactions. The findings also stated that the firm failed to establish, maintain, and enforce a supervisory system, including WSPs, reasonably designed to achieve compliance with trade confirmation requirements. The findings also included that the firm violated Regulation T promulgated by the board of governors of the federal reserve system under Section 7 of the Exchange Act by extending credit to certain customers of the firm and its Broker Dealers, which resulted in hundreds of incorrectly executed trades in those accounts and the frequent selling of the positions at issue to generate proceeds to cover the purchases. In connection with these transactions, customer accounts incurred commissions, markups, markdowns, and fees totaling $392,525.50, that they would not otherwise have incurred had the firm cancelled the trades. In addition, Broker Dealer customer accounts incurred $1,308 in fees in connection with these trades that they would not have incurred had the firm cancelled the trades. On April 29, 2024, RBC CM was censured, fined $375,000, ordered to pay $393,833.50 in restitution to customers, and required to certify that it has remediated the issues and implemented a supervisory system, including WSPs. • On November 2, 2023, RBC CM entered into a settlement with the SEC resulting in the SEC issuing an order (the “Order”). RBC CM consented to the entry of the Order that found that RBC CM failed to make and keep books, records, and accounts, which, in reasonable detail, accurately and fairly reflected the transactions and dispositions of the assets of the issuer and failed to devise and maintain a system of internal account controls sufficient to provide reasonable assurance that transactions are recorded to permit preparation of financial statements in conformity with generally accepted accounting principles. The Order directs that RBC CM cease-and-desist from committing or causing any violations and any future violations of Sections 13(B)(2)(A) and 13(B)(2)(B) of the Exchange Act. On November 2, 2023, without admitting or denying the findings, RBC CM consented to the Order and was fined $6,000,0000. • In May 2023, RBC CM entered into a settlement with the Commonwealth of Virginia’s State Corporation Commission’s Division of Securities and Retail Franchising (the “Division”) regarding allegations that it employed an investment adviser representative in the Commonwealth of Virginia without that person being duly registered with the Division, in violation of § 13.1-504 c (ii) of the Virginia Securities Act. RBC CM agreed to pay a $10,000 monetary penalty and $1,000 for the cost of the investigation. • In April 2023, without admitting or denying the findings, RBC CM reached a settlement with FINRA and consented to sanctions and the entry of findings that it failed to establish and maintain a supervisory system reasonably designed to achieve compliance with its suitability obligations in connection with syndicate preferred stock in brokerage accounts. The findings stated that while the firm’s procedures called for supervisors to closely examine representatives’ short-term trading of preferred stocks, the firm’s electronic surveillance of short-term trading in preferred stock was unreasonably designed, and it failed to monitor for that activity. Although the surveillance system had certain alerts that specifically monitored for short-term trading in other products, such as closed-end funds, it did not have any alerts that specifically monitored for short-term trading in preferred stock. The firm also did not have any other alerts that flagged the purchase and sale within 180 days of syndicate preferred stock. Certain of the firm’s registered representatives recommended that a number of the firm’s retail customers purchase syndicate preferred stocks, and then sold the positions within 180 days, and such customers sustained losses on these transactions. The firm earned $653,313 in selling concessions from these syndicate purchases and $128,643 in sales commissions from the subsequent sales. The firm conducted a substantial syndicate preferred stock business yet did not maintain a reasonable supervisory system to monitor whether its representatives recommended short-term trading of syndicate preferred securities that was unsuitable, including for the purpose of capturing sales concessions and commissions. The firm was censured, fined $300,000, ordered to pay $128,643.17, plus interest, in restitution to customers, ordered to pay $653,312.83, plus interest, in disgorgement, and required to certify that it has remediated the issues identified in this AWC and implemented a supervisory system, including WSPs, reasonably designed to achieve compliance with FINRA Rule 3110 regarding the issues identified in this AWC. • On March 3, 2022, RBC CM affiliate and registered investment adviser, CNR, reached a settlement with the SEC concerning CNR’s breach of its fiduciary duty relating to the use of proprietary Funds and certain share classes in advisory accounts. Those Funds generated fees for CNR and its affiliates, rather than competitor funds within the same asset classes that may not have generated such fees and created a conflict that was not disclosed. The SEC determined that CNR willfully violated sections 206(2) and 206(4) of the Advisers Act as well as Rule 206(4)-7 by failing to adopt and implement written RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 29 of 36 26-25-5088800_25213-CS (09/26)  policies and procedures reasonably designed to prevent violations of the Advisers Act. Under the terms of the settlement, CNR paid $30,361,804 in fines, disgorgement, and interest. • Without admitting or denying the findings, RBC CM consented to the sanctions and to the entry of findings that it failed to establish, maintain, and enforce a supervisory system, including WSPs, reasonably designed to achieve compliance with FINRA and Municipal Securities Rulemaking Board (“MSRB”) rules with respect to representatives’ recommendations of high-yield corporate and municipal bonds. The findings stated that the firm’s policies and procedures did not sufficiently address the suitability factors that representatives should consider before recommending high-yield bonds. On December 15, 2021, RBC CM was censured, fined $550,000, and ordered to pay $456,155, plus interest, in restitution to customers. • On September 17, 2021, RBC CM entered into a settlement with the SEC resulting in the SEC issuing an order (the “Order”). RBC CM consented to the entry of the Order which found that from 2014-2017, RBC CM engaged in improper conduct in connection with the allocation, purchase, and sale of certain new issue municipal bond offerings in violation of internal procedures, as well as MSRB and SEC rules. The Order found that RBC CM’s conduct violated MSRB and SEC rules. The Order censured RBC CM and required RBC CM to pay disgorgement of $552,440, prejudgment interest of $160,886.97, and $150,000 as a civil penalty to the SEC. Such payments were made by RBC CM on September 22, 2021. • The Virginia State Corporation Commission found that, from December 1, 2017, through November 27, 2020, RBC CM employed an investment adviser representative (“IAR”) who was registered in the District of Columbia but not Virginia and that RBC CM failed to enforce its written supervisory procedures regarding IAR registration. On September 8, 2021, RBC CM executed the settlement order which states that RBC CM neither admits nor denies the Virginia state corporation commission’s allegations and paid a $10,000 civil penalty. • It was found by the NYSE that RBC CM violated NYSE Rule 3110(a) and (b) (Supervision) by failing to establish and maintain a supervisory system and WSPs reasonably designed to detect and prevent errors in market on close orders. On July 6, 2021, RBC CM entered into a letter of acceptance, waiver and consent with the NYSE under which RBC CM consented to the sanctions and was censured and fined $10,000. • It was found that RBC CM violated SEC Rule 15c3-5(b) and (c)(1)(ii) and Rules 3.2 and 5.1 of the CBOE BZX Exchange, Inc., CBOE EDGA Exchange, Inc., CBOE BYX Exchange, Inc., and CBOE EDGX Exchange, Inc. due to the fact that the Firm’s financial risk management controls and supervisory procedures were not reasonably designed to (i) prevent the entry of erroneous orders, (ii) reject orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time, or (iii) reject duplicative orders. On March 30, 2021, without admitting or denying the findings, RBC CM was censured and fined $45,000 by CBOE BZX Exchange, Inc., $45,000 by CBOE EDGA Exchange, Inc., $70,000 by CBOE BYX Exchange, Inc. and $45,000 by CBOE EDGX Exchange, Inc. • The Massachusetts Securities Division found that RBC CM failed to adequately supervise its representatives with respect to concentration and suitability of master limited partnership energy and telecom positions in certain client accounts. On February 2, 2021, without admitting to any supervisory deficiencies, RBC CM agreed to the described sanctions and fines totaling $320,267.41. • Without admitting or denying the findings, on December 15, 2020, RBC CM consented to the sanctions and to the entry of findings that it failed to establish and maintain a supervisory system reasonably designed to supervise representatives’ recommendations to customers to purchase particular share classes of 529 college savings plans. The findings stated that RBC CM did not provide adequate guidance to representatives regarding the importance of considering share class differences when recommending 529 plans and had no procedures requiring supervisors to review 529 plan share class recommendations for suitability. RBC CM updated its procedures to include such a requirement, but the updated procedures failed to adequately instruct supervisors to consider either the age of the beneficiary or the number of years until expected withdrawals, both critical factors in determining the suitability of the recommended share class. Also, RBC CM did not consistently provide supervisors with the information necessary to review the suitability of 529 plan share class recommendations. Later, RBC CM issued a company-wide compliance alert that provided guidance to representatives regarding 529 plan share class recommendations. RBC CM then updated its supervisory systems and procedures with respect to 529 share class recommendations. Among other things, RBC CM instructed supervisors to consider the age of the beneficiary when assessing the suitability of a representative’s 529 share class recommendation. RBC CM has agreed to pay restitution and interest relating to the sale of class C shares to certain 529 plan customers in the estimated amount of $839,803. • The SEC found that from at least July 2012 through August 2017, RBC CM disadvantaged certain retirement plan and charitable organization brokerage customers who maintained accounts at RBC CM (“Eligible Customers”) by failing to ascertain that they were eligible for a less expensive share class and recommending and selling them more expensive share classes in certain open-end Funds when less expensive share classes were available. RBC CM did so without disclosing that it would receive greater compensation from the Eligible Customers’ purchases of the more expensive share classes. Eligible Customers did not have sufficient information to understand that RBC CM had a conflict of interest resulting from compensation it received for selling the more expensive share classes. Specifically, RBC CM recommended RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 30 of 36 26-25-5088800_25213-CS (09/26)  and sold these Eligible Customers class A shares with an up-front sales charge, or class B or class C shares with a back- end contingent deferred sales charge (a deferred sales charge the purchaser pays if the purchaser sells the shares during a specified time period following the purchase) and higher ongoing fees and expenses, when these Eligible Customers were eligible to purchase load-waived class A and/or no-load class R shares. RBC CM omitted material information concerning its compensation when it recommended the more expensive share classes. RBC CM also did not disclose that the purchase of the more expensive share classes would negatively impact the overall return on the Eligible Customers’ investments, in light of the different fee structures for the different fund share classes. In making those recommendations of more expensive share classes while omitting material facts, RBC CM violated sections 17(a)(2) and 17(a)(3) of the Securities Act. These provisions prohibit, respectively, in the offer or sale of securities, obtaining money or property by means of an omission to state a material fact necessary to make statements made not misleading, and engaging in a course of business which operates as a fraud or deceit on the purchaser. As a result of the conduct described above, RBC CM willfully violated sections 17(a)(2) and 17(a)(3) of the Securities Act. On April 24, 2020, RBC CM was censured and paid disgorgement of $2,607,676, prejudgment interest of $631,331, plus a civil monetary penalty of $650,000. Without admitting or denying the findings, RBC CM consented to the sanctions and the entry of findings that RBC CM entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of RBC CM. The findings state that RBC CM ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In addition, for the calendar year 2018 RBC CM conducted 11 of 12 monthly origin code reviews late because RBC CM failed to enforce its procedures requiring timely origin code reviews. Between August 28, 2019, and October 2, 2019, RBC CM settled for a total of $100,000 across eight exchanges (NASDAQ PHLX LLC $7,138; NASDAQ Stock Markets/The NASDAQ Options Market $5,687; CBOE BZX Exchange, Inc. $28,271; NASDAQ ISE, LLC Fine $6,721; NYSE American LLC $4,098; NYSE ARCA, Inc. $5,509; CBOE Exchange, Inc.: $36,592; and CBOE C2 Exchange, Inc., $5,984). • FINRA found that from March 2008 to June 2016, RBC CM failed to make the statutorily required delivery of prospectuses to customers who purchased approximately 165,000 ETFs and notes and hundreds of thousands of open-end and closed- end mutual funds. RBC CM failed to design, implement, and enforce a reasonable supervisory system, procedures and set of controls to comply with prospectus delivery rules for Funds and as a result, failed to discover the delivery failures until FINRA’s investigation into the matter. On October 17, 2019, RBC CM was censured and fined in the amount of $2,900,000. • RBC CM self-reported to the SEC the violations described below pursuant to the Division of Enforcement’s Share Class Selection Disclosure Initiative (“SCSD Initiative”). The SEC found that RBC CM, during the period of January 1, 2014, through March 27, 2017, failed to make adequate disclosures, in its Form ADV or otherwise, regarding its Fund share class selection practices, and the 12b-1 fees it received, in connection with advisory account transactions. Specifically, at times during the relevant period, RBC CM purchased, recommended, or held in advisory accounts Fund share classes that charged 12b-1 fees instead of lower cost share classes in the same fund. The SEC found that RBC CM failed to adequately disclose the receipt of the 12b-1 fees and the associated conflict of interest, thereby willfully violating Sections 206(2) and 207 of the Advisers Act. On March 11, 2019, without admitting or denying the findings, the SEC issued, and the firm consented to the entry of an order (the “Order”) that censured RBC CM and directs it to cease-and-desist from committing or causing any violations and any future violations of Sections 206(2) and 207 of the Advisers Act. Additionally, the Order requires Respondent to pay disgorgement of $10,494,813.38, prejudgment interest of $1,220,581.34, and to comply with the other undertakings enumerated in the Order as part of the settlement. Other Financial Industry Activities and Affiliations Broker-Dealer Registrations RBC CM is registered with the SEC as a broker-dealer and investment adviser. Certain of RBC CM’s management personnel and all of its Financial Advisors and their supervisors are registered with FINRA as representatives of RBC CM in its capacity as a broker-dealer. Further, RBC CM is a member of the NYSE, FINRA, SIPC, and several other exchanges and self-regulatory organizations. Futures/Commodities-Related Registrations RBC CM is also registered with the Commodity Futures Trading Commission (“CFTC”) as a futures commission merchant and swap firm. Material Relationships with Related Persons RBC C&C provides clearing and custodial services on a fully disclosed basis to broker-dealers and registered investment advisers, including your Broker Dealer, who are charged fees based on their use of these services. We, in our capacity as a broker-dealer and investment adviser, are routinely engaged in various securities transactions and trading activities for various clients and customers (in addition to you) which could create conflicts of interest among our duties to you and our duties to other clients and customers. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 31 of 36 26-25-5088800_25213-CS (09/26)  In addition to sponsoring the Programs, RBC CM sponsors other non-wrap investment advisory programs available to our clients and engages in a broad range of brokerage and other financial services. These services include public and private investment banking and underwriting, retail and institutional brokerage and trading, institutional research and numerous other brokerage, advisory and financial services. Clients of RBC CM may include Investment Managers and Overlay Managers available in the Programs. We have multiple affiliated entities engaged in many different business activities. The business interests of our affiliates may not align with the interests of our brokerage services. Consequently, our firm may be subject to pressure from our affiliates to protect their business interests. This pressure creates a conflict of interest because it incentivizes us to make certain products and services available to you in a manner which best protects those business interests. Nonpublic Information In the course of our respective investment banking or other activities, we and our affiliates may, from time to time, acquire confidential or material nonpublic information about corporations or other entities or their securities that may prevent us or them, for a period, from purchasing or selling particular securities in your Program account. We and our affiliates will not be permitted to divulge or to act upon any such information with respect to our or our affiliates’ advisory or brokerage activities, including activities with regard to your Program account. RBC GAM – U.S. RBC GAM – U.S. is an affiliate of RBC CM. RBC GAM – U.S. is a federally registered investment adviser that provides portfolio management services to institutional separate accounts, registered investment companies, pooled vehicles, and portfolio management services for wrap fee accounts and Model Portfolios offered by other Providers. RBC CM makes RBC GAM – U.S. available as an Investment Manager in the Consulting Solutions Program and as a Model Provider in RBC UP. In the Cash Sweep Program, you may have a balance in the RBC BlueBay U.S. Government Money Market Fund-Institutional Investor Class 2 (TIMXX) or the RBC BlueBay U.S. Government Money Market Fund-Investor Class (TUIXX), both managed by RBC GAM – U.S. A lower cost share class of the same RBC BlueBay U.S. Government Money Market Fund (TUGXX) is also available outside of the Cash Sweep Program. TUGXX is subject to eligibility requirements for Retirement Accounts. For amounts invested in shares of the RBC GAM – U.S. managed money market fund, our affiliate RBC GAM – U.S. will receive fees for managing and servicing the fund. RBC GAM – U.S. will also pay RBC CM 12b-1 fees, which provides us with another incentive to use this money market fund instead of another fund that does not pay us the same or any revenue share. We address this conflict of interest by proper disclosure. RBC Rochdale RBC Rochdale is a subsidiary of CNB. RBC Rochdale is a federally registered investment adviser that provides investment management services to high-net-worth individuals, families, and foundations. RBC Rochdale may also serve as investment adviser and/or sub-adviser to Funds that RBC CM may recommend. This is a conflict of interest as we are incented to make available Funds subadvised by RBC Rochdale or third-party Funds sub-advised by RBC Rochdale. This conflict of interest is addressed by proper disclosure and by rebating or not charging certain fees to Retirement Accounts in Consulting Solutions and RBC UP. RBC USA Holdco Corporation RBC CM, RBC GAM – U.S. and CNB are wholly-owned subsidiaries of RBC USA Holdco Corporation, which is a wholly owned indirect subsidiary of RBC. RBC Global Asset Management (UK) Limited GAM UK is a wholly owned indirect subsidiary of RBC and an affiliate of RBC CM. GAM UK serves as sub-adviser to certain U.S. registered Funds for which RBC GAM – U.S. or other third parties serve as the investment adviser. Such Funds may be recommended by RBC CM. This is a conflict of interest as we have an incentive to recommend Funds that are sub-advised by our affiliates over other products. To the extent permitted by applicable law, this conflict is addressed by proper disclosure and by not assessing the Program Sponsor Fee or the Overlay Manager Fee component of the Program Fee, when RBC CM acts as Overlay Manager, to the value of these Funds held in Consulting Solutions and RBC UP Retirement Accounts. In addition, RBC CM makes GAM UK available as a Model Provider in RBC UP. Trust and Estate Settlement Services Clients can select CNB, a nationally chartered bank and trust company, or its subsidiary RBC Trust Company (Delaware) Limited (“RBC Trust”), a Delaware chartered trust company, as professional trust and estate settlement service providers. RBC CM and its Financial Advisors are generally prohibited from serving as trustees. Clients can also select TrustCorp America (“TCA”), a Washington, D.C. chartered trust company, as a professional trust and estate settlement service provider. RBC CM has a minority interest in TCA. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 32 of 36 26-25-5088800_25213-CS (09/26)  Cash Sweep Program RBC CM and Affiliated Banks receive financial benefits in connection with Cash Sweep Options managed or held by such Affiliated Banks. See Item 4, “Cash Balances and the Cash Sweep Program” for a description of the Cash Sweep Options and related conflicts of interest. Lending Programs Royal Bank of Canada and RBC Bank receive financial benefits in connection with Lending Programs managed or held by Royal Bank of Canada and RBC Bank. See Item 4, “Securities-Based Lending” for a description of the Lending Programs and related conflicts of interest. Other Material Relationships Marketing and Operational Support Payments RBC CM receive cash payments and/or other financial benefits from certain Funds, ETPs, UITs, Alternative Investments, insurance companies, Investment Managers, Model Providers, and/or Envestnet (“Marketing Support”). Marketing Support is used to offset compliance and product management costs, for training and education programs, due diligence meetings, conferences, and/or to provide our employees with business entertainment, expense reimbursement for travel associated with these meetings and conferences, financial assistance in covering the cost of certain marketing and sales events, and small gifts. RBC CM’s existing or prospective clients also receive related financial benefits, such as seminars, education programs and small gifts. Marketing Support cash payments received by RBC CM vary and may be paid based on a percentage of client assets in certain securities or investment products, and/or based on a flat dollar amount. RBC CM does not receive payments from mutual fund companies based on a percentage of mutual fund assets held in retirement advisory accounts. RBC CM receives payments from certain Fund companies which are used in part to offset certain administrative and operational costs that RBC CM incurs in connection with providing certain sub-accounting and sub-transfer agent services in distributing Funds and provides a financial benefit to RBC CM (“Operational Support”). These costs include sending shareholder statements, maintaining shareholder records, and performing regulatory mailings. RBC CM rebates Operational Support payments received from mutual fund companies to clients with discretionary retirement accounts. Marketing Support and/or Operational Support payments create a conflict of interest because we are incentivized to utilize companies and recommend securities and investment products for which we earn greater compensation over companies, securities, and investment products that do not make such payments. We address this conflict through disclosure and by selecting companies, securities and investment products based on merit, qualitative and quantitative evaluations, performance, and risk management practices and not based on the amount of revenue we receive. In general, Funds and ETPs of companies that make Marketing Support and/or Operational Support payments to RBC CM have higher expense ratios than Funds and ETPs of companies that do not make such payments. The receipt of Marketing Support and/or Operational Support payments from Fund and ETP companies by RBC CM is one of multiple factors that RBC CM considers when deciding which Funds and share classes or ETPs to make available to clients. RBC CM has a conflict of interest in choosing a Fund or an ETP (with higher expense ratios) of companies that make the above-referenced payments to RBC CM for selling/distributing their Funds and/or ETPs. A higher expense ratio will adversely affect investment performance. These conflicts of interest are addressed by appropriate disclosure in this brochure. For a list of Fund families from which RBC CM receives payments described herein, please see “Mutual Fund and ETF Arrangements” at www.rbcclearingandcustody.com/disclosures. Additionally, RBC CM has arrangements with certain donor advised funds for the referral of clients or prospects that have indicated an interest in establishing and maintaining a donor advised fund. Neither RBC CM nor its Financial Advisors receive a referral fee for such arrangement. However, donor advised funds that partner with RBC CM generally invest the referred client assets in Programs that are advised and serviced by the referring Financial Advisor which creates an incentive to refer clients to donor advised funds with which RBC CM has a referral arrangement. We seek to address this conflict of interest through disclosure, and by treating Program assets owned and administered by such donor advised funds and Program assets owned directly by clients as separate and distinct advisory relationships in accordance with all applicable regulatory requirements. Federated Investment Counseling Federated Investment Counseling (including its Federated Hermes CW Henderson division) is an unaffiliated investment adviser registered with the SEC. As of the date of this brochure, Federated Investment Counseling (and one or more of its Investment Strategies and/or Model Portfolios, as applicable) is available for selection as an Investment Manager in Consulting Solutions and as a Model Provider or Investment Manager in RBC UP. In addition, Federated Investment Management Company is the investment adviser for the only unaffiliated money market fund available as a Cash Sweep Option for advisory clients. The Federated Hermes Treasury Obligations Fund (TOAXX) is the Cash Sweep Option RBC CM makes available to Retirement Accounts enrolled in a Program. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 33 of 36 26-25-5088800_25213-CS (09/26)  Cash balances in accounts managed by Federated Investment Counseling as Investment Manager in Consulting Solutions or invested in a Federated Investment Counseling Model Portfolio or Investment Strategy in RBC UP, will be invested in any such client’s selected Cash Sweep Option, which may be the Federated Hermes Treasury Obligations Fund (TOAXX). As discussed in Item 4, clients pay the Program Fee on the total value of the assets in their Program account, including cash balances. As a result, you should be aware that if Federated Investment Counseling is the discretionary Investment Manager for your Consulting Solutions account or RBC UP account Sleeve, or the Model Provider that delivers its Model Portfolio in which your RBC UP account is invested, you will pay Federated Investment Counseling advisory fees on all assets, including cash balances. If the Cash Sweep Option for your Program account is the Federated Hermes Treasury Obligations Fund (TOAXX), you will also pay Federated Hermes applicable money market mutual fund fees and expenses on these same cash balances, as described above in the section titled “Cash Balances and the Cash Sweep Program.” Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics and Personal Trading RBC CM has adopted an Investment Adviser Code of Ethics (the “IA Code of Ethics”) in accordance with Rule 204A-1 of the Advisers Act, which applies to all RBC CM employees, contingent workers, contract workers and interns (“Covered Persons”), with limited exceptions. The IA Code of Ethics sets forth the standards of business conduct applicable to RBC CM and its Covered Persons (i.e., to act with integrity, honesty, and professionalism and to always act in the best interests of our clients) and is designed to ensure that RBC CM and its Covered Persons comply with applicable federal and state securities laws and regulations. The IA Code of Ethics also highlights that as an investment adviser and fiduciary, RBC CM and its Covered Persons have an affirmative duty to always act in the best interest of our advisory clients, which means their interests must always come first. This means that when acting in an investment advisory capacity, Covered Persons are responsible to: (i) put client interests before their own; (ii) act with utmost good faith; (iii) provide full and fair disclosure of all material facts; (iv) not mislead clients; and (v) disclose all potential, perceived, and/or actual conflicts of interest to clients. The IA Code of Ethics also includes guidelines regarding personal securities transactions of, and the maintenance of personal securities accounts by, its Covered Persons (with the exception of interns) in accordance with RBC CM’s policies on outside securities accounts, and employee/employee-related accounts. More specifically, the IA Code of Ethics outlines RBC CM’s requirements contained in such policies, including that Covered Persons and their immediate family members (i) maintain their personal securities accounts and accounts in which they have a beneficial interest at RBC CM, unless RBC CM has given its prior express written permission to open and/or maintain an account outside of RBC CM, (ii) report their personal securities transactions and holdings to RBC CM, and (iii) obtain pre-approval for investments in private placements and initial public offerings, among others. In addition, the IA Code of Ethics also contains information on standards relating to prohibited and illegal activities associated with the possession of material information (e.g., further disclosure, trading), the administration and enforcement of the IA Code of Ethics, and maintenance of certain records relating to the IA Code of Ethics. As part of RBC CM’s annual Compliance questionnaire process, Covered Persons are required to certify to their receipt and review of, and compliance with, the IA Code of Ethics. A copy of the IA Code of Ethics is available to clients or prospective clients upon request. Participation or Interest in Client Transactions As a full-service broker-dealer, on an ongoing basis and as permitted by applicable law, we may, when appropriate: • act as broker or agent, effect securities transactions for compensation for you; • make available to Broker Dealer securities or investment products in which we or a related person or a family member of an employee has some financial interest; • buy or sell for ourselves securities that we also make available to Broker Dealer; or • sell or convert Fund shares or other unbilled assets, which will subject proceeds to the Program Fee. We have adopted internal policies and procedures with respect to conflicts of interest between us and our clients. Pursuant to these policies and procedures, we, when engaging in the activities enumerated above, treat your orders fairly and do not give our own orders preference over your orders. As required by applicable law and/or exchange rules, including, but not limited to, the Advisers Act, we obtain the consent of affected clients in advance of any transactions in which we will be engaging in the activities referenced above. When we engage in the activities mentioned above, all statements and/ or confirmations of such transactions contain the disclosures required by applicable law and exchange rules. Securities activities are monitored daily to detect and prevent employees from trading ahead of client accounts. RBC CM and its affiliates are not obligated to affect any transaction that they believe would violate federal or state law, or the regulations of any regulatory or self-regulatory body. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 34 of 36 26-25-5088800_25213-CS (09/26)  RBC CM or its Affiliate(s) in Underwriting Syndicate; RBC WM Distribution of Securities If RBC CM or its affiliate(s) is a member of the underwriting syndicate from which a security is purchased by an unaffiliated Investment Manager, and allocated to your account, we or our affiliates could directly or indirectly benefit from such purchase. If RBC CM participates in the distribution of new issue securities that are purchased for a client’s account by an unaffiliated Investment Manager, RBC CM will receive a fee to be paid by the issuing corporation to the underwriters of the securities and ultimately to RBC CM, which will be deemed additional compensation to us, if received by us. Agency Cross Transactions Agency cross trades and internal cross trades are generally prohibited for Program accounts. Best Execution It is the duty of the entity with brokerage discretion under a Program to seek the best net price and execution on securities trades for client accounts. If we sell a security to you or buy a security from you, we will use all reasonable efforts to ensure that you obtain the best net price and execution on the purchase or sale based on prevailing inter-dealer market prices. In some circumstances, the change in market price may result in financial benefit to us. We may consider it appropriate to use our own execution services to effect purchases and sales of securities for investment advisory clients. We may receive brokerage commissions in connection with such transactions and, in accordance with Section 11(a) of the Exchange Act, may execute transactions for investment advisory accounts over which we have discretion on the floors of securities exchanges of which we are a member. Mark-ups and mark-downs charged by a dealer unaffiliated with us may be included in the price of certain transactions. Payment for Order Flow, Order Routing and Rebates For options orders, we receive payments in the form of rebates and credits. We receive payments from option market centers in return for routing exchange-listed equity and index options orders to those centers when the rebates and credits we receive from those centers are in excess of the fees that those centers charge us for such orders. Any remuneration that we receive for directing options trades to any market center will not accrue to your account. RBC CM contracts with a third- party vendor, to provide execution metrics that RBC CM uses to evaluate execution quality across various markets and firms. These payments for order flow create a conflict of interest for RBC CM as it incentivizes us to route orders to the market center that pays the most. RBC CM mitigates this conflict by making routing decisions based on the quality of execution and not payment for order flow, and by ensuring payment rates do not differ between market centers and not sharing these payments with the Broker Dealer or those involved with the execution of the order. We also mitigate these conflicts by disclosing them to you and by establishing policies and procedures that limit the value, frequency, and nature of these types of incentives. For information with respect to RBC’s handling of customer orders, see “SEC Order Handling Disclosures” at www.rbcclearingandcustody.com/disclosures. You can request a written copy of this information from your Broker Dealer. Trade Errors From time to time, inadvertent administrative errors may occur in processing transactions, resulting in one or more erroneous securities transactions for a client’s account. If this occurs in an account, the error will be corrected, and the account will be restored to the same economic position had the error never occurred. Through this process, a profit may be realized, or a loss suffered in connection with correcting this error. Neither losses nor gains realized will be passed on to the client. RBC CM will retain amounts remaining after errors are corrected. As a result, trade corrections can result in financial benefit to RBC CM or its affiliated broker dealers. Trade Aggregation and Allocation In addition, the Overlay Managers have discretion to aggregate orders into a block trade and execute at an average price. Depending on the size of these orders and the liquidity of the individual security, the execution of the block may occur over more than one day. Review of Accounts When you open a Program account, your Broker Dealer (and its applicable personnel) are responsible for reviewing your account(s) to confirm that the account type, the Program and the investment strategy approach are suitable and appropriate based on your financial (and other relevant) circumstances, investment objectives, risk tolerance, and any other information you have provided for your account. As a Program client paying a fee to receive investment advice and services, your Broker Dealer is responsible for conducting periodic reviews of your account(s) to ensure consistency with your best interest, Advisory Risk Profile and overall situation. RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 35 of 36 26-25-5088800_25213-CS (09/26)  It is your sole responsibility to ensure that the information you provide for your Program account(s) is, and continues to be, complete and accurate and to notify your Broker Dealer promptly of any changes. This includes, but is not limited to, information regarding your financial circumstances, investment objectives, and risk tolerance. Reports to Program Clients RBC CM will provide you with the following trade confirmations and account statements: • trade confirmations reflecting all transactions effected with or through us (other than cash sweep transactions) unless designated otherwise by you, in accordance with applicable law, rules and regulations; and • Periodic account statements as described in your Customer Account Agreement. In the Advisory Agreement, you will elect whether you wish to receive trade confirmations on a daily or monthly basis for your account(s). RBC Advisor accounts can only receive trade confirmations on a trade-by-trade daily basis. At any time, you may request a copy of the trade confirmation for transactions that appear on the monthly transaction summary statement, as well as any subsequent transaction, or previous transaction effected through RBC CM at no additional cost. If you or RBC CM terminate a Program account, RBC CM will revert the frequency of trade confirmations to daily. Financial Information We are not required to include a balance sheet in this brochure because we do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. We do not have any financial conditions that are reasonably likely to impair our ability to meet our contractual commitments to clients. RBC CM and their predecessors have not been the subject of a bankruptcy petition during the past 10 years RBC Clearing & Custody (Broker Dealer) Advisory Programs Disclosure Document Page 36 of 36 © 2026 RBC Capital Markets, LLC, registered investment adviser and Member NYSE/FINRA/SIPC. All rights reserved. 26-25-5088800_25213-CS (09/26) 

Advisory Programs Disclosure Document (Registered Investment Adviser) Form ADV, Part 2A Appendix 1, Wrap Fee Programs Brochure September 30, 2026 This wrap fee program brochure provides information about the qualifications and business practices of RBC Wealth Management (“RBC WM”), a division of RBC Capital Markets, LLC (“RBC CM”). If you have any questions about the contents of this brochure, please contact us at (800) 759-4029. 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. Additional information about RBC CM and RBC WM is available on the SEC’s website at www.adviserinfo.sec.gov. Registration with the SEC does not imply a certain level of skill or training. RBC Clearing & Custody 250 Nicollet Mall | Minneapolis, MN 55401-1931 (800) 759-4029 | www.rbcclearingandcustody.com PLEASE RETAIN A COPY OF THIS DOCUMENT FOR YOUR RECORDS Investment and insurance products offered through RBC Clearing & Custody are not insured by the FDIC or any other federal government agency, are not deposits or other obligations of, or guaranteed by, a bank or any bank affiliate, and are subject to investment risks, including possible loss of the principal amount invested. © 2026 RBC Clearing & Custody, a division of RBC Capital Markets, LLC, registered investment adviser and Member NYSE/FINRA/SIPC. All rights reserved. 26-25-5088800_25213-AS (09/26) HNW_NRG_B_Inset_NoMask ITEM 2: MATERIAL CHANGES This Form ADV Part 2A wrap fee programs disclosure brochure (the “Brochure“), dated September 30, 2026, contains the following material changes and other updates from the previously amended Brochure dated August 24, 2026. For more details on any specific update, please see the item in this Brochure referred to in the summary below. • In Item 4, the subsection of the RBC Unified Portfolio Program overview titled “Rebalancing of Assets” has been updated to clarify the three rebalancing frequency options (quarterly, annually, or no rebalance), the timing of initial and subsequent account rebalancing, and the circumstances that can result in unscheduled rebalancing of a client’s RBC Unified Portfolio account. • In Item 4, under “RBC Unified Portfolio,” we have updated the subsection formerly titled “Overlay Manager Discretionary Authority” with the new heading “Investment Manager and Overlay Manager Discretionary Authority,” and the addition of language explaining how the services and investment strategies selected determine discretionary authority between the Overlay Manager and the selected Investment Manager(s) for a client’s RBC Unified Portfolio account. • In Item 4, under “RBC Unified Portfolio,” we have updated the disclosures under the subsection titled “Tax Management” relating to clients electing Tax Management services in RBC Unified Portfolio. The updated language clarifies that clients that request the Overlay Manager consider realized gains from assets held outside their RBC UP account when seeking losses to offset gains for the current tax year (“External Gains to Offset”) will need to reset this number every calendar year by contacting their Investment Adviser. • In Item 4, section titled “Eligible Investments; Fund Share Class Selection,” subsection titled “Funds,” we have updated our disclosure as follows: If your Program account includes a share class that is not available in the Program, we may grant an exception for you to continue to hold your existing Fund shares (in the cheaper share class), but you cannot purchase any additional shares of that share class. In such case, you will need to work with your Financial Professional to select an alternate Fund. In RBC Unified Portfolio, if an exception has been granted for you to retain Fund shares that are not available in the Program and such Fund is included in your target investment allocation, your Overlay Manager (RBC CM or Envestnet) may make additional purchases of such Fund in the share class that is available in the Program. • Information Cash Sweep Program conflicts of interest, previously spread throughout the Brochure, is now consolidated in Item 4 section titled “Cash Balances and the Cash Sweep Program,” subsection titled “Cash Sweep Program Conflicts of Interest.” Further, this section has been revised to add clarity. • In Item 6, the disclosures under the section titled “Related Persons as Investment Manager, Model Provider, and/or Overlay Manager, and Associated Conflicts of Interest” have been updated to add clarity around certain Investment Strategies available in both the Consulting Solutions and RBC Unified Portfolio Programs, including the fees clients pay, and we retain, in each of these Programs and the conflicts of interest that arise relating to our Financial Advisors recommending the use of such Investment Strategies in one of these Programs over the other. • In Item 9, under the section titled “Other Financial Industry Activities and Affiliations,” we have enhanced the following language related to nonpublic information under the new subsection title: “Nonpublic Information.” The updated language is as follows: Nonpublic Information In the course of our respective investment banking or other activities, we and our affiliates may, from time to time, acquire confidential or material nonpublic information about corporations or other entities or their securities that may prevent us or them, for a period, from purchasing or selling particular securities in your Program account. We and our affiliates will not be permitted to divulge or to act upon any such information with respect to our or our affiliates’ advisory or brokerage activities, including activities with regard to your Program account. • In Item 9, under the section titled “Participation or Interest in Client Transactions,” we have added the following new subsection which contains the following language: RBC CM or its Affiliate(s) in Underwriting Syndicate; RBC WM Distribution of Securities If RBC CM or its affiliate(s) is a member of the underwriting syndicate from which a security is purchased by an unaffiliated Investment Manager, and allocated to your account, we or our affiliates could directly or indirectly benefit from such purchase. If RBC CM participates in the distribution of new issue securities that are purchased for a client’s account by an unaffiliated Investment Manager, RBC CM will receive a fee to be paid by the issuing corporation to the underwriters of the securities and ultimately to RBC CM, which will be deemed additional compensation to us, if received by us. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 2 of 35 26-25-5088800_25213-AS (09/26)  ITEM 3: TABLE OF CONTENTS ITEM 1: COVER PAGE .............................................................................................................................................................................. 1 ITEM 2: MATERIAL CHANGES ................................................................................................................................................................. 2 ITEM 3: TABLE OF CONTENTS ................................................................................................................................................................ 3 ITEM 4: SERVICES, FEES AND COMPENSATION ................................................................................................................................... 4 Services ............................................................................................................................................................................................................. 5 Advisory Programs ........................................................................................................................................................................................... 6 RBC Unified Portfolio Program ................................................................................................................................................................... 6 Consulting Solutions Program ..................................................................................................................................................................... 8 Other Disclosures Relating to the Programs ................................................................................................................................................. 9 Funding Program Accounts ......................................................................................................................................................................... 9 Withdrawals from Program Accounts .......................................................................................................................................................... 9 Eligible Investments; Fund Share Class Selection ...................................................................................................................................... 9 Cash Balances and the Cash Sweep Program ......................................................................................................................................... 10 Harvesting Gains or Losses ...................................................................................................................................................................... 12 Securities-Based Lending ......................................................................................................................................................................... 13 Fees and Compensation ................................................................................................................................................................................ 14 Fees .......................................................................................................................................................................................................... 14 Calculation of Program Fees; Valuation of Account Assets ...................................................................................................................... 15 Payment of Program Fee .......................................................................................................................................................................... 16 Offset of Certain Fees to Retirement Accounts ......................................................................................................................................... 16 Comparing Costs ............................................................................................................................................................................................ 16 Additional Fees and Expenses ...................................................................................................................................................................... 17 Compensation to Investment Adviser .......................................................................................................................................................... 19 ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ........................................................................................................... 19 ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION ........................................................................................................ 20 Selection of Investment Managers and Model Providers ........................................................................................................................... 20 Monitoring and Review of Investment Managers and Model Providers .................................................................................................... 20 Removal of an Investment Strategy, Model Portfolio, Overlay Manager, or Fund .................................................................................... 21 Related Persons as Investment Manager, Model Provider, and/or Overlay Manager, and Associated Conflicts of Interest ............... 21 RBC CM Acting as Portfolio Manager ........................................................................................................................................................... 22 Performance-Based Fees and Side-by-Side Management ....................................................................................................................... 23 Methods of Analysis, Investment Strategies and Risk of Loss .................................................................................................................. 23 Voting Client Securities (Proxy Voting) ...................................................................................................................................................... 26 ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS .......................................................................................... 27 ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS ................................................................................................................. 27 ITEM 9: ADDITIONAL INFORMATION ..................................................................................................................................................... 27 Disciplinary Information ................................................................................................................................................................................. 27 Other Financial Industry Activities and Affiliations ..................................................................................................................................... 30 Broker-Dealer Registrations ...................................................................................................................................................................... 30 Futures/Commodities-Related Registrations ............................................................................................................................................ 30 Material Relationships with Related Persons ............................................................................................................................................ 30 Other Material Relationships ..................................................................................................................................................................... 32 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................................................................... 33 Code of Ethics and Personal Trading ........................................................................................................................................................ 33 Participation or Interest in Client Transactions .......................................................................................................................................... 33 Review of Accounts ........................................................................................................................................................................................ 34 Financial Information ................................................................................................................................................................................. 35 RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 3 of 35 26-25-5088800_25213-AS (09/26)  ITEM 4: SERVICES, FEES AND COMPENSATION RBC Capital Markets, LLC (“RBC CM”), an indirect, wholly owned subsidiary of the Royal Bank of Canada (“RBC”), is a registered investment adviser and broker-dealer with the U.S. Securities and Exchange Commission (“SEC”) and is a member of the Financial Industry Regulatory Authority (“FINRA”), the New York Stock Exchange (“NYSE”), and other major securities exchanges. RBC CM, through its RBC Wealth Management (“RBC WM”) division, offers clients (“you” or “your”) products and services in its capacity as investment adviser, including portfolio management, and as sponsor of various wrap fee advisory programs. For purposes of this brochure, RBC CM and RBC WM will collectively be referred to as “RBC CM,” the “Firm,” “we,” “us,” or “our.” This brochure provides information about RBC CM and the services it offers through its RBC Clearing and Custody division (“RBC C&C”) to registered investment advisers, and as applicable, their employees (“Investment Advisers” or individually, “Investment Adviser”). Pursuant to an agreement between the Investment Adviser and RBC CM, RBC CM provides clearing and custody services and makes certain advisory programs of RBC WM available to such Investment Advisers for recommendation to their clients, as they deem suitable and appropriate. The RBC CM-sponsored advisory wrap fee programs available to Investment Advisers for recommendation to their clients (each, a “Program,” and collectively, the “Programs”) are RBC Unified Portfolio (“RBC UP”) and Consulting Solutions (“Consulting Solutions”), each described below in Item 4. This brochure describes the Programs as they are intended to be used by Investment Advisers with their clients. It is important to note, however, that RBC CM, including its affiliates, is not responsible for the Investment Adviser’s compliance programs including with respect to the Investment Adviser’s responsibilities and regulatory obligations in the use of the Programs. As such, while RBC CM provides access to the general structure and investment options of the Programs to certain Investment Advisers, all responsibility for client suitability and providing investment advice and recommendations that are in your fiduciary best interest (e.g., recommending an advisory account, a specific Program, an investment strategy, specific investment vehicle, and/or an investment manager, etc.), in accordance with the Investment Advisers Act of 1940, as amended (the “Advisers Act”), lies with your Investment Adviser. RBC CM provides the Program services under a “wrap fee” arrangement. This means that the fee you pay in the Programs covers the investment advisory services of RBC CM as well as certain trade execution, custody, and other brokerage services for a single fee. A description of services and fees that are included in, and excluded from, the wrap fee you pay is included in the Advisory Agreement and described below. In this brochure, the term “Investment Manager” refers to a client’s affiliated or unaffiliated discretionary investment adviser that manages client accounts in accordance with one or more of their investment strategies (each, an “Investment Strategy”) available in the applicable Program. For certain Programs, the Investment Manager may be RBC CM or its affiliates, including (but not limited to) RBC Global Asset Management (U.S.) Inc. (“RBC GAM – U.S.”). In RBC UP, the term “Overlay Manager” refers to either RBC CM or Envestnet Asset Management, Inc. (“Envestnet”) and the term “Model Provider” refers to RBC CM and affiliated or unaffiliated non-discretionary investment advisers that provide their model portfolio(s) (each, a “Model Portfolio”) for implementation in RBC UP. The term “Funds” includes open-end mutual funds, exchange-traded funds (“ETFs”), exchange-traded notes (“ETNs”), and certain interval funds, unless otherwise specified. Interval funds are a type of closed-end mutual fund that does not trade on a secondary market. Rather, the fund only provides periodic offers to repurchase a limited number of shares. As a result, shareholders may not have access to the invested assets for extended periods of time. Refer to the Interval Fund Disclosure for more information. For purposes of this brochure, the term “Retirement Account” will be used to cover (i) “employee benefit plans” (as defined under Section 3(3) of Employee Retirement Income Security Act of 1974, as amended (“ERISA”), which include pension, defined contribution, profit-sharing and welfare plans sponsored by private employers, as well as similar arrangements sponsored by governmental or other public employers which are generally not subject to ERISA; and (ii) individual retirement accounts (each, an “IRA”) as described in the Internal Revenue Code of 1986, as amended (the “Code”). RBC CM does not act as a fiduciary for any Investment Adviser client’s Retirement Account subject to ERISA or the Code, except in its capacity as Overlay Manager, if applicable. The Form ADV Part 2A brochure for each Investment Manager, Model Provider, and the third-party Overlay Manager (Envestnet) available in applicable Programs is also available at the SEC’s website at www.adviserinfo.sec.gov. Assets Under Management As of June 30, 2026, we had $345,747,567,752 in assets under management, $263,708,872,591 of which was managed on a discretionary basis and $82,038,695,161 of which was managed on a non-discretionary basis. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 4 of 35 26-25-5088800_25213-AS (09/26)  Services The Programs are customized advisory programs whereby Program services are provided pursuant to your investment advisory agreement(s) with RBC CM and your Investment Adviser. It is the responsibility of your Investment Adviser to work with you to analyze and define your investment objectives, financial circumstances, risk tolerance to develop and/or select an investment strategy. To open and enroll an account in any of the Programs described herein, clients and their Investment Adviser are required to enter into a written investment advisory agreement with RBC CM known as the Advisory Master Services Agreement (the “Advisory Agreement”). As discussed in Item 5, the Advisory Agreement governs the terms of a client’s current and future Program account(s) and relationships with RBC CM and outlines the services to be provided to the client’s account(s) in a Program. As part of the Program account opening process, Investment Advisers are responsible for working with their clients to determine their risk profile, which is intended to encompass the client’s risk tolerance, investment objective(s), investment time horizon, and financial situation (when referred to collectively, the “Advisory Risk Profile”). Investment Advisers provide Advisory Risk Profiles to RBC CM. It is each client’s responsibility to verify that the information they provide to their Investment Adviser is, and continues to be, complete and accurate, and to notify their Investment Adviser promptly if any of their information and circumstances change. Based on the Advisory Risk Profile and other client information provided to the Investment Adviser during the account opening process, each client will work with their Investment Adviser to select a Program. The Investment Adviser is responsible for providing instructions to RBC CM regarding client enrollment and investment decisions. Except as provided in Item 6 below, RBC CM has no discretionary authority to select a Program, strategy, or services on behalf of clients. Pursuant to the Advisory Agreement, and as further discussed below, clients pay a quarterly, asset-based, wrap fee (the “Program Fee”) for investment advisory, brokerage execution, and other services rendered under a Program, to RBC CM, typically based on the value of their Program account(s) regardless of the number of trades placed. In certain circumstances, a client’s Investment Adviser or RBC CM may require the client to sign additional documentation relating to Program Fee. The services generally covered by the Program Fee include the investment advisory services provided by the Investment Adviser, and Program management services provided by RBC CM (and depending on the Program, investment advisory services provided by the Investment Manager, Model Provider, and/or Overlay Manager), as well as trade execution, clearing, custody, and other administrative and account reporting services provided by RBC CM. Please see the detailed discussion of fees and other costs below under “Fees and Compensation” in Item 4. Reasonable Investment Restrictions Clients can request that certain reasonable investment restrictions be placed on the management of their Program account(s). Reasonable investment restrictions include restrictions on the purchase and/or sale of certain securities or categories of securities related to a financial sector or industry (e.g., fossil fuels, tobacco). Such restrictions are subject to acceptance by the Investment Adviser, RBC CM, and, where applicable, the Investment Manager(s) and/or the Overlay Manager(s) as reasonable, in each of their sole discretion. It should be noted that any reasonable investment restrictions will not apply to the underlying portfolio of any Fund, UIT, the sub-accounts of annuities, or other similar securities that are held or purchased in a Program account. When an account is terminated from a Program, any previously accepted, client- imposed investment restrictions for that account will no longer be in effect. Where reasonable investment restrictions have been accepted, they can be implemented in various ways, including, but not limited to, increasing the relative proportions of other securities in a portfolio to replace the restricted securities and/ or selecting alternate securities. Any investment restrictions clients impose on the management of their Program account(s) can limit the Investment Manager’s and/or the Overlay Manager’s ability to make investments or take advantage of opportunities. Clients are responsible for notifying their Investment Adviser, who will in turn notify RBC CM of any changes to their investment restrictions. RBC CM will then notify the Overlay Manager and/or Investment Manager of any changes to the investment restrictions. Custody RBC CM will act as custodian for the assets and securities held in a Program account(s). RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 5 of 35 26-25-5088800_25213-AS (09/26)  Advisory Programs RBC Unified Portfolio Program The RBC UP Program is a “unified managed account” program in which a single client account can invest in all or some of the following investment products (each, an “Investment Product”), which may or may not be affiliated with RBC CM: eligible Funds, closed-end funds, Model Portfolios managed and provided by Model Providers and/or Investment Strategies managed by Investment Managers. The different Investment Products are held in “sleeves” (each, a “Sleeve”) in a single RBC UP account. Except for Sleeves managed by Investment Managers, Sleeves are managed on a discretionary basis by the Overlay Manager. The Overlay Manager for an RBC UP account will either be RBC CM or Envestnet, a third-party portfolio manager that is not affiliated with RBC CM. In addition to providing discretionary account management, each Overlay Manager provides portfolio implementation, coordination, and other services as specified below. This discretionary authority includes the authority to implement any Model Portfolio(s), Fund(s) and/or closed-end fund(s) selected for your RBC UP account, subject to any reasonable investment restrictions you have requested, and which have been accepted by the Overlay Manager. The Overlay Manager will not have discretionary authority over Sleeves managed by Investment Managers. The Overlay Manager for your RBC UP account will be determined by the specific services you elect to receive in the Program. If you elect tax management services (“Tax Management”) and/or responsible investing screens services (“Screens”), each as further described below, your account will be managed by Envestnet as Overlay Manager. If you do not select Tax Management or Screens, your account will be managed by RBC CM as Overlay Manager. Recommendation of Investment Strategy You will work with your Investment Adviser to determine the investment strategy and target investment allocation for your RBC UP account. The target investment allocation for your RBC UP account will ultimately be comprised of the specific Investment Product(s) that you or your Investment Adviser select from those available in the Program and a target allocation to each such Investment Product. The target investment allocation and Investment Product(s) selected for your account will be provided to the Overlay Manager and/or Investment Manager(s). You can change the target investment allocation and/or Investment Products for your account by notifying your Investment Adviser, who will in turn notify the Overlay Manager and/or Investment Manager(s) of the change. RBC CM will send you written confirmation of such change. As further discussed below under “Eligible Investments; Fund Share Class Selection,” if your target investment allocation includes a Fund share class that is ineligible for the Program, we can update your allocation to the eligible share class of the same Fund without notification to you. If your target investment allocation includes a Fund or closed-end fund that becomes closed to all purchases, or if you do not want to purchase additional shares of a fund included in your target investment allocation, you, or your Financial Advisor if you have granted them discretionary authority, may apply an “alternate fund”. When an alternate fund is applied, no additional shares of the fund will be purchased; however, your Overlay Manager can sell existing shares of the fund. All additional shares will be invested in the alternate fund. Investment Manager and Overlay Manager Discretionary Authority Investment Managers have discretionary authority over the implementation of their respective Investment Strategies. As such, if you select one more Investment Strategies, the Investment Manager(s) will execute trades in your account’s applicable Sleeve in accordance with the Investment Strategy that you have selected, subject to any investment restrictions you have requested, and which have been accepted by RBC CM and the Investment Manager. The Overlay Manager has discretionary authority over Model Portfolios, Funds and closed-end funds. If your account is comprised of one or more Model Portfolios, the Overlay Manager will manage your RBC UP account in accordance with such Model Portfolios, and any updates thereto, as provided and communicated by the respective Model Providers to the Overlay Manager. While implementing the Model Portfolio, the Overlay Manager will take into account any reasonable investment restrictions as discussed above, or client elected services as discussed below. The Model Portfolios, and changes to the Model Portfolios, are typically implemented by the Overlay Manager as soon as practicable after they are received from the Model Provider. Therefore, reasonable delays may occur between the receipt of Model Portfolio revisions, and the resulting execution of securities transactions by the Overlay Manager for client accounts. Depending on the circumstances (including the extent to which Model Portfolios are widely distributed, the timing in which the Overlay Manager receives revisions to the Model Portfolios and acts on them, and the trading activity in the securities contained in the Model Portfolios),transactions in client accounts can be subject to significant market impact prior to execution. For example, the implemented Model Portfolio can receive less favorable execution prices, particularly if the overall trading in the securities is large in relation to the securities’ trading volume. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 6 of 35 26-25-5088800_25213-AS (09/26)  Rebalancing of Assets You will choose from three rebalancing frequencies for your RBC UP account: quarterly, annually, or no rebalance. If quarterly or annually is selected, the Overlay Manager will execute trades and coordinate with any Investment Managers, as needed, to bring your account as close to your target investment allocation as practicable. Your first scheduled rebalance will occur one quarter or one year, as applicable, from the date your account is enrolled in RBC UP. If your rebalancing frequency is changed from no rebalance to quarterly or annually, your account will be rebalanced at the time of the change and the rebalance date will be set to the next quarter or year, as applicable. If you select no rebalance, the account will only be rebalanced upon request. Regardless of your selected rebalance option, your account can be rebalanced at any time when deemed necessary or appropriate by the Overlay Manager to implement the allocation and investments selected or due to other factors that include, but are not limited to, contributions, withdrawals, updates to any Model Portfolio(s) and/or Investment Strategy(s). Any unscheduled rebalance of your account will reset the next rebalance date to the next quarter or a year, as applicable. If you have elected to receive Tax Management (described below), Envestnet will evaluate the trade-off between rebalancing the account and the tax consequences of any client specified limits. If your account is not tax-exempt, the sale, redemption, or exchange of investments may result in taxable gains or losses. We will not be liable for any tax consequences or Fund redemption fees (see the Fund’s prospectus) that result from rebalancing. In general, any contributions or withdrawals of assets to or from your account will be applied to the target investment allocation. Tax Management You can elect Tax Management if you are utilizing an equity or Fund Model Portfolio, or any combination thereof. If you elect Tax Management, Envestnet will develop a tax strategy for your account based on the information and instructions, including any limits you provide to your Investment Adviser and your Investment Adviser forwards to Envestnet. The tax strategy Envestnet develops is provided solely in connection with your account. Neither Envestnet nor RBC CM provide tax advice or tax planning services of any kind; clients are urged to consult with their own personal tax advisors for advice specific to their situation. If you elect Tax Management, please consider the following: • Tax Management is limited in scope and is not designed to eliminate taxes in the account. Envestnet can, in light of other considerations in an account, effect transactions even though they may generate tax liabilities, including short-term taxable income, or exceed any of the limits or mandates identified by the client. Envestnet makes no guarantee that tax liability in the account will be reduced or that any indicated limits or mandates will be met. • The use of limits to restrict the amount of capital gains realized can severely restrict trading in the account and could result in substantial deviations from your target investment allocation. Limits should only be imposed on the account after you have consulted with your own personal tax advisor. The limits specified will be used annually until you instruct your Investment Adviser to instruct Envestnet otherwise. If you elect Tax Management, your account can perform better or worse than similarly invested accounts that did not elect Tax Management. • You may request that Envestnet consider realized gains from assets held outside of your RBC UP account when seeking losses to offset gains for the current tax year (“External Gains to Offset”) by contacting your Registered Investment Adviser. The External Gains to Offset number you provide expires at the end of each calendar year; therefore, you must contact your Investment Adviser to reset this number for each calendar year. • When providing Tax Management, Envestnet avoids net short-term capital gains where possible, but does not limit net long-term capital gains. • If your account is funded with positions that have long-term capital gains and you have not set a long-term capital gain limit, then all long-term tax lots of securities that are not included in your equity Model Portfolio(s) will be sold, which will cause you to incur long-term capital gains. • If Fund Model Portfolios, or Envestnet’s Quantitative Portfolios, are included in your target investment allocation, existing Fund positions held in your account may be able to be retained for tax reasons, regardless of whether they are part of such Fund Model Portfolios, or Envestnet Quantitative Portfolios. The Fund positions that are retained may have a higher cost. However, if you are not invested in Fund Model Portfolios or Envestnet Quantitative Portfolios, any existing Fund positions held in your account that are not included in your target investment allocation will be sold upon Program account opening regardless of tax consequences. • You may cancel Tax Management at any time. Cancelling Tax Management may result in the recognition of significant taxable capital gains or losses. If you cancel Tax Management, but your account maintains or enrolls in Screens, Envestnet will continue to act as Overlay Manager. If you cancel Tax Management, and your account is not enrolled in Screens, RBC CM will become your Overlay Manager. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 7 of 35 26-25-5088800_25213-AS (09/26)  • Significant investment allocations to certain Fund Model Portfolios may result in less effective Tax Management. For example, Envestnet has less flexibility in managing a client’s tax strategy where a client is invested in a Fund Model Portfolio with frequent, tactical changes, thereby making it difficult to evaluate the portfolio’s tracking error. • Accounts that include Investment Products not eligible for Tax Management (e.g., Funds, closed-end funds and/or bond Model Portfolios, Investment Strategies) may still elect Tax Management, but Tax Management will not be applied to those Investment Products. Envestnet performs an automated year-end tax loss harvest review. For accounts with Tax Management that have net realized gains for the year, securities in equity Model Portfolios are reviewed for harvesting. Starting with the largest percentage loss tax lots that are available to sell (i.e., there is no known wash sale or other sale restriction on the tax lot or security), Envestnet will harvest losses until the account’s net realized gains are eliminated, or all available tax lots with losses greater than 10% are harvested. The sales proceeds are invested in other Model Portfolio holdings and/or cash. This review process typically occurs in early December and is intended to harvest losses while minimizing the impact to the integrity of the investment allocation. Envestnet’s ability to harvest losses is dependent on account circumstances and market environment, among other factors. If your account is enrolled in Tax Management, you may not separately request that Envestnet harvest gains or losses in your account. Except when Envestnet’s Quantitative Portfolios are included in your investment allocation, Envestnet will only seek to harvest losses from equity Model Portfolios and Fund Model Portfolios. Envestnet will not seek to harvest losses from Funds, closed-end funds, or bond Model Portfolios. When the equity Model Portfolios in a client’s target investment allocation are solely Envestnet’s Quantitative Portfolios, and they comprise at least 35% of the client’s total target investment allocation, the client can select Envestnet’s “Portfolio Diversification Solution,” an additional Tax Management service. Envestnet’s “Portfolio Diversification Solution” is a Tax Management service designed to transition a client’s current holdings to their target investment allocation over a longer period of time (subject to any maximum imposed by Envestnet) than might otherwise be allowed based on Envestnet’s standard tracking error thresholds. For these purposes, tracking error measures the difference between the performance of Model Portfolios when used in accounts with Tax Management and when used in accounts without Tax Management. With Envestnet’s Portfolio Diversification Solution, there are no limits on the initial tracking error provided that the selected tax budgets will allow full transition to the target investment allocation within the determined time period. Tracking error will be higher at the beginning of the transition and will decline over time as capital gains are realized and the client’s investments become increasingly more in line with the target investment allocation. You should consult your own personal tax advisor before enrolling in Tax Management and providing any tax information to your Investment Adviser and Envestnet. For more information on Tax Management, please refer to Envestnet’s ADV which is available upon request or at the SEC’s website: www.adviserinfo.sec.gov. Responsible Investing Screens Screens are available to you if you are utilizing an equity Model Portfolio. Clients may restrict their accounts from investing in certain securities or industries by selecting Screens for their account(s). Envestnet relies on third-party data research providers for industry and socially responsible classifications of individual securities, and Envestnet and RBC CM make no guarantee as to the accuracy of such third parties’ classification. The third-party data research providers of these classifications apply different definitions and criteria from other similar providers, which can generate different responsible investing ratings that, when applied, could result in the restriction of different securities (i.e., there is no single industry definition or uniformly applied criteria that inform the Screens). If a third-party data research provider changes the classification of an individual security, Envestnet will make reasonable efforts to implement those changes in a timely manner. Envestnet may implement restrictions by, for example, increasing the relative proportions of other securities to replace the restricted securities and/or selecting alternate securities. Many of the Screens have both a “Best in Class” and “Strict” restriction. Best in Class restrictions are designed for investors seeking to achieve alignment between their values and the prudent management of their investments, while Strict restrictions are designed for investors who want to integrate more stringent environmental/social criteria into their investments by minimizing exposure to companies with specific products, services, and/or operations that do not meet the investor’s personal values criteria. Screens will only be applied to equity Model Portfolios and not to other Investment Products held in a Program account. The application of Screens can cause an account to underperform or overperform when compared to other similarly invested accounts that have not elected Screens. Consulting Solutions Program In the Consulting Solutions Program, your Investment Adviser will assist you in selecting one or more Investment Managers and one or more of their Investment Strategies (each, an “Investment Strategy”) from those RBC CM has made available in this Program. Upon consultation with you, your Investment Adviser will provide you with recommendations regarding RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 8 of 35 26-25-5088800_25213-AS (09/26)  Investment Managers and their Investment Strategy or Investment Strategies that they believe are suitable and consistent with your Advisory Risk Profile. The Investment Managers made available to clients through this Program include both RBC CM affiliated and non-affiliated Investment Managers who meet the Firm’s eligibility requirements for participation as detailed below in Item 6: “Portfolio Manager Selection and Evaluation.” In Consulting Solutions, you or your Investment Adviser are responsible for the ultimate selection of the Investment Manager and Investment Strategy. The Investment Manager has discretionary authority over your account and will implement the investment decisions for your account in accordance with the selected Investment Strategy, subject to any investment restrictions you have requested, and which have been accepted by the Investment Manager. In Consulting Solutions, the Advisory Agreement that you sign is between you, your Investment Adviser, and RBC CM; you do not sign a separate agreement with the Investment Manager. Several direct indexing Investment Strategies are available in Consulting Solutions. Investment Managers who offer direct indexing Investment Strategies typically require that accounts enrolled in such Investment Strategies they manage be set to a Highest Cost, First Out (“HIFO”) tax lot accounting method. If you elect to enroll your account and invest in a direct indexing Investment Strategy, RBC CM will change the tax lot accounting method of your account to HIFO upon your written consent before your enrollment in such direct indexing Investment Strategy (if it was not already set to HIFO). If you terminate the Investment Strategy or your Consulting Solutions account, the tax lot accounting method for your account will remain HIFO unless you or your Investment Adviser provides instruction to RBC CM to change the tax lot accounting method for your account. Other Disclosures Relating to the Programs The following disclosures generally apply to all the Programs, unless noted otherwise. Funding Program Accounts You can fund your Program account by depositing cash and/or securities acceptable to RBC CM (subject, for Retirement Accounts, to any limitations imposed under the retirement plan documents, ERISA, or the Code, as applicable). The investment of assets in a Program account will only occur when all operational requirements have been met. Deposits of cash and/or securities into Consulting Solutions or RBC UP accounts will be invested by the Investment Manager or the Overlay Manager, as applicable, as soon as reasonably practicable. The management of a new Program account will begin after RBC CM has accepted the account into a Program and, as applicable, after the Investment Manager or Overlay Manager has accepted the account. At the time of Program enrollment, account acceptance could be delayed or rejected if the account is underfunded, funded with ineligible securities, and/or for other operational reasons. If you fund your Consulting Solutions or RBC UP account with securities, the Investment Manager or Overlay Manager (which may be RBC CM), as applicable, will liquidate the securities on your behalf, or request that your Investment Adviser liquidate the securities on your behalf, and allocate the proceeds in accordance with the Investment Strategy or Investment Products you have selected. Depending on the type of security involved, liquidation may result in redemption charges and/or taxable gains or losses. RBC CM will not be liable for any lost opportunity profits that may result from investing or liquidating deposits. Withdrawals from Program Accounts Withdrawals from a Program account will be taken first from any free credit cash balances and then from cash balances in your Cash Sweep Option. If the liquidation of securities is required to effect a withdrawal, trades will be implemented as soon as practicable, although they may be delayed depending on market volatility, the Program in which your account is enrolled, and/or the types of securities held in your account. Frequent withdrawals from your Program account may affect the performance and the investment objective of your account. Taxable gains and losses may be realized as result of your withdrawal instructions. RBC CM reserves the right to terminate a Program account if a withdrawal or series of withdrawals results in the account assets falling below the Program minimum. Eligible Investments; Fund Share Class Selection Your Investment Adviser and/or RBC CM may restrict the purchase or holding of certain investments in Program accounts. If a Program account is funded with investments deemed to be ineligible, the Investment Manager and/or Overlay Manager, as applicable, will generally liquidate such investments, or in the case of Funds, RBC CM will convert such investments to an eligible share class of the same Fund without notice to you. Alternatively, you may instruct your Investment Adviser to move such investments to an eligible account. Your account may incur certain transaction charges as a result. Funds In identifying and selecting Funds eligible in the Programs, we may use many sources of information and analysis about Funds, including data provided by third parties. We determine which Fund share classes are available in the Programs RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 9 of 35 26-25-5088800_25213-AS (09/26)  based on a number of factors, including, but not limited to, availability, eligibility requirements, and payment of Operational Support and/or Marketing Support to us (as described below in the “Fund Fees and Expenses” section). We do not always make the lowest cost share class available to you. Lower cost share classes may be available to you elsewhere, including, but not limited to, through other broker-dealers or registered investment advisers to which RBC CM provides clearing, custody, and execution services. Where RBC CM offers a lower cost share class than the designated eligible share class for the Programs, in certain circumstances, RBC CM may grant exceptions for clients to hold their existing share class and for institutional clients to purchase the lower cost share class option. In accordance with applicable regulations, we will make a Fund’s current prospectus accessible to you when you purchase shares of the Fund through us. Fund companies can offer various share classes of a Mutual Fund which allows investors to access the same strategy or portfolio of assets through different types of shares within the same Mutual Fund, each with a unique fee structure, investment requirement, and suitability for different investors. Some share classes may be cheaper than the share classes available in the Program. If your Program account includes a share class that is not available in the Program, we may grant an exception for you to continue to hold your existing Fund shares (in the cheaper share class), but you cannot purchase any additional shares of that share class. In such case, you will need to work with your Investment Adviser to select an alternate Fund. In RBC Unified Portfolio, if an exception has been granted for you to retain Fund shares that are not available in the Program and such Fund is included in your target investment allocation, your Overlay Manager (RBC CM or Envestnet) may make additional purchases of such Fund in the share class that is available in the Program. If your account is not tax-exempt, the redemption or exchange of Fund shares can result in taxable gains or losses. RBC CM does not provide tax, legal or accounting advice and, therefore, you should consult your own personal tax, legal or accounting advisors for such advice. We are not liable for any tax consequences or redemption fees that can result from rebalancing. Compensation differences between product types may create a conflict of interest for RBC CM and Investment Advisers as there may be an incentive to make products available that pay higher compensation. For a discussion of fees and certain conflicts of interest associated with Fund share class selection, please see the section below titled, “Fund Fees and Expenses.” Please see the section above titled “Eligible Investments; Fund Share Class Selection” for more information. Cash Balances and the Cash Sweep Program Events such as deposits, the sale of securities, and/or other similar activity can generate uninvested cash balances in your account. Pursuant to your brokerage account agreement with RBC CM (the “Client Account Agreement”), you have the option to have uninvested cash balances in your account(s) automatically deposited, on a daily basis, into an interest- bearing deposit account, a specified money market mutual fund, or a non-sweep cash investment alternative (each, a “Cash Sweep Option,” and collectively, the “Cash Sweep Options”). Upon notice to you, RBC CM may add, remove, or change the Cash Sweep Options available to you through the Cash Sweep Program (hereinafter, the “Cash Sweep Program”). As discussed below, the different available Cash Sweep Options are subject to eligibility requirements and restrictions. You should review your Client Account Agreement and related Cash Sweep disclosures for details regarding the Cash Sweep Options. For additional information and disclosures on the Cash Sweep Options discussed here, refer to the links under “Cash Management” on our public website at www.rbcclearingandcustody.com/disclosures. The Cash Sweep Options available to you will depend, in part, on the type of account you have opened. You should consider the investment objectives, risks, charges, and expenses of the Cash Sweep Option(s) available to you before selecting that option. Please read any related disclosures, including prospectuses (as applicable), carefully before investing to make sure the Cash Sweep Option is appropriate for your goals and risk tolerance. Non-Retirement Accounts Cash held in non-retirement accounts will be swept into the Cash Sweep Option you choose. The available Cash Sweep Options for non-retirement accounts are: • RBC Insured Deposits. RBC Insured Deposits is a Cash Sweep Option that automatically deposits, or “sweeps,” available cash balances in your Program account into interest-bearing deposit accounts (“Deposit Accounts”) established for you at participating depository institutions (“Program Banks”), whose deposits are insured by the FDIC up to applicable limits, subject to bank capacity (“Deposit Limit”). The Program Banks include unaffiliated, third-party banks and two affiliated banks, RBC Bank (Georgia), N.A. (“RBC Bank”) and City National Bank (“CNB”) (together, “RBC Affiliate Banks” or “Affiliate Banks”). Funds in RBC Insured Deposits are not subject to market risk and potential value loss, but they are subject to the risk of a Program Bank’s failure. RBC CM is not an FDIC-insured depository institution. FDIC insurance available in RBC Insured Deposits is subject to certain conditions and FDIC insurance only protects against the failure of a bank. A list of Program Banks is available at www.rbcclearingandcustody.com/rbc-insured-deposits-program-banks. The RBC Insured Deposits terms and conditions are available at www.rbcclearingandcustody.com/rbc-insured-deposits. More information regarding FDIC insurance is available at http://www.fdic.gov. In the event a Program Bank fails, deposits at each Program Bank are eligible for FDIC coverage up to applicable limits. However, deposits at each Program Bank are not protected by the Securities Investor Protection Corporation (“SIPC”) RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 10 of 35 26-25-5088800_25213-AS (09/26)  or any excess coverage purchased by RBC CM. Cash balances in RBC Insured Deposits in excess of applicable limits (“Excess Funds”) are swept into one or more other banks (“Excess Banks”), which will accept funds without limitation and without regard to the FDIC limit, which may be RBC Affiliate Banks. Currently, the primary Excess Bank is CNB. • GAM Money Market Fund. A money market fund managed by our affiliate, RBC GAM – U.S., (“GAM Money Market Fund”) subject to eligibility and applicable minimum amounts. • Credit Interest Program. The Credit Interest Program (“CIP”) is a non-sweep cash alternative and represents our direct obligation to repay the invested amount, on demand, plus interest. We invest and use CIP assets as free credit balances for our benefit, and we periodically adjust the interest rate payable on CIP accounts. We use these funds in the ordinary course of our brokerage business, subject to the requirements of Rule 15c3-3 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”). The difference between amounts earned by us from our investments and the rate we pay to CIP account holders is our profit. Cash invested in the CIP is protected by SIPC up to $250,000 per account on claims for cash. SIPC protects against the custodial risk (and not a decline in market value) when a brokerage firm fails by replacing missing cash up to the $250,000 limit. Retirement Accounts Cash balances held in Retirement Accounts will be swept into an unaffiliated money market fund, the Federated Hermes Treasury Obligations Fund (the “Federated Money Market Fund”) You may access the most recent Federated Money Market Fund prospectus by contacting your Investment Adviser or by accessing Federated Investment Management Company’s website at www.federatedinvestors.com/products/mutual-funds/treasury-obligations/as.do. Money Market Funds in the Cash Sweep Program As described above, the money market funds offered in the Cash Sweep Program are the GAM Money Market Fund and the Federated Money Market Fund. Money market funds will usually pay a higher rate of interest on cash balances than RBC Insured Deposits or the Credit Interest Program. Other financial institutions may offer cash sweep options that pay you a higher rate of interest than is available in our Cash Sweep Program. You can also receive higher rates on cash balances outside of the Cash Sweep Program by investing directly in money market funds or other cash alternatives; however, such investments must be directed by you and will not be invested automatically. For more information about the Cash Sweep Options available to you, please refer to your Client Account Agreement, which can be found at www.rbcclearingandcustody. com/disclosures and/or the prospectuses of the Federated Money Market Fund and/or GAM Money Market Fund. Interest Rates In RBC Insured Deposits, interest rates are tiered based on the total RBC Insured Deposits balance in your account. Balances are reviewed daily to determine the appropriate interest rate tier for each account. Current RBC Insured Deposits interest rates are set forth on our public website under “Program Interest Rates” at www.rbcclearingandcustody.com/rbc-insured- deposits. Interest rates are variable and subject to change without notice. Cash Sweep Program Conflicts of Interest RBC CM has a conflict of interest in offering the Cash Sweep Options because RBC CM and/or our affiliates receive compensation or benefits from cash balances swept to these Cash Sweep Options in addition to the Program Fee assessed on Program accounts. This conflict of interest is greater when higher cash balances are maintained in your account. This creates an incentive for RBC CM to offer and encourage deposits in these specific Cash Sweep Options. At times, however, your Financial Advisor and/or the Investment Manager(s) or Model Provider(s) may believe that it is in your best interest to maintain assets in cash, particularly for defensive purposes in volatile markets. We address these conflicts of interest through proper disclosure and by also offering in RBC Insured Deposits the ability to opt-out of having your deposits maintained at Affiliate Banks. • The Program Fee. We charge the Program Fee on cash balances in your Program account(s) and we and/or our affiliates receive benefits from amounts invested in the Cash Sweep Options. This means that we and/or our affiliates earn two levels of fees on the same cash balances in your account. • RBC Affiliate Banks. RBC Affiliate Banks pay RBC CM an annual per- account fee for each account enrolled in RBC Insured Deposits. RBC CM receives such fees in addition to the Program Fee you pay to RBC CM. This creates a conflict of interest for us because we have an incentive to maintain and direct your uninvested cash into Deposit Accounts at our Affiliate Banks where they use such deposits to generate additional revenue for themselves. Our Affiliate Banks make a profit on the difference, or “spread,” between the interest they pay and other costs they incur on deposits, and the interest or other income they earn using the deposits for loans, investments, and the purchase of other assets. Our Affiliate Banks can change the interest rate they pay on deposits at any time, and we can increase the amount of the fee we retain, both of which can change the amount of interest you receive on cash balances. Because the amount of interest paid to clients in RBC Insured Deposits is deducted from the revenue our Affiliate Banks earn on these deposits, RBC CM has a conflict of interest in that the less interest paid to you, the more revenue our Affiliate RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 11 of 35 26-25-5088800_25213-AS (09/26)  Banks earn on those assets. Further, RBC CM receives internal accounting credits that help us meet our internal profitability goals as reported to our mutual parent company, which positively affects the amount of bonus paid to senior executives. For RBC Insured Deposits cash balances placed with our Affiliate Banks, including amounts that exceed total FDIC program coverage and are placed at CNB in its capacity as the primary Excess Bank, our Affiliate Banks will receive a stable source of deposits at a cost that is less than other funding sources available. By being designated as the Primary Excess Bank in RBC Insured Deposits, CNB will receive substantial additional deposits to use in its business to increase its profitability. We address these conflicts of interest through proper disclosure and by offering clients the ability to opt-out of having their Deposit Accounts maintained at Affiliate Banks. • Third-Party Program Banks. Third-party Program Banks holding deposits through RBC Insured Deposits pay RBC CM a fee based on a percentage of the average daily balance of assets placed with them. RBC CM pays you interest out of the amount we receive from the third-party Program Banks. The amount of fees retained by RBC CM will affect the interest rate you earn on your deposits The fee retained by RBC CM is larger than the amount of interest you receive. The Program Banks can change the interest rate they pay on deposits, and we can increase the amount of the fee we retain, both of which can change the amount of interest you receive on your deposits. Therefore, RBC CM has a conflict of interest in that the less interest you receive on your deposits, the more in fees we retain on those cash balances. • Credit Interest Program. For CIP, we invest and use cash balances as free credit balances for our benefit. We use the free credit balances in the ordinary course of our brokerage business, subject to the requirements of Rule 15c3-3 under the Exchange Act. Under these arrangements, we invest CIP cash balances and generally earn interest or a return based on short-term market interest rates prevailing at the time. We periodically adjust the interest rate we pay you on CIP cash balances, and the spread between the interest earned by us from our investments and the interest rate we pay you on CIP cash balances will be favorable to us. We address these conflicts of interest through proper disclosure and by making the CIP unavailable to Retirement Account clients. • Money Market Funds. For amounts invested in the Federated Money Market Fund, the fund pays RBC CM service fees in the form of a recordkeeping fee and a shareholder servicing fee. This provides us with an incentive to use money market funds that pay us such fees instead of other funds that do not. These money market funds typically pay you a lower yield than money market funds that do not pay us recordkeeping or shareholder servicing fees. We address this conflict of interest by proper disclosure. For amounts invested in shares of GAM Money Market Fund, RBC GAM – U.S. is an affiliate of RBC CM and RBC GAM – U.S. receives fees for managing and servicing the fund. RBC GAM – U.S. also pay RBC CM 12b-1 fees, which provides us with another incentive to use this money market fund instead of another fund that does not pay us the same or any revenue share. • Recurring Distributions. In non-retirement accounts, you may also elect to automatically distribute accrued dividends, interest, capital gains, and return on capital payments from your account on a recurring basis. RBC CM invests and uses such cash balances as free credit from the date of deposit until the funds are distributed from your account, which is a benefit to us. You do not earn interest on free credit cash balances. Additional information regarding RBC CM’s use of free credit cash balances can be found in the Credit Interest Program section of the Client Account Agreement between you and RBC CM. • Differential Interest Rates by Business Channel. You may receive a different interest rate in RBC Insured Deposits from clients who enroll through a different business channel. This creates a conflict of interest because clients receive a lower interest rate on their RBC Insured Deposits cash balances in business channels where RBC CM retains a higher fee on such cash balances. Please see the Cash Management section of our public website at www.rbcclearingandcustody.com/disclosures for more information regarding RBC CM’s Cash Sweep Program. Harvesting Gains or Losses Except for RBC UP accounts enrolled in Tax Management provided by Envestnet, you can request that the Overlay Manager or Investment Manager harvest gains or losses in your RBC UP or Consulting Solutions account. Such requests are subject to acceptance by the Overlay Manager or Investment Manager. To request harvesting of gains or losses for your account in either of these Programs, you can notify your Investment Adviser, who will in turn notify the Overlay Manager or Investment Manager. You must make such request each time, and for each account, that you desire gain or loss harvesting. Through the notification of your direction to the Overlay Manager or Investment Manager for your account, you are providing independent instructions to said Overlay Manager or Investment Manager to sell and to then either reinvest the loss sale proceeds in one or more replacement securities or retain the proceeds in cash. Gain sale proceeds will be reinvested in the account in accordance with the applicable asset allocation, as determined by the Overlay Manager or Investment Manager. You can typically request gain or loss harvesting (i) for specified securities, (ii) for specified tax lots, (iii) in a specified total amount, or (iv) in the maximum amount available, subject to each Investment Manager’s and Overlay Manager’s own policies and/or ability and willingness to accommodate such requests. It is important to note that the Investment RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 12 of 35 26-25-5088800_25213-AS (09/26)  Manager or the Overlay Manager may reject your request for tax harvesting in whole or in part, at its discretion. In addition, tax harvesting services may not be available for certain Investment Strategies, and the availability of tax-harvesting functionality may be limited due to technology-related and other factors. Please be aware that gain or loss harvesting is an intricate, nuanced strategy that may not be appropriate in all situations and may adversely impact investment performance. Neither RBC CM (including its affiliates) nor the Investment Managers or Overlay Managers provide any tax advice or make any guarantee that tax harvesting will be successful or produce any specific outcome. As such, you should consult your own independent tax, accounting and/or legal professionals before requesting gain or loss harvesting. In addition, when harvesting gains or losses, please keep the following in mind: • If a replacement security increases in value during any applicable wash sale period, such increase can result in a short- term capital gain to you when sold upon expiration of the applicable wash sale period. • There is no guarantee that harvesting requests received late in a calendar year will be completed before year-end. • There is no guarantee that harvesting will achieve any particular result. Tax management or “harvesting” is not tax advice and may not achieve the intended results. • If utilizing harvesting, your account holdings and performance can differ from other similarly invested accounts that do not utilize harvesting. • Harvesting requests only apply to the specific account for which the request is made. If you buy or sell securities in an account that overlaps with the securities sold in another account and such sale generates a loss, this loss may be disallowed under the IRS wash sale rules. • Withdrawing sale proceeds generated from harvesting will likely result in the rebalance of your account and the realization of additional capital gains or losses. Securities-Based Lending Clients have the opportunity to borrow money through lending programs, including RBC Express Credit (“Margin”) offered by RBC CM and RBC Credit Access Line (“CAL”) offered by Royal Bank of Canada and RBC Bank, bank affiliates of RBC CM, collectively referred to as “Lending Programs,” subject to eligibility requirements. In these Lending Programs, the client’s loan is secured by investments and other assets in their account(s) at RBC CM, including those held in Program accounts. Retirement Accounts, including those subject to Title I of ERISA and IRAs, are not eligible for participation in the Lending Programs. To participate in a Lending Program, you agree to maintain securities and/or other assets (“Collateral”) in your account that have a value at least equal to the amount required by its terms (“Maintenance Requirement”). Various factors may be considered in determining your Maintenance Requirement(s), including the value, liquidity, and concentration of the Collateral. Not all securities are eligible to be used as Collateral. If the Collateral declines in value, certain actions may be taken to maintain the Maintenance Requirement, including selling securities or other assets in your account. Due to market volatility, debt you incur can exceed the value of the Collateral you deposit in your account. You will be required to deposit additional cash or securities, or pay down your loan, should the value of your Collateral decline below the percentage equity you must maintain for your Maintenance Requirement, or should the percentage equity you must maintain for your Maintenance Requirement increase. Through the Lending Programs, RBC CM receives interest on loans RBC CM extends on Margin or through CAL. RBC CM is permitted to lend or utilize securities on Margin and may receive compensation in connection with the use of such securities. This compensation creates a conflict of interest because it incentivizes RBC CM to make these Lending Programs available to you. Additionally, Investment Adviser clients with balances in a Lending Program may be charged a different interest rate from clients who have balances in the same program through a different business channel. This creates a conflict of interest because RBC CM retains a higher percentage of the revenue received on loans in business channels that charge clients a higher interest rate. RBC Express Credit (Margin) In this Lending Program, we charge you interest on credit extended to you for the purpose of purchasing, carrying, or trading in securities or commodities or otherwise using eligible securities in your accounts held with us as Collateral. Margin interest rates are determined using a base lending rate plus a sliding scale of percentages according to the size of your Margin debit balance. RBC CM receives a portion of the interest earned by RBC CM. The use of Margin in your Program account will impact the Program Fee you pay as further discussed in the section titled, “Calculation of Program Fees” in Item 4 below. RBC Credit Access Line (CAL) In this Lending Program, you have access to a securities-based line of credit through Royal Bank of Canada and RBC Bank. Interest rates can vary depending on factors such as your creditworthiness and the amount of credit for which you are eligible, as determined by Royal Bank of Canada and RBC Bank. Interest you pay on your CAL is paid to Royal Bank of Canada RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 13 of 35 26-25-5088800_25213-AS (09/26)  and/or RBC Bank. RBC CM receives a portion of the interest and transactions fees earned by Royal Bank of Canada and/or RBC Bank on your CAL. For more information about these Lending Programs, please refer to “Risks Related to Securities-Based Lending” in Item 6 below and the “RBC Credit Access Line,” “RBC Express Credit”, and “Schedule of Fee” disclosures available at www.rbcclearingandcustody.com/disclosures. Fees and Compensation Fees In the Programs, you will pay the “Program Fee,” which is comprised of the Investment Adviser Fee, the Program Sponsor Fee, and for certain Programs, the Investment Manager Fee, the Model Provider Fee, and/or the Overlay Manager Fee (each as defined and described below). Each of these is expressed as a percentage rate. The Program Fee will not exceed 3.0%. • Investment Adviser Fee. In all Programs, you pay an “Investment Adviser Fee” to your Investment Adviser for the services they provide in the Programs. The Investment Adviser Fee rate is determined between you and your Investment Adviser. • Program Sponsor Fee. In all Programs, you pay a “Program Sponsor Fee” to RBC CM which covers the services RBC CM provides as sponsor of the Programs, as well as services related to the custody of account assets, trade execution, clearing and settlement, account reporting and other administrative services. The Program Sponsor Fee typically ranges from 0.00% to 0.40% of Program account assets under management. • Investment Manager Fee. In the Consulting Solutions Program, and the RBC UP Program when utilizing Investment Strategies managed by any Investment Manager(s), you will pay a fee for the investment management services of any Investment Manager (the “Investment Manager Fee”). • Overlay Manager Fee. In the RBC UP Program, you will pay a fee for the services of the Overlay Manager (the “Overlay Manager Fee”). • Model Provider Fee. In the RBC UP Program, as applicable, you will pay a fee for the Model Portfolio(s) provided by any Model Provider(s) (the “Model Provider Fee”). You will receive written confirmation of the Program Fee for your account upon enrollment in a Program, and each time you and your Investment Adviser agree to any changes. In certain circumstances, RBC CM and/or your Investment Adviser may require you to sign additional documentation relating to the Program Fee (or a component thereof) for your account(s). On the written confirmations you receive from RBC CM, the term “Management Fee” will include, as applicable, the Overlay Manager Fee, the Model Provider Fee, and/or the Investment Manager Fee. Information and ranges for Investment Manager Fees, Model Provider Fees, and Overlay Manager Fees are included below. These fee rates may increase or decrease from time to time which will impact the relevant fee components of your total Program Fee. If the Investment Manager, Model Provider, or Overlay Manager for your account changes, the relevant components of your total Program Fee may increase or decrease based on the selected Investment Manager, Model Provider, or Overlay Manager. In such case, we will notify you in writing of any change to your Program Fee. Program Fee Components and Ranges by Program The Program Fee is established at the account level. The Program Fee components depend on the Program in which your account is enrolled, and therefore, the Program Fee can vary between Program accounts, as follows: • Consulting Solutions. The Program Fee consists of the Investment Adviser Fee, Program Sponsor Fee, and the Investment Manager Fee. Investment Manager Fees you pay range from an annual rate of 0.00% to 0.50% of Program account assets under management and vary by Investment Manager and Investment Strategy. We pay a portion of the Investment Manager Fee to each Investment Manager, which typically ranges from 0.00% to 0.50% of Program account assets. Such amount is determined by the specific Investment Strategies of each Investment Manager currently available in the Program, the services provided by each Investment Manager, the total assets managed by each Investment Manager, and fee negotiations with the Investment Manager, as set forth in an agreement between RBC CM and each such Investment Manager. In some cases, fees we pay to Investment Managers may be lower than the amount of the Investment Manager Fee you pay us. Additionally, we negotiate fee schedules with some Investment Managers, which reduce the effective fee rate we pay to Investment Managers as the total amount of Program assets managed by those Investment Managers increases. Any difference in Investment Manager Fees charged to clients and the percentage of such fees we ultimately pay to the Investment Managers are retained by us. Fees retained by us are not passed on to the Investment Adviser. The fees we pay Investment Managers may change from time to time and such change may impact the total Program Fee we charge you. That is, if we negotiate a lower Investment Manager Fee for the Investment Strategy of an Investment Manager in which your Program account is invested, we may similarly decrease RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 14 of 35 26-25-5088800_25213-AS (09/26)  the Investment Manager Fee you pay us as part of the Program Fee. If we renegotiate an existing Investment Manager’s current fee rate, we will notify affected clients of any increase to the Investment Manager Fee. • RBC UP. The Program Fee consists of the Investment Adviser Fee, the Program Sponsor Fee, the Overlay Manager Fee and, as applicable, the Model Provider Fee and/or the Investment Manager Fee. When RBC CM acts as Overlay Manager, the Overlay Manager Fee is 0.05% and is in addition to the Program Sponsor Fee paid to us. When Envestnet acts as Overlay Manager, the Overlay Manager Fee is 0.10% and includes Envestnet’s Tax Management and/or Screens services, if selected. As noted above in Item 4, the Overlay Manager Fee will be assessed on all assets in the account, regardless of whether Tax Management and/or Screens are applied to all or some of those assets. When Envestnet is the Overlay Manager, we pay a portion of the Overlay Manager Fee to Envestnet that ranges from an annual rate of 0.00%-0.08% of account assets under management. We retain any difference between the Overlay Manager Fee of 0.10% that you pay and the portion of such fee we ultimately pay to Envestnet. The Model Provider Fee component of the Program Fee varies by Model Provider, Model Portfolio and type of account (i.e., Retirement Accounts investing in affiliated Model Portfolios), and ranges from 0.00% to 0.65% annually of the market value of an account’s assets allocated to a Model Portfolio, as set forth in an agreement between RBC CM and each Model Provider. If more than one Model Portfolio and/or Investment Strategy is included in your RBC UP account, RBC CM employs a Sleeve-level billing methodology to calculate the amount of each Model Provider Fee and/or Investment Manager Fee. The amount will be determined by calculating the value invested in each Model Portfolio and/or Investment Strategy, or Sleeve, multiplied by the applicable Model Provider Fee for each Model Portfolio and/or Investment Manager Fee for each Investment Strategy in your RBC UP account at the time of each billing event. We pay each Model Provider and Investment Manager a portion of the Model Provider Fee or Investment Manager Fee you pay us. Any difference in the Overlay Manager Fee, Model Provider Fee and/or Investment Manager Fee paid by clients and the percentage of such fees that we ultimately pay to the Overlay Manager, Model Provider and/or Investment Manager are retained by us. Your Program Fee may be higher or lower than (i) the fees and commissions you would pay in a brokerage account; (ii) the fees of other clients depending on considerations such as the size of your account, the types of securities, services provided, and other relevant criteria; and (iii) the cost of similar services offered through other Investment Advisers or financial institutions. Calculation of Program Fees; Valuation of Account Assets Typically, the Program Fee is charged quarterly, in advance, based on the market value of the assets in a Program account, including securities, cash, money market funds, Cash Sweep Program balances, and/or Credit Interest Program balances as of the last business day of the preceding calendar quarter. We include the full market value of assets purchased on Margin in the calculation of your Program Fee and do not reduce the market value of your account by your Margin debit balance. Because the Program Fee is assessed on the market value of assets in your account at the end of a quarter, the total amount of the Program Fee billed each quarter will generally change as Program assets increase or decrease in the Program account. Exchange-traded securities will be valued at the last trade price, or if unavailable, the last known bid price as provided by a third-party vendor. Over-the-counter and illiquid securities will be valued using the broadest and most representative market available. Securities for which market quotations are not readily available will be valued at the known current bid price. If updated pricing is not available from the third-party vendor within 45 days or RBC CM determines the price received from the third-party vendor does not reasonably reflect the last trade price, last known bid price or current market value, as applicable, the price of the security will be removed from the system. All other securities are valued by an independent third- party retained by us or, if unavailable, by a valuation statement provided by the issuer, which will remain unchanged for one year from the date on the valuation statement or until an updated statement is received. Securities where the price cannot be determined will be excluded from the Program Fee charged by RBC CM. Funds To compute the value of assets held in a Program account, we value Fund shares at their respective net asset values as reported on the valuation date by each Fund. Dividends In non-retirement accounts, if you have elected to automatically distribute accrued dividends, interest, capital gains, and return on capital payments from your account on a recurring basis, the proceeds of these payments will not be assessed a Program Fee from the date these payments are made to the date of distribution. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 15 of 35 26-25-5088800_25213-AS (09/26)  Deposits, Withdrawals and Changes Program Fees are prorated for any billing period that is less than a complete quarter. Deposits to or withdrawals from a Program account of cash and/or securities with a value equal to or greater than $10,000 will be billed on a pro-rated basis. Deposits and withdrawals on the same day will offset each other, and the net amount will be used to calculate on a daily basis an additional Program Fee or refund to your account. In each case, the additional Program Fee or refund will be calculated based on the applicable fee rate times the amount of the increase or decrease, pro-rated based on the number of days from the date of the triggering event to the last day of the calendar quarter. If there is any change in your Overlay Manager, Model Provider, Model Portfolio, Investment Manager, Investment Strategy or investment allocation in your account before the end of a quarter, we will use the market valuation from the date of the change to adjust only the portion(s) of the Program Fee (e.g., Overlay Manager Fee, Model Provider Fee, Investment Manager Fee) affected by such change on a pro-rated basis. At the time of such account change, the market value of your account may be higher or lower than the market value of your account at the time your quarterly Program Fee was calculated. As a result, the prorated Model Provider Fee, Overlay Manager Fee, and/ or Investment Manager Fee portion of the Program Fee may be higher or lower than when originally calculated. Each of Investment Adviser and RBC CM reserve the right to correct errors in calculations of Program Fees that were charged to you by debiting or crediting your account, as applicable, without prior notice to you. Additionally, RBC CM reserves the right to increase any components of the Program Fee upon thirty (30) days’ advance written notice to you. Fees Upon Termination You, Investment Adviser, or RBC CM can terminate your Program account in accordance with the notice and other provisions contained in the Advisory Agreement. If a Program account is terminated prior to the last day of the quarter, we will refund you the prorated portion of the Program Fee you paid, calculated based upon the days remaining in the quarter. The termination of a Program account will terminate the Advisory Agreement for that account and, where RBC CM was the Overlay Manager, we will no longer be acting as a fiduciary to you with respect to that account. Payment of Program Fee The Program Fee will be deducted on a quarterly basis directly from your Program account unless you affirmatively elect, verbally or in writing, to be billed directly, or to have the Program Fee deducted from another account with your Investment Adviser for which RBC CM is custodian, provided that the account is not a custodial account (e.g., UGMA/UTMA account) or a Retirement Account, as permitted by applicable law. If you have elected to be invoiced for the Program Fee and the Program Fee is not paid within sixty (60) days of the date of the invoice, RBC CM will instead debit your applicable Program account for the invoiced amount of the Program Fee due. Offset of Certain Fees to Retirement Accounts With respect to Retirement Accounts in the Consulting Solutions and RBC UP Programs, if you hold RBC GAM – U.S. Funds, including the RBC BlueBay Access Capital Community Investment Fund, RBC BlueBay Destra International Event-Driven Credit Fund, or Funds subadvised by RBC Rochdale, LLC (“RBC Rochdale”), we will rebate the net management fee charged by the Fund company to you. For other affiliated Funds and/or Funds sub-advised by an affiliate of ours (e.g., RBC GAM –U.S.), the Program Sponsor Fee, and the Overlay Manager Fee when RBC CM acts as Overlay Manager in RBC UP, will not be assessed on the value of these Funds held in Consulting Solutions and/or RBC UP Retirement Accounts. Unless required by applicable law, the credit or offset will not apply to other Fund expenses such as transfer agency fees and shareholder servicing fees, or actual distribution, shareholder servicing and other fees paid to RBC CM and its affiliates. Additionally, RBC CM has a conflict of interest in offering and recommending proprietary and affiliated Funds in the Programs over non-proprietary and/or non-affiliated Funds because we and/or our affiliates receive the fees and expenses charged by such Funds rather than a non-affiliate. For more information see “Fees to RBC Affiliates” on our public website at www.rbcclearingandcustody.com/en-us/legal/. Comparing Costs You may pay more or less in a Program than you might otherwise pay if you purchased the services separately, through other firms, or if you chose to purchase the same or similar securities in a brokerage account without the investment advisory services through the Programs. Factors to consider with respect to the cost of a Program include but are not limited to: the cost of the services if provided and charged separately; the Program Fee rate charged in the Program; and the trading activity in your Program account. When making cost comparisons, you should be aware that the combination of investment management, custodial, consulting, and brokerage services available through a Program may not be available separately or may require multiple accounts, agreements, and fees. In addition, certain Investment Strategies, Overlay Managers, and/or Model Portfolios RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 16 of 35 26-25-5088800_25213-AS (09/26)  may not be available to clients outside of a Program either because of minimum account size requirements, fee schedules, geographic availability, or other factors. When assessing the overall cost of a Program, you should also consider that a Program account with low trading volumes, high cash balances, and/or significant fixed income positions could receive similar services at a lower cost in a brokerage account. If a Program account is actively traded through RBC CM, the Program Fee may be less expensive than separately paying investment management fees, consulting fees, and trading and execution costs. In addition, investments that have no upfront fees or commissions, such as no-load Funds, may be available to you outside of a Program account at no additional cost. As discussed below in Item 4 under “Fund Fees and Expenses,” fees charged in connection with certain investments in your Program account, such as management and other fees charged by Funds, are not included in the Program Fee and will result in higher total costs than if you invested in such securities outside of a Program account. Additional Fees and Expenses The Program Fee (including all components described above) does not cover or include any of the following additional fees and expenses, where applicable: • Fees charged to you by your Investment Adviser; • commissions, “mark-ups,” “mark-downs,” and dealer spreads, if any, (i) that RBC CM or its affiliates receive when acting as principal in certain transactions where permitted by law, rule, or regulation, or (ii) that other broker-dealers receive when acting as principal in certain transactions effected through RBC CM and/or its affiliates acting as agent, which • is typically the case for dealer market transactions (e.g., fixed income, over-the-counter equity, and foreign exchange (“FX”) conversions in connection with purchases or sales of non-US dollar-denominated securities and with payments of principal and interest dividends on such securities); • underwriting commissions, investment banking, and other fees where RBC CM is a member of an underwriting syndicate; • certain other costs or charges that may be imposed by third parties including, among other things, bid-ask spreads, odd- lot differentials, exchange fees, transfer taxes, foreign custody fees, supplemental transaction fees, regulatory fees and other fees or taxes that may be imposed pursuant to law, rule, or regulation; • RBC CM’s usual and customary transaction charges on the liquidation of investments deemed ineligible for the Programs; • any contingent deferred sales charges, redemption charges, or other fees and expenses imposed by certain Funds or alternative investments (see Fund prospectus or private placement memorandum (“PPM”), as applicable, for details); • check reordering costs and fees; • short-term trading charges for purchases and corresponding redemptions of certain Fund shares (see Fund prospectus for details) made within a short period of time; • costs and expenses of UITs (e.g., organization costs, operating expenses, portfolio supervision, bookkeeping, trustee, and other administrative fees, etc.); • fees and charges specific to annuities linked to your Program account, which may include but are not limited to, administrative and termination/distribution charges, mortality and expense risk charges, expenses for underlying investment options and optional rider/benefit fees; • RBC Express Credit (margin) or RBC Credit Access Line (CAL) interest, or interest on other debit account balances; • non-sponsored alternative investment processing and maintenance fees; • safekeeping fees for physical securities; • American Depositary Receipt (“ADR”) pass-through fees; • additional costs incurred when purchasing foreign securities that are assessed by the foreign exchange, including, but not limited to, exchange fees, taxes, conversion fees and currency translation costs. For example, when “ordinary shares” are purchased on a foreign exchange (which may charge a fee or tax on the trade) and are converted to ADRs, the depository bank may charge a fee to convert the ordinary shares to ADRs and in doing so, there may be currency translation costs associated with the conversion; • additional costs when investing in foreign securities and utilizing foreign tax relief and reclamation services; • fees charged by RBC CM related to reporting and filing unrelated business taxable income in Retirement Accounts; and • any fees/expenses associated with RBC Insured Deposits. Fund Fees and Expenses Funds pay fees and expenses that are ultimately borne by clients (including, but not limited to, management fees, brokerage costs, administrative, and custody fees), as detailed in each Fund’s prospectus. Program clients that are holding or investing RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 17 of 35 26-25-5088800_25213-AS (09/26)  in Funds will pay two levels of investment advisory fees: 1) investment management fees charged by the Fund companies, and 2) Program Fees to your Investment Adviser, RBC CM as Program sponsor, the Investment Managers, the Model Providers, and/or the Overlay Manager. Some of the fees and expenses are paid to and, where permitted under applicable regulatory requirements, retained by us and/or the Investment Adviser for advisory and/or other services. Funds eligible for the Programs will be subject to the Program Fee which could also subject you to a higher overall cost. Outside of the Cash Sweep Program, RBC CM may, without notice to you, convert Funds in your Program account to a lower cost share class of the same Fund offered by RBC CM or make changes to your investment model or allocation in the event a lower cost share class of the same Fund is or becomes available through RBC CM. However, if you purchased a Fund from RBC CM with an up-front sales charge, typically in a brokerage account outside of the Programs, and subsequently transfer such Fund shares into an advisory Program account, those Fund shares will not be subject to the Program Fee for two or more years from the date of initial purchase. Fund shares purchased at other financial institutions may be converted to the appropriate share class in a Program account and subject to the Program Fee immediately whether you paid an up-front sales charge or other compensation or not. RBC CM may also elect not to convert certain Fund shares if, for example, there is no equivalent share class available in the Programs, or such conversion could subject you to additional sales or other charges, or in certain other circumstances, as determined by us. Additionally, if you have a systematic buy or sell transaction established for a Fund that is ineligible for the Program selected, the transaction may be rejected resulting in your trade(s) not being fulfilled. Prior to enrolling in the Programs, you should review the costs and impact of converting your Fund share classes and discuss this with your Investment Adviser. If you do not want your Funds converted, or your investment model/allocation updated, you should discuss leaving those holdings in or transferring those holdings to a non-Program account. Under certain circumstances, your account may be invested in a Fund share class with a 12b-1 fee. This fee, which is also known as a distribution fee, is an operational expense used to pay for marketing and distribution expenses and is therefore included in the Fund’s expense ratio. 12b-1 fees are part of the overall Fund expense ratio, which is paid by you through deduction of assets in the Fund’s daily net asset value calculation. 12b-1 fees may vary by share class, with certain share classes having lower or no 12b-1 fees. Typically, the 12b-1 fee is paid to your Investment Adviser as ongoing compensation for a period of time, as outlined in the applicable prospectus, creating an incentive for your Investment Adviser to recommend a Fund and a share class that pays a 12b-1 fee as opposed to a Fund or share class that does not. Excluding the Cash Sweep Program, RBC CM addresses this conflict of interest by (1) limiting offerings of share classes that pay a 12b-1 fee in the Programs, and (2) crediting any 12b-1 fees that RBC CM receive back to you rather than paying such fee to the Investment Adviser. Funds and certain other investments will be accompanied by a prospectus or other offering document that contains important information about each such Fund, including investment objectives, risks, and applicable fees and expenses. Clients should read each Fund’s prospectus carefully and consider all the information in it before investing. If, and to the extent that your account is invested in a Fund managed by an affiliate of ours, you will indirectly pay two levels of advisory and other fees to us in connection with such balances (i.e., the investment management fees charged by the Fund companies, and the Program Fee). We address this conflict through disclosure and by subjecting the affiliated Funds to the same selection and evaluation standards as non-affiliated Funds. Further, in Retirement Accounts, if you hold Funds subadvised by RBC Rochdale, the management fee charged by the Fund company will be rebated to you. For other RBC CM affiliated Funds subadvised by RBC Rochdale, the Program Sponsor Fee payable to RBC CM, and when RBC CM acts as the Overlay Manager in RBC UP, the Overlay Manager Fee component of the Program Fee, will not be assessed to the value of such Funds maintained in Retirement Accounts. You should read the Fund’s prospectus carefully prior to selecting a Fund. Trading Away and Associated Costs We generally anticipate most Investment Managers and the Overlay Managers will effect substantially all portfolio trades for Program accounts with or through us. This arrangement creates an incentive for us to make available Investment Managers or Model Providers with lower portfolio turnover rates. There are certain Investment Managers, including those offering certain fixed income strategies, that have historically directed most, if not all, their trades to outside broker dealers. RBC CM makes information on Investment Managers’ trading practices in this regard available via the “Investment Managers and Trading Practices” link at RBC CM’s legal disclosure website, www.rbcclearingandcustody.com/disclosures. The information we provide in this regard is based solely on the historical information provided to us by the Investment Managers. We do not make any representations regarding their future trading practices. If Investment Managers trade away from RBC CM with other broker dealers, you should understand that commissions, mark- ups, spreads, and other transactional charges for such trades are charged to you by the executing broker dealer (and passed along to you by RBC CM). Accordingly, the Program Fee you pay does not cover such costs charged by other broker-dealers; the Program Fee covers these costs only when the transactions are executed by RBC CM. The executing broker-dealer may net these commissions, mark-ups, spreads and other transactional charges into the overall purchase or sale price of the trades, and these RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 18 of 35 26-25-5088800_25213-AS (09/26)  commissions, mark-ups, spreads and other transactional charges are not delineated on your RBC CM trade confirmation, monthly transaction summary or statement. RBC CM does not restrict an Investment Manager’s ability to trade away, as the responsibility to determine the suitability of trading away from RBC CM and for best execution is that of the Investment Manager. RBC CM does not evaluate whether an Investment Manager is meeting its best execution obligations when trading away. You should understand that RBC CM is not a party to transactions that are not executed through or with us, and therefore, we are not able to negotiate the price or transaction-related charge(s) with the executing broker-dealer. While the costs associated with equity trades done away are typically in the form of commissions and other transactional charges that are disclosed and accessible to RBC CM, the additional costs associated with fixed income trades are not identified separately because they are incorporated into the net price of the trade. Additional information on trade-away practices of Investment Managers in Consulting Solutions is available via at: www.rbcclearingandcustody.com/disclosures. Note, before selecting an Investment Manager for any Program described in this brochure, you should carefully review all material related to that Investment Manager, including any disclosure on whether the Investment Manager uses broker- dealers other than RBC CM to effect any trades and any additional trading costs (brokerage commissions or other charges) associated with executing trades with such other broker-dealers. You should consider this information (i.e., an Investment Manager’s trading practices and any associated additional costs and expenses), when assessing the overall costs of a Program and a particular Investment Manager and/or Investment Strategy. Foreign Tax Relief and Reclamation Services For clients who invest in international securities, we utilize a third-party vendor that provides foreign tax relief and reclamation services on behalf of clients. For more information, please see “Foreign Tax Relief and Reclamation Overview” on our public website at www.rbcclearingandcustody.com/disclosures. Tax Considerations The payment of the Program Fee as described above may produce income tax results different from those resulting from the payment of brokerage commissions or other transactional charges on a per trade basis. If you are not a tax-exempt entity, the sale, redemption, or exchange of investments may result in taxable gains or losses. Further, it is your responsibility to ensure that the payment method selected, and subsequent treatment of the related expenses, complies with applicable tax laws and other regulations. In addition, careful consideration should be given prior to purchasing investments or selecting strategies that may utilize “tax-advantaged” investments in certain qualified accounts. This may result in no additional tax benefits at the expense of performance. Neither RBC CM, nor its affiliates or employees provide legal, accounting or tax advice. All legal, accounting or tax decisions regarding your accounts and any transactions or investments entered into in relation to such accounts, should be made in consultation with your independent advisors. No information, including but not limited to written materials provided by RBC CM or its affiliates or employees should be construed as legal, accounting or tax advice. Compensation to Investment Adviser Advisory Fees For information on how your Investment Adviser compensates its advisory personnel and financial professionals, please see your Investment Adviser’s ADV brochure or other similar disclosure documents, or contact your Investment Adviser. Investment Advisers are compensated based on the market value of billable assets in your Program account. In certain instances, your account could contain assets that are not included in the billable value of the account. Therefore, this is a conflict of interest as your Investment Adviser could have a financial incentive to sell these assets and purchase assets that would be included in the billable value of the account and directly impact compensation. ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS To open an account in any of the Programs and receive the investment advisory and other related services described in this brochure, you must enter into the Advisory Agreement with your Investment Adviser and RBC CM. The Advisory Agreement expressly acknowledges the parameters of our investment advisory relationship with you, describes the services we will provide to you, and details the terms and conditions of the Program. The Advisory Agreement governs the relationship with your Investment Adviser and RBC CM with respect to the terms of your existing and future Program accounts. Each of the Programs generally requires a certain minimum amount of assets to open an account in that Program. However, RBC CM has the discretion to accept accounts that are below the Program minimums. RBC CM reserves the right to terminate a Program account if the account assets fall below the Program minimums set forth below. • RBC UP: Depending on services and Investment Products selected, minimums range from $2,500-$500,000. • Consulting Solutions: $100,000-$600,000 for equity strategies; $100,000-$500,000 for fixed income strategies, subject to minimum account requirements imposed by the applicable Investment Manager. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 19 of 35 26-25-5088800_25213-AS (09/26)  RBC CM provides investment advisory services to individuals, foundations, endowments, employee benefit plans, trusts, estates, educational institutions, corporations, businesses, government entities and other entities. The Programs are generally available for both non-retirement and Retirement Accounts, including IRAs. When providing services to clients who are subject to ERISA, we may rely on various Prohibited Transaction Exemptions (“PTEs”) available under ERISA, including PTE 84-14, which is only available to qualified professional asset managers (the “QPAM Exemption”). On March 5, 2024, the French Court of Appeal rendered a judgment of conviction (the “Conviction”) against Royal Bank of Canada Trust Company (Bahamas) Limited (“RBCTC Bahamas”), an affiliate of RBC CM, and other parties regarding a charge of complicity in estate tax fraud relating to actions taken relating to a trust for which RBCTC Bahamas serves as trustee. In 2016, RBC was granted an exemption by the U.S. Department of Labor that allowed RBC and its current and future affiliates to continue to qualify for the QPAM Exemption under ERISA despite the conviction of RBCTC Bahamas in the French proceeding for a temporary one-year period from the date of conviction. In 2025, the Department of Labor granted RBC an exemption providing longer-term relief, which is effective from August 12, 2025, through March 4, 2030. ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION Selection of Investment Managers and Model Providers In RBC UP and Consulting Solutions, we consider and select only Investment Managers and Model Providers that meet our eligibility requirements. In identifying and choosing Investment Managers and Model Providers, we evaluate the financial and organizational stability of the firm and product, historical performance results, experience, and other factors. Based on the evaluation, Investment Managers and Model Providers are categorized by their respective investment styles. Each Model Portfolio and Investment Strategy added to the RBC UP and/or Consulting Solutions Programs, as applicable, are further categorized by the level of conviction RBC CM has in the Investment Manager and/or Model Provider and their respective Investment Strategy or Model Portfolio. Information that we gather regarding Investment Managers and Model Providers is believed to be reliable and accurate, but we do not independently verify it. We conduct periodic reviews of Envestnet and our own Overlay Manager function to evaluate adherence to Model Portfolios and investment allocations selected by you. As described above in Item 4, you will establish an Advisory Risk Profile for your Program account. For Programs in which you select an Investment Manager(s) or Model Provider(s), your Investment Adviser will consult with you regarding investment alternatives consistent with your Advisory Risk Profile. You then can select one or more Investment Managers (and their Investment Strategy(ies)) and/or Model Providers (and their Model Portfolio(s)). When required to do so by law or as otherwise agreed to with an Investment Manager, we will provide you with a copy of each Investment Manager’s and/or the Overlay Manager’s written disclosure statement (Part 2A of its Form ADV or other comparable document) at the time of Program enrollment. Monitoring and Review of Investment Managers and Model Providers On a quarterly basis, we monitor and review the Investment Managers we make available in Consulting Solutions and RBC UP, and the Model Providers we make available in RBC UP, to determine whether they continue to meet the standards and requirements of RBC CM. This evaluation may involve, among other things, a review of investment discipline and trends in investment philosophies. Comparisons are made to other accounts and to standard industry market statistics. These initial and ongoing due diligence reviews are conducted by the RBC Global Manager Research team (“GMR”). The level of review applied by GMR depends on RBC CM’s conviction in each Investment Manager and Model Provider and their respective Investment Strategies and Model Portfolios. For the highest conviction Investment Strategies and Model Portfolios, this review is based on both the investment style descriptions offered by the Investment Managers and Model Providers (qualitative factors) and analysis performed by GMR (quantitative factors). GMR’s ratings and opinions for the highest conviction Investment Strategies and Model Portfolios are available to Investment Advisers. These ratings and opinions are updated annually or more frequently, as needed. Investment Strategies and Model Portfolios not deemed highest conviction are reviewed quarterly based primarily on quantitative factors. A quantitative score (“Score”) is assigned to each Investment Strategy and Model Portfolio based on multiple factors related to the firm and product, investment professionals, investment approach and performance and weights assigned to the individual factors selected. Investment Strategies and Model Portfolios not deemed to be the highest conviction must meet these predefined Scores to be added and maintained in the Programs. If a Score cannot be calculated, the same factors are reviewed manually, instead of systematically, until a Score can be calculated. For cases where a Score cannot be produced, GMR will continue to qualitatively monitor the applicable Investment Strategies and Model Portfolios and provide annual updates as needed to the RBC CM Managed Account Investment Committee. Scores are not assigned to the RBC CM Portfolio Advisory Group (“PAG”) Model Portfolios. Each of the PAG Model Portfolios is reviewed quarterly by an internal oversight committee led by GMR to determine if it continues to align with its stated investment objective. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 20 of 35 26-25-5088800_25213-AS (09/26)  Through our monitoring process, the level of conviction in an Investment Strategy or Model Portfolio may change, and therefore, the level of review applied may also change. If you would like information regarding RBC CM’s conviction in a particular Investment Strategy or Model Portfolio, please contact your Investment Adviser. The level of conviction we have in an Investment Strategy or Model Portfolio is not indicative of its quality nor is it a basis for how the Program Fee is determined. Watch List As part of our monitoring process, RBC CM maintains a watch list of Investment Strategies and Model Portfolios for which there may be developments of potential concern. Such developments may include Investment Managers’ and Model Providers’ adherence to management style, consistency with client objectives, unexplained poor performance, or other matters that come to our attention. The watch list provides us with the means to review and communicate developments related to Investment Managers and Model Providers. Placement of Investment Managers and/or Model Providers on the watch list initiates a probationary period that allows us adequate time to better assess the effects — negative or positive — stemming from the developments in question. Performance • Investment Manager and Model Provider. For all Investment Strategies and Model Portfolios, we produce product profiles containing reported historical performance available to your Investment Adviser to provide to you. These product profiles include the Investment Manager’s or Model Provider’s reported performance and generally present 10 years of an investment strategy’s performance history. • Fund Performance. We utilize the Fund’s published performance for review purposes. • Portfolio Advisory Group (PAG). We create performance composites for each PAG Model Portfolio and make them available to your Investment Adviser to provide to you. These composites are comprised of the RBC UP Sleeves invested in each such Model Portfolio. We make product profiles for each PAG Model Portfolio available to Financial Professionals to provide to you. These product profiles include our calculated composite performance. Your Financial Professional may provide you with information to allow you to compare this PAG performance data with your account and/or Sleeve performance. Removal of an Investment Strategy, Model Portfolio, Overlay Manager, or Fund Upon written notice to affected clients, we may remove an Investment Strategy or Model Portfolio from RBC UP or Consulting Solutions if our rating and/or opinion of the Investment Strategy or Model Portfolio materially changes. This will most commonly be a result of fundamental developments that are determined to be detrimental to the potential longer-term success of the Investment Manager, Model Provider, or underlying investment strategy (e.g., departure of key personnel, performance, etc.). In such event, we will promptly notify your Investment Adviser, who will in turn consult with you to reallocate applicable account assets to a new Investment Manager or Model Provider. In the event RBC CM removes an Investment Strategy from Consulting Solutions, and you do not reallocate applicable account assets prior to the termination of the Investment Strategy, we may terminate your Program account. In RBC UP, when RBC CM removes a Model Portfolio or Investment Strategy selected for your account, if you do not select a new Model Portfolio or Investment Strategy before the removal date, we will move your assets to an available Investment Strategy or Model Portfolio which we deem, in our sole discretion, to be consistent with the removed Model Portfolio or Investment Strategy. If an appropriate replacement Model Portfolio or Investment Strategy is not available, we will move your assets to an appropriate Fund and/or closed-end fund. In RBC UP, we will provide information to your Investment Adviser regarding a Fund that is no longer eligible for the Program. Your Investment Adviser will work with you to select a suitable replacement investment. In RBC UP, we may change the Overlay Managers upon advance written notice to the affected clients. Related Persons as Investment Manager, Model Provider, and/or Overlay Manager, and Associated Conflicts of Interest If you invest in certain Programs described in this brochure, your account may be managed by an Investment Manager that is an affiliate of ours (also referred to as a related person), or that is a client of an affiliate of ours. In addition, we, or our affiliates (or clients of our affiliates) may act as Model Providers. Related persons or their clients acting as Investment Managers or Model Providers are subject to the same eligibility, review, and removal procedures as non-affiliated Investment Managers and Model Providers, as described above. When related persons or their clients act as Investment Managers or Model Providers for Program clients, certain conflicts of interest exist (see Item 9, Material Relationships with Related Persons for more information on conflicts of interest). In some cases, the same Investment Strategies are available in both Consulting Solutions and RBC UP. However, the fees associated with these Investment Strategies may differ depending on the Program. Generally, for fixed income Investment Strategies available in both Consulting Solutions and RBC UP, the Investment Manager Fee is the same. However, for equity RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 21 of 35 26-25-5088800_25213-AS (09/26)  Investment Strategies available in both Consulting Solutions and RBC UP, the RBC UP Model Provider Fee is generally lower than the Consulting Solutions Investment Manager Fee due to the specific services provided in each Program. Consulting Solutions client accounts are separately managed to an Investment Strategy by the Investment Managers in the Program on a discretionary basis. In contrast, in RBC UP, implementation of, and updates to, Model Portfolios are managed by us or Envestnet as Overlay Manager on a discretionary basis. When we act as Overlay Manager in RBC UP, we retain the 0.05% Overlay Manager Fee that we charge which can give us an incentive to promote RBC UP over Consulting Solutions, particularly where an investment strategy is available in both Programs. Any difference in fees paid by you and fees we pay to the Investment Managers, Model Providers or the Overlay Managers are retained by us. This fee differential for certain equity investment strategies is larger in Consulting Solutions than in RBC UP. When fee differentials are retained by us, we do not pay any part of the retained fees to your Investment Adviser. Therefore, Investment Advisers do not have a direct financial incentive to recommend using investment strategies in one Program over the other. Our Cash Sweep Program creates a conflict of interest for us because we have an incentive for you to maintain and direct otherwise uninvested cash in your account to Deposit Accounts of our Affiliate Banks and third-party banks, where RBC CM earns a fee on such cash balances and RBC CM and our affiliates can use such deposits to generate additional revenue. Please see the above Cash Sweep Program Conflicts of Interest section in Item 4 for additional details. More information regarding the Cash Sweep Program is available in the Cash Management section of our public website at www.rbcclearingandcustody.com/disclosures. In the Programs, you may be able to invest in Funds and other investment products affiliated with RBC CM. Certain conflicts of interest among the issuer, Fund, the Fund manager, and/or the broker or agent may exist as described in the PPM or applicable prospectus. Where we are affiliated, through common ownership and control by the RBC, with a Fund, Fund manager, issuer or agent, we have an incentive to make our proprietary or affiliated product available over an unaffiliated product, such that the fees and expenses charged by the Fund, Fund manager, issuer or agent are earned by us or our affiliate, rather than a non-affiliate. You may invest in an Investment Manager and/or Model Provider affiliated with RBC CM. We have an incentive to make our affiliated Investment Managers and Model Providers available because RBC CM and its affiliates receive greater revenue. RBC GAM – U.S. RBC GAM – U.S. acts as an Investment Manager in Consulting Solutions and as a Model Provider in RBC UP. This is a conflict of interest as we are incented to make RBC GAM – U.S. available as a Model Provider and Investment Manager over non- affiliates. This conflict of interest is addressed by proper disclosure. If you select RBC GAM – U.S. as your Investment Manager in Consulting Solutions, or as your Model Provider in RBC UP, RBC GAM – U.S. and RBC CM will each collect separate advisory fees. RBC Global Asset Management (UK) Limited RBC Global Asset Management (UK) Limited (“GAM UK”) acts as a Model Provider in RBC UP. This is a conflict of interest as we are incented to recommend GAM UK over non-affiliates. This conflict of interest is addressed by proper disclosure. If you select GAM UK as your Model Provider in RBC UP, GAM UK and RBC CM will each collect separate advisory fees. RBC CM Acting as Portfolio Manager As discussed above in Item 4, RBC CM acts as the Overlay Manager in RBC UP. Our participation in a Program creates an incentive for us to make such Program available where we are the Portfolio Manager over other qualified and suitable Portfolio Managers. Where RBC CM serves as the Overlay Manager in RBC UP, we charge and retain the Overlay Manager Fee component of the Program Fee you pay. PAG independently analyzes research from its research providers and makes such information available to Investment Advisers.. The research that is produced by PAG is intended to provide a broad and extensive array of fundamental research in the marketplace by focusing on key analysts, recommendations, and trends within their research sources, including those of RBC CM as well as through nationally recognized correspondents. Using such research data provided by PAG, RBC CM also creates equity Model Portfolios for use in RBC UP. RBC CM does not receive a Model Provider Fee for providing these Model Portfolios. While PAG’s research is independent, RBC CM has a conflict of interest when selecting Funds for inclusion in a model portfolio because we have an incentive to use certain Funds over others. Specifically, we have an incentive to select 1) Funds for which we receive additional compensation from the investments in such Funds, and/or 2) Funds managed by an affiliate of RBC CM which results in compensation to any such affiliate. We mitigate this conflict of interest by disclosure and subjecting RBC CM’s Model Portfolios to review by an internal oversight committee on a regular basis, consistent with the standards employed when reviewing and selecting those of unaffiliated and affiliated Investment Managers and Model Providers, as further detailed in Item 6. Selection of Investment Managers and Model Providers. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 22 of 35 26-25-5088800_25213-AS (09/26)  Performance-Based Fees and Side-by-Side Management RBC CM does not charge performance-based fees in the Programs. However, certain Funds available in the Programs may be subject to performance-based fees or varying expense charges imposed by the Fund manager. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies The methods of analysis used and investment strategies available in each Program are described above in the “Services, Fees and Compensation” and the “Portfolio Manager Selection and Evaluation” sections. We obtain information from various sources including financial publications, company press releases and securities filings, research and due diligence material prepared by RBC CM, our affiliates and other third parties, rating or timing services, regulatory reports, third-party data, and research providers, professionals and other public sources. Your Investment Adviser may use research, model portfolios, and/or asset allocation recommendations provided by RBC CM, our affiliates and/or third parties to make recommendations to you. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. There is no guarantee of performance for any investment strategy implemented or recommended by your Investment Adviser, and the value of a client’s investments will fluctuate due to market conditions and other factors. Investments are subject to various risks, including, but not limited to, market, liquidity, currency, economic, and political risk, and will not necessarily be profitable. Past performance does not predict or guarantee any level of future performance. For the strategies used in the Programs, equities, Funds, options, and fixed income securities are the primary investments. Below are certain material risk factors associated with the Programs and the strategies utilized in the Programs. There are certain other risk factors described throughout this brochure. For more details on material risk factors associated with Investment Strategies, Model Portfolios, and/or the services of the unaffiliated Overlay Manager in applicable Programs, please refer to each Investment Manager’s, Model Provider’s, and/or the Overlay Manager’s Form ADV Part 2A brochure and/or other similar disclosure documents. In addition, always read the prospectus or other offering documents for a full description of risks associated with a particular investment. You are urged to consult with your Investment Adviser to discuss the risks associated with any investment strategy, particular investments, securities, and/or transactions recommended or effected in your Program account(s). Some of the material risks associated with investments available in the Programs are as follows: • Market Risk. The value of securities owned by an investor may go up or down, sometimes rapidly or unpredictably, due to factors affecting certain industries and/or securities markets generally. • Interest Rate Risk. Fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. • Economic Conditions Risk. The economic, political, or financial developments will, from time to time, result in periods of volatility or other adverse effects that could negatively impact your account. • Credit Risk. Investors could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. • Liquidity Risk. Investors would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments and interval funds have higher liquidity risk than securities traded on exchanges, fixed income securities or open-end mutual funds. • Risks Relating to Equities. The price may rise or fall, sometimes rapidly or unpredictably, because of changes in a company’s financial condition. These price movements can result from economic changes or macro factors such as the economic performance of a particular country, interest rate movements, and international developments. Sector or industry developments as well as changes in government regulations may affect equity prices. • Risk Relating to Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may prepay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures, and the investor may lose income. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 23 of 35 26-25-5088800_25213-AS (09/26)  • Risks Relating to Specific Styles. Different types of stocks tend to shift in and out of favor depending on market and economic conditions. To the extent a portfolio emphasizes a value or growth style of investing, a portfolio runs the risk that undervalued companies’ valuations will never improve or that growth companies may be more volatile than other types of investments, respectively. • Risks Relating to Securities-Based Lending. Certain Program accounts may be eligible for Margin or other types of securities-based lending as part of RBC CM’s brokerage services. The extension of credit may be obtained through Lending Programs described above. Prior to enrolling in any of the Lending Programs, you should carefully review the agreement and disclosures for such Lending Program and ensure that you understand the risks associated with leveraging your account. You must carefully consider: — Whether or not you can afford, and want, to assume the additional risks that losses in your account may be significantly greater than if you decide not to invest with borrowed funds (i.e., not to use leverage). Leveraging your account may increase your risks and make your investment objectives more difficult to realize you may lose more than your original investment; — You will pay interest on the outstanding loan balance; thus, the use of leverage will increase your costs of investing; — Since the Program Fee is calculated as a percentage of the net market value in a Program account, the use of Margin to purchase additional securities in a Program account will increase the net market value of the Program account by the value of such additional securities purchased with the proceeds of the Margin loan (and will not be offset by the amount of the client’s Margin debit held in an account outside of a Program). This will result in a higher Program Fee that you pay to us and your Investment Adviser. This will result in additional compensation to RBC CM and your Investment Adviser; — RBC CM, or a third-party lender, can force the sale of Program assets to satisfy collateral requirements without notice to you; — Neither RBC CM nor our affiliates will act as an investment adviser to you with respect to the liquidation of securities held in a Program account to meet collateral requirements. These liquidations will be executed in our capacity as broker-dealer and creditor and may, as permitted by and in accordance with applicable laws, rules, and regulations, including the Advisers Act, result in executions on a principal basis in your account; and — Under these circumstances, RBC CM cannot guarantee a favorable price on the sale of Program assets or that the liquidations align with your investment strategy or Advisory Risk Profile. RBC CM is permitted to lend or utilize Margin securities in its possession and receives compensation in connection with the use of such securities. The costs you pay associated with the Lending Programs is not included in the Program Fee and will result in additional compensation to RBC CM and/or our affiliates and your Investment Adviser. For more information, please see the “Margin Disclosure Statement” under “RBC Express Credit” on our public website at www. rbcclearingandcustody.com/disclosures. • Risks Relating to Money Market Funds. An investment in a money market fund is neither insured nor guaranteed by the FDIC or any other government agency. Although money market funds seek to preserve the value of your investment at $1.00 per share, there is no assurance that will occur, and it is possible to lose money if the fund value per share falls. Moreover, in some circumstances, money market funds may be forced to cease operations when the value of a fund drops below $1.00 per share. If this happens, the fund’s holdings are liquidated and distributed to the fund’s shareholders. This liquidation process is likely to take a month or more. During that time, these funds would not be available to you to support purchases, withdrawals and, if applicable, check writing or other money movement debits from your account. • Concentration Risk. To the extent a client concentrates their investments by investing a significant portion of their assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub-sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub-sectors. An individual sector, industry, or sub sector of the market may be more volatile and may perform differently than the broader market. The several industries that constitute a sector may not all react in the same way to economic, political, or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub-sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. • Risks Relating to Foreign Securities and Emerging Markets. Investments in securities of foreign issuers denominated in foreign currencies are subject to risks in addition to the risks of securities of U.S. issuers. These risks include political and economic risks, civil conflicts and war, greater volatility, expropriation and nationalization risks, sanctions or other measures by the United States or other governments, currency fluctuations, higher transactions costs, delayed settlement, possible foreign controls on investment, liquidity risks, and less stringent investor protection and disclosure RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 24 of 35 26-25-5088800_25213-AS (09/26)  standards of some foreign markets. Events and evolving conditions in certain economies or markets may alter the risks associated with investments tied to countries or regions that historically were perceived as comparatively stable becoming riskier and more volatile. These risks are magnified in countries in emerging markets, which may have relatively unstable governments and less-established market economies than those of developed countries. Emerging markets may face greater social, economic, regulatory, and political uncertainties. These risks make emerging market securities more volatile and less liquid than securities issued in more developed countries. For more information, see the “Risks Related to Foreign Securities and Foreign Currencies section” in the Client Account Agreement and Disclosure, available on our public website at www.rbcclearingandcustody.com/disclosures. • High Yield Securities Risk. Certain strategies invest in securities and instruments that are issued by companies that are highly leveraged, less creditworthy, or financially distressed. These investments (known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties, and potential illiquidity. For more information see the “High-Yield Securities Disclosure” on our public website at www.rbcclearingandcustody.com/disclosures. • Counterparty Risk. An account may have exposure to the credit risk of counterparties with which it deals in connection with the investment of its assets, whether engaged in exchange traded or off-exchange transactions or through brokers, dealers, custodians, and exchanges through which it engages. In addition, many protections afforded to cleared transactions, such as the security afforded by transacting through a clearing house, might not be available in connection with over-the-counter (“OTC”) transactions. Therefore, in those instances in which an account enters into OTC transactions, the account will be subject to the risk that its direct counterparty will not perform its obligations under the transactions and will sustain losses. • Derivatives Risk. Certain strategies may use derivatives. Derivatives, including forward currency contracts, futures, options and commodity-linked derivatives and swaps, may be riskier than other types of investments because they may be more sensitive to changes in economic and market conditions, and could result in losses that significantly exceed the investor’s original investment in the derivative. Many derivatives create leverage thereby causing a portfolio to be more volatile than it would have been if it had not been exposed to such derivatives. Derivatives also expose a portfolio to counterparty risk (the risk that the derivative counterparty will not fulfill its contractual obligations), including the credit risk of the derivative counterparty. Certain derivatives are synthetic instruments that attempt to replicate the performance of certain reference assets. Regarding such derivatives, an investor does not have a claim on the reference assets and is subject to enhanced counterparty risk. Derivatives may not perform as expected, so an investor may not realize the intended benefits. The possible lack of a liquid secondary market for derivatives and the resulting ability to sell or otherwise close a derivatives position could expose a portfolio to losses. Additionally, certain derivatives are subject to position limits imposed by regulators, and the investment adviser will not be able to obtain additional exposure if these limits are reached. When used for hedging, the change in value of a derivative may not correlate as expected with what is being hedged. In addition, given their complexity, derivatives expose an investor to risks of mispricing or improper valuation. • Risks Relating to Structured Investments. Structured Investments are generally a combination of unsecured debt and other underlying assets. Since Structured Investments represent an unsecured debt obligation of the issuer, you should consider the creditworthiness of the company issuing the security, since downside protections and payment features are contingent upon the solvency of the issuer. The potential benefits of Structured Investments typically will not be fully realized unless held to maturity. For example, if sold prior to maturity, the sale will be subject to market prices and the principal may not be fully returned. There is no guarantee of secondary market price or interim liquidity, and the interim value of a Structured Investment could differ from the original issue price and the investments intrinsic value. Depending on the type of structure, risks of investing in a Structured Investment include, but are not limited to, call risk, coupon risk, currency risk, liquidity risk, issuer credit risk, loss of principal risk, risks associated with the performance of underlying assets, and tax risk. Structured Investments are complex and are not appropriate for all investors. You should understand the complete terms, risks, tax consequences, and possible performance outcomes of investing in any Structured Investment before purchasing, as each structure is different and constructed for different investment objectives and market conditions. When considering a Structured Investment, you should review the accompanying prospectus, which will contain more complete information. • Risks Relating to Smaller Companies. Investments in smaller companies are generally riskier than investments in larger companies. The securities of smaller companies may trade less frequently and in smaller volumes than securities of larger companies. Securities of smaller companies tend to be less liquid than securities of larger companies. In addition, small companies are generally more vulnerable to economic, market and industry changes. As a result, the changes in value of their securities may be more sudden or erratic than in large capitalization companies, especially over the short term. Because smaller companies may have limited product lines, markets or financial resources or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than large capitalization companies. This may cause unexpected and frequent decreases in the value of an account’s investments. Finally, emerging companies in certain sectors may not be profitable and may not realize earning profits in the foreseeable future. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 25 of 35 26-25-5088800_25213-AS (09/26)  Voting Client Securities (Proxy Voting) You have the right to vote proxies for securities held in your Program account(s). You also have the option to delegate proxy voting authority as described below. In the Advisory Agreement, you indicate your proxy voting authority election for your Program account(s). • Client as proxy authority. For all Programs, you can retain the right to vote proxies with respect to the securities held in the account(s), or delegate that right to another third-party designated by you. If you retain proxy voting authority, we will forward to you (or another third-party designated by you) all proxy-related materials, annual and interim reports, and other issuer-related materials that RBC CM receives pertaining to the securities in your Program account(s). • Manager as proxy authority. For certain Programs, you can delegate your proxy voting authority to a manager to vote proxies with respect to the securities held in your Program account(s). If you delegate voting authority to a manager, we will forward all proxy-related materials, annual and interim reports, and other issuer-related materials that RBC CM receives pertaining to the securities in your Program account(s) to a third-party Investment Manager(s) or Overlay Manager (i.e., Envestnet or RBC CM), if applicable, to vote proxies on your behalf. When a client has delegated proxy voting authority to RBC CM, RBC CM further delegates such authority to an independent third-party proxy voting agent, currently Institutional Shareholder Services (“ISS”), as described below. We will not provide you with notice that we have received a proxy solicitation, nor will we or any third-party Investment Manager or proxy voting agent consult with you before casting a vote. Your designation of “Manager” is only valid if accepted by that designee. Investment Managers and the Overlay Managers retain the right to rescind their acceptance of the proxy authorization. If an Investment Manager or the Overlay Manager elects to stop voting proxies, we will forward proxy voting materials to you (or a third-party agent designated by you), and if an Investment Manager or Overlay Manager elects to start voting proxies, we will send to them all proxy-related materials and you will not receive them. You may change your proxy voting election at any time upon written notice to us, in accordance with the terms of your Advisory Agreement. If you or RBC CM terminate a Program account, RBC CM will revert proxy voting authority to you (or another third-party selected by you). RBC UP If you designate “Manager” as proxy authority for your account(s) in RBC UP, RBC CM or Envestnet as Overlay Manager, will vote proxies on your behalf. When we vote proxies, we have a fiduciary responsibility to vote proxies in a manner that we believe is consistent with your best interest and in accordance with the policies and procedures adopted by RBC CM. We have retained ISS, to provide fundamental research and independent voting recommendations based on its standard proxy voting guidelines, and to vote proxies in your account(s) on our behalf. The proxy voting guidelines set forth by ISS are reasonably designed to identify potential conflicts of interest when voting proxies on a client’s behalf. The engagement of ISS as our agent is not intended to be a delegation of our proxy voting responsibilities and does not relieve us of any fiduciary obligations with respect to the voting of proxies. RBC CM has implemented policies reasonably designed to identify potential material conflicts of interest to help us vote proxies without undue influence from individuals or groups who may have an economic interest in the outcome of a proxy vote. These policies include: • Causing the proxies to be delegated to an independent third party; • Causing the independent third party to use predetermined voting guidelines; • Causing proxies to be voted in accordance with recommendations of an independent third party. While ISS uses its best efforts to vote proxies, there are instances when they do not vote proxies because voting is not practical or is not in the best interest of clients. For example, casting a vote on a foreign security may involve additional costs or may prevent, for a period of time, sales of shares that have been voted. Additionally voting may be restricted when a security is a privately held company or a preferred stock where ISS does not have a separate service contract to provide a vote recommendation, or the voting instructions require a vote from either a controlling shareholder or shareholder with personal interest. You may contact your Investment Adviser to request and obtain a copy of our proxy voting policies and procedures, ISS’ standard proxy voting guidelines, and records of how RBC CM voted proxies with respect to securities held in your Program account(s). Consulting Solutions If you designate “Manager” as proxy voting authority for your account(s) in Consulting Solutions, such designation of proxy voting authority is subject to acceptance by the applicable Investment Manager in its sole discretion. Pursuant to this designation, you (i) authorize the selected Investment Manager to receive the proxy-related materials, annual and interim RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 26 of 35 26-25-5088800_25213-AS (09/26)  reports, and other issuer-related materials for securities in your account(s), and (ii) delegate to the Investment Manager the proxy voting rights for those securities. If an Investment Manager has elected to not vote client proxies, you (or another third-party agent designated by you) will be responsible for voting proxies for the securities in your Program account(s). Retirement Accounts With respect to Retirement Accounts subject to Title I of ERISA, we shall have no responsibility or authority to vote proxies on behalf of any such account. The right to direct the voting of proxies is reserved to a named fiduciary of the plan as selected by you. Unless you indicate otherwise in the Advisory Agreement, RBC CM, your Investment Adviser, the Investment Manager(s) selected by you, and/or the Overlay Manager(s) are expressly precluded from voting proxies on behalf of any Retirement Account subject to Title I of ERISA (although we may, in our capacity as a broker, act pursuant to the instructions of a named plan fiduciary). We deem the authority to vote proxies as expressly reserved to a named plan fiduciary and therefore, we have no obligation and will not accept any authority to take action on your behalf with respect to any proxy-related material. ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS We share relevant client information with (1) the Investment Manager(s) and/or Overlay Manager(s) in order for such Investment Manager(s) and/or Overlay Manager(s) to adequately manage your Program account, and (2) certain companies that we or your selected Investment Manager(s) and/or Overlay Manager(s) partner with to service your Program account(s). ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS Investment Adviser, through RBC CM, shall serve as the liaison for communications between you and the Investment Managers and/or Overlay Managers. However, unlike the Investment Managers, the Model Providers do not have direct investment advisory relationships with clients and may have their own restrictions on such contact and consultation. Clients are encouraged to review the Form ADV Part 2A brochure(s) or other similar disclosure documents of any Investment Manager(s), the Overlay Manager (Envestnet), and/or Model Provider(s) for information on whether they have any of their own restrictions on direct client communication. ITEM 9: ADDITIONAL INFORMATION Disciplinary Information The following is a summary of certain adverse legal and disciplinary events and regulatory settlements during the last 10 years that may be material to your decision of whether to retain us for your investment advisory needs. You can find additional information regarding these settlements in Part 1 of our Form ADV at adviserinfo.sec.gov. • In June 2025, RBC CM entered into a settlement (the “Settlement”) with the Securities Division of the Office of the Secretary of the Commonwealth of Massachusetts regarding allegations that RBC CM charged unreasonable commission for certain equity transactions, and did not reasonably supervise these transactions in violation of § 204(a) (2)(J) of the Massachusetts Uniform Securities Act. RBC CM agreed to pay restitution in an amount no less than $113,295.06, plus 6% compounded interest, to affected Massachusetts customers. RBC CM also agreed to provide restitution, plus 6% compounded interest, to affected customers of other jurisdictions that agree to the terms of an agreement (“Term Sheet”) between RBC CM and a multi-state group, including Massachusetts, executed contemporaneously with the Settlement. RBC CM agreed to pay an administrative fine in an aggregate amount not to exceed $1,095,000 to the jurisdictions agreeing to the terms of the Term Sheet, which includes $25,000 to be paid to Massachusetts. • On August 14, 2024, RBC CM entered into a settlement order with the SEC in connection with RBC CM’s recordkeeping practices concerning business-related electronic communications sent or received by firm personnel using non-approved channels or methods (“off-channel communications”). The SEC found that from at least June 2019 to August 2024, RBC CM willfully violated Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder in connection with RBC CM’s failure to maintain and preserve the substantial majority of off-channel communications of its personnel that were records required to be maintained under Exchange Act Rule 17a-4(b)(4) and/or Advisers Act Rule 204-2(a)(7); and therefore, failed to reasonably supervise its personnel within the meaning of Section 15(b)(4)(E) of the Exchange Act and Section 203(e)(6) of the Advisers Act. RBC CM admitted to the facts in the settlement order and acknowledged its conduct violated the federal securities laws. The SEC ordered RBC CM to cease and desist from committing or causing any violations and any future violations of Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2 thereunder, censured it for its conduct, ordered it to pay a civil monetary penalty in the amount of $45,000,000, and ordered it to comply with the undertakings enumerated in the settlement order. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 27 of 35 26-25-5088800_25213-AS (09/26)  • RBC CM consented to FINRA sanctions and findings that its supervisory system did not provide certain customers with mutual fund sales charge waivers and fee rebates to which they were entitled through rights of reinstatement offered by mutual fund companies, which resulted in the payment of $264,939.44 in excess sales charges and fees by eligible customers. On July 2, 2024, RBC CM was censured, fined $75,000 and required to certify that it had remediated the issues and implement reasonably designed supervisory system, including written supervisory procedures (“WSPs”). The firm also made full restitution, plus interest, to the affected customers. • RBC CM consented to FINRA sanctions and findings that it sent trade confirmations to customers that contained inaccurate information. The findings stated that the firm sent its institutional customers confirmations for fixed income transactions, including certain municipal securities transactions, that inaccurately stated that the transactions were executed in an agency capacity, when they were executed in a principal capacity. The firm also sent its institutional customers trade confirmations that inaccurately stated that certain transactions that were solicited were unsolicited and vice versa. In addition, the firm failed to deliver trade confirmations to customers that had requested electronic delivery of trade confirmations and failed to send trade confirmations for millions of dividend reinvestment program (“DRIP”) transactions. The findings also stated that the firm failed to establish, maintain, and enforce a supervisory system, including WSPs, reasonably designed to achieve compliance with trade confirmation requirements. The findings also included that the firm violated Regulation T promulgated by the board of governors of the federal reserve system under Section 7 of the Exchange Act by extending credit to certain customers of the firm and its introducing firms, which resulted in hundreds of incorrectly executed trades in those accounts and the frequent selling of the positions at issue to generate proceeds to cover the purchases. In connection with these transactions, customer accounts incurred commissions, markups, markdowns, and fees totaling $392,525.50, that they would not otherwise have incurred had the firm cancelled the trades. In addition, introducing firm customer accounts incurred $1,308 in fees in connection with these trades that they would not have incurred had the firm cancelled the trades. On April 29, 2024, RBC CM was censured, fined $375,000, ordered to pay $393,833.50 in restitution to customers, and required to certify that it has remediated the issues and implemented a supervisory system, including WSPs. • On November 2, 2023, RBC CM entered into a settlement with the SEC resulting in the SEC issuing an order (the “Order”). RBC CM consented to the entry of the Order that found that RBC CM failed to make and keep books, records, and accounts, which, in reasonable detail, accurately and fairly reflected the transactions and dispositions of the assets • of the issuer and failed to devise and maintain a system of internal account controls sufficient to provide reasonable assurance that transactions are recorded to permit preparation of financial statements in conformity with generally accepted accounting principles. The Order directs that RBC CM cease-and-desist from committing or causing any violations and any future violations of Sections 13(B)(2)(A) and 13(B)(2)(B) of the Exchange Act. On November 2, 2023, without admitting or denying the findings, RBC CM consented to the Order and was fined $6,000,0000. • In May 2023, RBC CM entered into a settlement with the Commonwealth of Virginia’s State Corporation Commission’s Division of Securities and Retail Franchising (the “Division”) regarding allegations that it employed an investment adviser representative in the Commonwealth of Virginia without that person being duly registered with the Division, in violation of § 13.1-504 c (ii) of the Virginia Securities Act. RBC CM agreed to pay a $10,000 monetary penalty and $1,000 for the cost of the investigation. • In April 2023, without admitting or denying the findings, RBC CM reached a settlement with FINRA and consented to sanctions and the entry of findings that it failed to establish and maintain a supervisory system reasonably designed to achieve compliance with its suitability obligations in connection with syndicate preferred stock in brokerage accounts. The findings stated that while the firm’s procedures called for supervisors to closely examine representatives’ short-term trading of preferred stocks, the firm’s electronic surveillance of short-term trading in preferred stock was unreasonably designed, and it failed to monitor for that activity. Although the surveillance system had certain alerts that specifically monitored for short-term trading in other products, such as closed-end funds, it did not have any alerts that specifically monitored for short-term trading in preferred stock. The firm also did not have any other alerts that flagged the purchase and sale within 180 days of syndicate preferred stock. Certain of the firm’s registered representatives recommended that a number of the firm’s retail customers purchase syndicate preferred stocks, and then sold the positions within 180 days, and such customers sustained losses on these transactions. The firm earned $653,313 in selling concessions from these syndicate purchases and $128,643 in sales commissions from the subsequent sales. The firm conducted a substantial syndicate preferred stock business yet did not maintain a reasonable supervisory system to monitor whether its representatives recommended short-term trading of syndicate preferred securities that was unsuitable, including for the purpose of capturing sales concessions and commissions. The firm was censured, fined $300,000, ordered to pay $128,643.17, plus interest, in restitution to customers, ordered to pay $653,312.83, plus interest, in disgorgement, and required to certify that it has remediated the issues identified in this AWC and implemented a supervisory system, including WSPs, reasonably designed to achieve compliance with FINRA Rule 3110 regarding the issues identified in this AWC. • On March 3, 2022, RBC CM affiliate and registered investment adviser, CNR, reached a settlement with the SEC concerning CNR’s breach of its fiduciary duty relating to the use of proprietary Funds and certain share classes in advisory accounts. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 28 of 35 26-25-5088800_25213-AS (09/26)  Those Funds generated fees for CNR and its affiliates, rather than competitor funds within the same asset classes that may not have generated such fees and created a conflict that was not disclosed. The SEC determined that CNR willfully violated sections 206(2) and 206(4) of the Advisers Act as well as Rule 206(4)-7 by failing to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. Under the terms of the settlement, CNR paid $30,361,804 in fines, disgorgement, and interest. • Without admitting or denying the findings, RBC CM consented to the sanctions and to the entry of findings that it failed to establish, maintain, and enforce a supervisory system, including WSPs, reasonably designed to achieve compliance with FINRA and Municipal Securities Rulemaking Board (“MSRB”) rules with respect to representatives’ recommendations of high-yield corporate and municipal bonds. The findings stated that the firm’s policies and procedures did not sufficiently address the suitability factors that representatives should consider before recommending high-yield bonds. On December 15, 2021, RBC CM was censured, fined $550,000, and ordered to pay $456,155, plus interest, in restitution to customers. • On September 17, 2021, RBC CM entered into a settlement with the SEC resulting in the SEC issuing an order (the “Order”). RBC CM consented to the entry of the Order which found that from 2014-2017, RBC CM engaged in improper conduct in connection with the allocation, purchase, and sale of certain new issue municipal bond offerings in violation of internal procedures, as well as MSRB and SEC rules. The Order found that RBC CM’s conduct violated MSRB and SEC rules. The Order censured RBC CM and required RBC CM to pay disgorgement of $552,440, prejudgment interest of $160,886.97, and • $150,000 as a civil penalty to the SEC. Such payments were made by RBC CM on September 22, 2021. • The Virginia State Corporation Commission found that, from December 1, 2017, through November 27, 2020, RBC CM employed an investment adviser representative (“IAR”) who was registered in the District of Columbia but not Virginia and that RBC CM failed to enforce its written supervisory procedures regarding IAR registration. On September 8, 2021, RBC CM executed the settlement order which states that RBC CM neither admits nor denies the Virginia state corporation commission’s allegations and paid a $10,000 civil penalty. • It was found by the NYSE that RBC CM violated NYSE Rule 3110(a) and (b) (Supervision) by failing to establish and maintain a supervisory system and WSPs reasonably designed to detect and prevent errors in market on close orders. On July 6, 2021, RBC CM entered into a letter of acceptance, waiver and consent with the NYSE under which RBC CM consented to the sanctions and was censured and fined $10,000. • It was found that RBC CM violated SEC Rule 15c3-5(b) and (c)(1)(ii) and Rules 3.2 and 5.1 of the CBOE BZX Exchange, • Inc., CBOE EDGA Exchange, Inc., CBOE BYX Exchange, Inc., and CBOE EDGX Exchange, Inc. due to the fact that the Firm’s financial risk management controls and supervisory procedures were not reasonably designed to (i) prevent the entry of erroneous orders, (ii) reject orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time, or (iii) reject duplicative orders. On March 30, 2021, without admitting or denying the findings, RBC CM was censured and fined $45,000 by CBOE BZX Exchange, Inc., $45,000 by CBOE EDGA Exchange, Inc., $70,000 by CBOE BYX Exchange, Inc. and $45,000 by CBOE EDGX Exchange, Inc. • The Massachusetts Securities Division found that RBC CM failed to adequately supervise its representatives with respect to concentration and suitability of master limited partnership energy and telecom positions in certain client accounts. On February 2, 2021, without admitting to any supervisory deficiencies, RBC CM agreed to the described sanctions and fines totaling $320,267.41. • Without admitting or denying the findings, on December 15, 2020, RBC CM consented to the sanctions and to the entry of findings that it failed to establish and maintain a supervisory system reasonably designed to supervise representatives’ recommendations to customers to purchase particular share classes of 529 college savings plans. The findings stated that RBC CM did not provide adequate guidance to representatives regarding the importance of considering share class differences when recommending 529 plans and had no procedures requiring supervisors to review 529 plan share class recommendations for suitability. RBC CM updated its procedures to include such a requirement, but the updated procedures failed to adequately instruct supervisors to consider either the age of the beneficiary or the number of years until expected withdrawals, both critical factors in determining the suitability of the recommended share class. Also, RBC CM did not consistently provide supervisors with the information necessary to review the suitability of 529 plan share class recommendations. Later, RBC CM issued a company-wide compliance alert that provided guidance to representatives regarding 529 plan share class recommendations. RBC CM then updated its supervisory systems and procedures with respect to 529 share class recommendations. Among other things, RBC CM instructed supervisors to consider the age of the beneficiary when assessing the suitability of a representative’s 529 share class recommendation. RBC CM has agreed to pay restitution and interest relating to the sale of class C shares to certain 529 plan customers in the estimated amount of $839,803. • The SEC found that from at least July 2012 through August 2017, RBC CM disadvantaged certain retirement plan and charitable organization brokerage customers who maintained accounts at RBC CM (“Eligible Customers”) by failing to ascertain that they were eligible for a less expensive share class and recommending and selling them more expensive RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 29 of 35 26-25-5088800_25213-AS (09/26)  share classes in certain open-end Funds when less expensive share classes were available. RBC CM did so without disclosing that it would receive greater compensation from the Eligible Customers’ purchases of the more expensive share classes. Eligible Customers did not have sufficient information to understand that RBC CM had a conflict of interest resulting from compensation it received for selling the more expensive share classes. Specifically, RBC CM recommended and sold these Eligible Customers class A shares with an up-front sales charge, or class B or class C shares with a back- end contingent deferred sales charge (a deferred sales charge the purchaser pays if the purchaser sells the shares during a specified time period following the purchase) and higher ongoing fees and expenses, when these Eligible Customers were eligible to purchase load-waived class A and/or no-load class R shares. RBC CM omitted material information concerning its compensation when it recommended the more expensive share classes. RBC CM also did not disclose that the purchase of the more expensive share classes would negatively impact the overall return on the Eligible Customers’ investments, in light of the different fee structures for the different fund share classes. In making those recommendations of more expensive share classes while omitting material facts, RBC CM violated sections 17(a)(2) and 17(a)(3) of the Securities Act. These provisions prohibit, respectively, in the offer or sale of securities, obtaining money or property by means of an omission to state a material fact necessary to make statements made not misleading, and engaging in a course of business which operates as a fraud or deceit on the purchaser. As a result of the conduct described above, RBC CM willfully violated sections 17(a)(2) and 17(a)(3) of the Securities Act. On April 24, 2020, RBC CM was censured and paid disgorgement of $2,607,676, prejudgment interest of $631,331, plus a civil monetary penalty of $650,000. • Without admitting or denying the findings, RBC CM consented to the sanctions and the entry of findings that RBC CM entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of RBC CM. The findings state that RBC CM ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In addition, for the calendar year 2018 RBC CM conducted 11 of 12 monthly origin code reviews late because RBC CM failed to enforce its procedures requiring timely origin code reviews. Between August 28, 2019, • and October 2, 2019, RBC CM settled for a total of $100,000 across eight exchanges (NASDAQ PHLX LLC $7,138; NASDAQ Stock Markets/The NASDAQ Options Market $5,687; CBOE BZX Exchange, Inc. $28,271; NASDAQ ISE, LLC Fine $6,721; NYSE American LLC $4,098; NYSE ARCA, Inc. $5,509; CBOE Exchange, Inc.: $36,592; and CBOE C2 Exchange, Inc., $5,984). • FINRA found that from March 2008 to June 2016, RBC CM failed to make the statutorily required delivery of prospectuses to customers who purchased approximately 165,000 ETFs and notes and hundreds of thousands of open-end and closed- end mutual funds. RBC CM failed to design, implement, and enforce a reasonable supervisory system, procedures and set of controls to comply with prospectus delivery rules for Funds and as a result, failed to discover the delivery failures until FINRA’s investigation into the matter. On October 17, 2019, RBC CM was censured and fined in the amount of $2,900,000. • RBC CM self-reported to the SEC the violations described below pursuant to the Division of Enforcement’s Share Class Selection Disclosure Initiative (“SCSD Initiative”). The SEC found that RBC CM, during the period of January 1, 2014, through March 27, 2017, failed to make adequate disclosures, in its Form ADV or otherwise, regarding its Fund share class selection practices, and the 12b-1 fees it received, in connection with advisory account transactions. Specifically, at times during the relevant period, RBC CM purchased, recommended, or held in advisory accounts Fund share classes that charged 12b-1 fees instead of lower cost share classes in the same fund. The SEC found that RBC CM failed to adequately disclose the receipt of the 12b-1 fees and the associated conflict of interest, thereby willfully violating Sections 206(2) and 207 of the Advisers Act. On March 11, 2019, without admitting or denying the findings, the SEC issued, and the firm consented to the entry of an order (the “Order”) that censured RBC CM and directs it to cease-and-desist from committing or causing any violations and any future violations of Sections 206(2) and 207 of the Advisers Act. Additionally, the Order requires Respondent to pay disgorgement of $10,494,813.38, prejudgment interest of $1,220,581.34, and to comply with the other undertakings enumerated in the Order as part of the settlement. Other Financial Industry Activities and Affiliations Broker-Dealer Registrations RBC CM is registered with the SEC as a broker-dealer and investment adviser. Certain of RBC CM’s management personnel and all of its Financial Advisors and their supervisors are registered with FINRA as representatives of RBC CM in its capacity as a broker- dealer. Further, RBC CM is a member of the NYSE, FINRA, SIPC, and several other exchanges and self-regulatory organizations. Futures/Commodities-Related Registrations RBC CM is also registered with the Commodity Futures Trading Commission (“CFTC”) as a futures commission merchant and swap firm. Material Relationships with Related Persons RBC C&C provides clearing and custodial services on a fully disclosed basis to broker dealers and registered investment advisers, including your Investment Adviser, who are charged fees based on their use of these services. We, in our capacity RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 30 of 35 26-25-5088800_25213-AS (09/26)  as broker dealer and investment adviser, are routinely engaged in various securities transactions and trading activities for various clients and customers (in addition to you) which could create conflicts of interest among our duties to you and our duties to other clients and customers. In addition to sponsoring the Programs, RBC CM sponsors other non-wrap investment advisory programs available to our clients and engages in a broad range of brokerage and other financial services. These services include public and private investment banking and underwriting, retail and institutional brokerage and trading, institutional research and numerous other brokerage, advisory and financial services. Clients of RBC CM may include Investment Managers and Overlay Managers available in the Programs. We have multiple affiliated entities engaged in many different business activities. The business interests of our affiliates may not align with the interests of our brokerage services. Consequently, our firm may be subject to pressure from our affiliates to protect their business interests. This pressure creates a conflict of interest because it incentivizes us to make certain products and services available to you in a manner which best protects those business interests. Nonpublic Information In the course of our respective investment banking or other activities, we and our affiliates may, from time to time, acquire confidential or material nonpublic information about corporations or other entities or their securities that may prevent us or them, for a period, from purchasing or selling particular securities in your Program account. We and our affiliates will not be permitted to divulge or to act upon any such information with respect to our or our affiliates’ advisory or brokerage activities, including activities with regard to your Program account. RBC GAM – U.S. RBC GAM – U.S. is an affiliate of RBC CM. RBC GAM – U.S. is a federally registered investment adviser that provides portfolio management services to institutional separate accounts, registered investment companies, pooled vehicles, and portfolio management services for wrap fee accounts and Model Portfolios offered by other Providers. RBC CM makes RBC GAM – U.S. available as an Investment Manager in the Consulting Solutions Program and as a Model Provider in RBC UP. In the Cash Sweep Program, you may have a balance in the RBC BlueBay U.S. Government Money Market Fund-Institutional Investor Class 2 (TIMXX) or the RBC BlueBay U.S. Government Money Market Fund-Investor Class (TUIXX), both managed by RBC GAM – U.S. A lower cost share class of the same RBC BlueBay U.S. Government Money Market Fund (TUGXX) is also available outside of the Cash Sweep Program. TUGXX is subject to eligibility requirements for Retirement Accounts. For amounts invested in shares of the RBC GAM – U.S. managed money market fund, our affiliate RBC GAM – U.S. will receive fees for managing and servicing the fund. RBC GAM – U.S. will also pay RBC CM 12b-1 fees, which provides us with another incentive to use this money market fund instead of another fund that does not pay us the same or any revenue share. We address this conflict of interest by proper disclosure. RBC Rochdale RBC Rochdale is a subsidiary of CNB. RBC Rochdale is a federally registered investment adviser that provides investment management services to high-net-worth individuals, families, and foundations. RBC Rochdale may also serve as investment adviser and/or sub-adviser to Funds that RBC CM may recommend. This is a conflict of interest as we are incented to make available Funds subadvised by RBC Rochdale or third-party Funds sub-advised by RBC Rochdale. This conflict of interest is addressed by proper disclosure and by rebating or not charging certain fees to Retirement Accounts in Consulting Solutions and RBC UP. RBC USA Holdco Corporation RBC CM, RBC GAM – U.S. and CNB are wholly-owned subsidiaries of RBC USA Holdco Corporation, which is a wholly owned indirect subsidiary of RBC. RBC Global Asset Management (UK) Limited GAM UK is a wholly owned indirect subsidiary of RBC and an affiliate of RBC CM. GAM UK serves sub-adviser to certain U.S. registered Funds for which RBC GAM – U.S. or other third parties serve as the investment adviser. Such Funds may be recommended by RBC CM. This is a conflict of interest as we have an incentive to recommend Funds that are sub-advised by our affiliates over other products. To the extent permitted by applicable law, this conflict is addressed by proper disclosure and by not assessing the Program Sponsor Fee or the Overlay Manager Fee component of the Program Fee, when RBC CM acts as Overlay Manager, to the value of these Funds held in Consulting Solutions and RBC UP Retirement Accounts. In addition, RBC CM makes GAM UK available as a Model Provider in RBC UP. Trust and Estate Settlement Services Clients can select CNB, a nationally chartered bank and trust company, or its subsidiary RBC Trust Company (Delaware) Limited (“RBC Trust”), a Delaware chartered trust company, as professional trust and estate settlement service providers. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 31 of 35 26-25-5088800_25213-AS (09/26)  RBC CM and its Financial Advisors are generally prohibited from serving as trustees. Clients can also select TrustCorp America (“TCA”), a Washington, D.C. chartered trust company, as a professional trust and estate settlement service provider. RBC CM has a minority interest in TCA. Cash Sweep Program RBC CM and Affiliated Banks receive financial benefits in connection with Cash Sweep Options managed or held by such Affiliated Banks. See Item 4, “Cash Balances and the Cash Sweep Program” for a description of the Cash Sweep Options and related conflicts of interest. Lending Programs Royal Bank of Canada and RBC Bank receive financial benefits in connection with Lending Programs managed or held Royal Bank of Canada and RBC Bank. See Item 4, “Securities-Based Lending” for a description of the Lending Programs and related conflicts of interest. Other Material Relationships Marketing and Operational Support Payments RBC CM receive cash payments and/or other financial benefits from certain Funds, ETPs, UITs, Alternative Investments, insurance companies, Investment Managers, Model Providers, and/or Envestnet (“Marketing Support”). Marketing Support is used to offset compliance and product management costs, for training and education programs, due diligence meetings, conferences, and/or to provide our employees with business entertainment, expense reimbursement for travel associated with these meetings and conferences, financial assistance in covering the cost of certain marketing and sales events, and small gifts. RBC CM’s existing or prospective clients also receives related financial benefits, such as seminars, education programs and small gifts. Marketing Support cash payments received by RBC CM vary and may be paid based on a percentage of client assets in certain securities or investment products, and/or based on a flat dollar amount. RBC CM does not receive payments from mutual fund companies based on a percentage of mutual fund assets held in retirement advisory accounts. RBC CM receives payments from certain Fund companies which are used in part to offset certain administrative and operational costs that RBC CM incurs in connection with providing certain sub-accounting and sub-transfer agent services in distributing Funds and provides a financial benefit to RBC CM (“Operational Support”). These costs include sending shareholder statements, maintaining shareholder records, and performing regulatory mailings. RBC CM rebates Operational Support payments received from mutual fund companies to clients with discretionary retirement accounts. Marketing Support and/or Operational Support payments create a conflict of interest because we are incentivized to utilize companies and recommend securities and investment products for which we earn greater compensation over companies, securities, and investment products that do not make such payments. We address this conflict through disclosure and by selecting companies, securities and investment products based on merit, qualitative and quantitative evaluations, performance, and risk management practices and not based on the amount of revenue we receive. In general, Funds and ETPs of companies that make Marketing Support and/or Operational Support payments to RBC CM have higher expense ratios than Funds and ETPs of companies that do not make such payments. The receipt of Marketing Support and/or Operational Support payments from Fund and ETP companies by RBC CM is one of multiple factors that RBC CM considers when deciding which Funds and share classes or ETPs to make available to clients. RBC CM has a conflict of interest in choosing a Fund or an ETP (with higher expense ratios) of companies that make the above-referenced payments to RBC CM for selling/distributing their Funds and/or ETPs. A higher expense ratio will adversely affect investment performance. These conflicts of interest are addressed by appropriate disclosure in this brochure. For a list of Fund families from which RBC CM receives payments described herein, please see “Mutual Fund and ETF Arrangements” at www.rbcclearingandcustody.com/disclosures. Additionally, RBC CM has arrangements with certain donor advised funds for the referral of clients or prospects that have indicated an interest in establishing and maintaining a donor advised fund. Neither RBC CM nor its Financial Advisors receive a referral fee for such arrangement. However, donor advised funds that partner with RBC CM generally invest the referred client assets in Programs that are advised and serviced by the referring Financial Advisor which creates an incentive to refer clients to donor advised funds with which RBC CM has a referral arrangement. We seek to address this conflict of interest through disclosure, and by treating Program assets owned and administered by such donor advised funds and Program assets owned directly by clients as separate and distinct advisory relationships in accordance with all applicable regulatory requirements. Federated Investment Counseling Federated Investment Counseling (including its Federated Hermes CW Henderson division) is an unaffiliated investment adviser registered with the SEC. As of the date of this brochure, Federated Investment Counseling (and one or more of its Investment Strategies and/or Model Portfolios, as applicable) is available for selection as an Investment Manager in Consulting Solutions and as a Model Provider or Investment Manager in RBC UP. In addition, Federated Investment RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 32 of 35 26-25-5088800_25213-AS (09/26)  Management Company is the investment adviser for the only unaffiliated money market fund available as a Cash Sweep Option for advisory clients. The Federated Hermes Treasury Obligations Fund (TOAXX) is the Cash Sweep Option RBC CM makes available to Retirement Accounts enrolled in a Program. Cash balances in accounts managed by Federated Investment Counseling as Investment Manager in Consulting Solutions or invested in a Federated Investment Counseling Model Portfolio or Investment Strategy in RBC UP, will be invested in any such client’s selected Cash Sweep Option, which may be the Federated Hermes Treasury Obligations Fund (TOAXX). As discussed in Item 4, clients pay the Program Fee on the total value of the assets in their Program account, including cash balances. As a result, you should be aware that if Federated Investment Counseling is the discretionary Investment Manager for your Consulting Solutions account or RBC UP account Sleeve, or the Model Provider that delivers its Model Portfolio in which your RBC UP account is invested, you will pay Federated Investment Counseling advisory fees on all assets, including cash balances. If the Cash Sweep Option for your Program account is the Federated Hermes Treasury Obligations Fund (TOAXX), you will also pay Federated Hermes applicable money market mutual fund fees and expenses on these same cash balances, as described above in the section titled “Cash Balances and the Cash Sweep Program.” Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics and Personal Trading RBC CM has adopted an Investment Adviser Code of Ethics (the “IA Code of Ethics”) in accordance with Rule 204A-1 of the Advisers Act, which applies to all RBC CM employees, contingent workers, contract workers and interns (“Covered Persons”), with limited exceptions. The IA Code of Ethics sets forth the standards of business conduct applicable to RBC CM and its Covered Persons (i.e., to act with integrity, honesty, and professionalism and to always act in the best interests of our clients) and is designed to ensure that RBC CM and its Covered Persons comply with applicable federal and state securities laws and regulations. The IA Code of Ethics also highlights that as an investment adviser and fiduciary, RBC CM and its Covered Persons have an affirmative duty to always act in the best interest of our advisory clients, which means their interests must always come first. This means that when acting in an investment advisory capacity, Covered Persons are responsible to: (i) put client interests before their own; (ii) act with utmost good faith; (iii) provide full and fair disclosure of all material facts; (iv) not mislead clients; and (v) disclose all potential, perceived, and/or actual conflicts of interest to clients. The IA Code of Ethics also includes guidelines regarding personal securities transactions of, and the maintenance of personal securities accounts by, its Covered Persons (with the exception of interns) in accordance with RBC CM’s policies on outside securities accounts, and employee/employee-related accounts. More specifically, the IA Code of Ethics outlines RBC CM’s requirements contained in such policies, including that Covered Persons and their immediate family members (i) maintain their personal securities accounts and accounts in which they have a beneficial interest at RBC CM, unless RBC CM has given its prior express written permission to open and/or maintain an account outside of RBC CM, (ii) report their personal securities transactions and holdings to RBC CM, and (iii) obtain pre-approval for investments in private placements and initial public offerings, among others. In addition, the IA Code of Ethics also contains information on standards relating to prohibited and illegal activities associated with the possession of material information (e.g., further disclosure, trading), the administration and enforcement of the IA Code of Ethics, and maintenance of certain records relating to the IA Code of Ethics. As part of RBC CM’s annual Compliance questionnaire process, Covered Persons are required to certify to their receipt and review of, and compliance with, the IA Code of Ethics. A copy of the IA Code of Ethics is available to clients or prospective clients upon request. Participation or Interest in Client Transactions As a full-service broker-dealer, on an ongoing basis and as permitted by applicable law, we may, when appropriate: • act as broker or agent, effect securities transactions for compensation for you; • make available to Investment Adviser securities or investment products in which we or a related person or a family member of an employee has some financial interest; • buy or sell for ourselves securities that we also make available to Investment Adviser; or • sell or convert Fund shares or other unbilled assets, which will subject proceeds to the Program Fee. We have adopted internal policies and procedures with respect to conflicts of interest between us and our clients. Pursuant to these policies and procedures, we, when engaging in the activities enumerated above, treat your orders fairly and do not give our own orders preference over your orders. As required by applicable law and/or exchange rules, including, but not limited to, the Advisers Act, we obtain the consent of affected clients in advance of any transactions in which we will be engaging in the activities referenced above. When we engage in the activities mentioned above, all statements and/ or confirmations of such transactions contain the disclosures required by applicable law and exchange rules. Securities activities are monitored daily to detect and prevent employees from trading ahead of client accounts. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 33 of 35 26-25-5088800_25213-AS (09/26)  RBC CM and its affiliates are not obligated to affect any transaction that they believe would violate federal or state law, or the regulations of any regulatory or self-regulatory body. RBC CM or its Affiliate(s) in Underwriting Syndicate; RBC WM Distribution of Securities If RBC CM or its affiliate(s) is a member of the underwriting syndicate from which a security is purchased by an unaffiliated Investment Manager, and allocated to your account, we or our affiliates could directly or indirectly benefit from such purchase. If RBC CM participates in the distribution of new issue securities that are purchased for a client’s account by an unaffiliated Investment Manager, RBC CM will receive a fee to be paid by the issuing corporation to the underwriters of the securities and ultimately to RBC CM, which will be deemed additional compensation to us, if received by us. Agency Cross Transactions Agency cross trades and internal cross trades are generally prohibited for Program accounts. Best Execution It is the duty of the entity with brokerage discretion under a Program to seek the best net price and execution on securities trades for client accounts. If we sell a security to you or buy a security from you, we will use all reasonable efforts to ensure that you obtain the best net price and execution on the purchase or sale based on prevailing inter-dealer market prices. In some circumstances, the change in market price may result in financial benefit to us. We may consider it appropriate to use our own execution services to effect purchases and sales of securities for investment advisory clients. We may receive brokerage commissions in connection with such transactions and, in accordance with Section 11(a) of the Exchange Act, may execute transactions for investment advisory accounts over which we have discretion on the floors of securities exchanges of which we are a member. Mark-ups and mark-downs charged by a dealer unaffiliated with us may be included in the price of certain transactions. Payment for Order Flow, Order Routing and Rebates For options orders, we receive payments in the form of rebates and credits. We receive payments from option market centers in return for routing exchange-listed equity and index options orders to those centers when the rebates and credits we receive from those centers are in excess of the fees that those centers charge us for such orders. Any remuneration that we receive for directing options trades to any market center will not accrue to your account. RBC CM contracts with a third- party vendor, to provide execution metrics that RBC CM uses to evaluate execution quality across various markets and firms. These payments for order flow create a conflict of interest for RBC CM as it incentivizes us to route orders to the market center that pays the most. RBC CM mitigates this conflict by making routing decisions based on the quality of execution and not payment for order flow, and by ensuring payment rates do not differ between market centers and not sharing these payments with the Investment Adviser or those involved with the execution of the order. We also mitigate these conflicts by disclosing them to you and by establishing policies and procedures that limit the value, frequency, and nature of these types of incentives. For information with respect to RBC’s handling of customer orders, see “SEC Order Handling Disclosures” at www.rbcclearingandcustody.com/disclosures. You can request a written copy of this information from your Investment Adviser. Trade Errors From time to time, inadvertent administrative errors may occur in processing transactions, resulting in one or more erroneous securities transactions for a client’s account. If this occurs in an account, the error will be corrected, and the account will be restored to the same economic position had the error never occurred. Through this process, a profit may be realized, or a loss suffered in connection with correcting this error. Neither losses nor gains realized will be passed on to the client. RBC CM will retain amounts remaining after errors are corrected. As a result, trade corrections can result in financial benefit to RBC CM or its affiliated broker dealers. Trade Aggregation and Allocation In addition, the Overlay Managers have discretion to aggregate orders into a block trade and execute at an average price. Depending on the size of these orders and the liquidity of the individual security, the execution of the block may occur over more than one day. Review of Accounts When you open a Program account, your Investment Adviser (and its applicable personnel) are responsible for reviewing your account(s) to confirm that the account type, the Program and the investment strategy approach are suitable and appropriate based on your financial (and other relevant) circumstances, investment objectives, risk tolerance, and any other information you have provided for your account. As a Program client paying a fee to receive investment advice and services, your Investment Adviser is responsible for conducting periodic reviews of your account(s) to ensure consistency with your best interest, Advisory Risk Profile and overall situation. RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document Page 34 of 35 26-25-5088800_25213-AS (09/26)  It is your sole responsibility to ensure that the information you provide for your Program account(s) is, and continues to be, complete and accurate and to notify your Investment Adviser promptly of any changes. This includes, but is not limited to, information regarding your financial circumstances, investment objectives, and risk tolerance. Reports to Program Clients RBC CM will provide you with the following trade confirmations and account statements: • trade confirmations reflecting all transactions effected with or through us (other than cash sweep transactions) unless designated otherwise by you, in accordance with applicable law, rules and regulations; and • Periodic account statements as described in your Client Account Agreement. In the Advisory Agreement, you will elect whether you wish to receive trade confirmations on a daily or monthly basis for your account(s). At any time, you may request a copy of the trade confirmation for transactions that appear on the monthly transaction summary statement, as well as any subsequent transaction, or previous transaction effected through RBC CM at no additional cost. If you or RBC CM terminate a Program account, RBC CM will revert the frequency of trade confirmations to daily. Financial Information We are not required to include a balance sheet in this brochure because we do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. We do not have any financial conditions that are reasonably likely to impair our ability to meet our contractual commitments to clients. RBC CM and their predecessors have not been the subject of a bankruptcy petition during the past 10 years. Page 35 of 35 RBC Clearing & Custody (Registered Investment Adviser) Advisory Programs Disclosure Document © 2026 RBC Capital Markets, LLC, registered investment adviser and Member NYSE/FINRA/SIPC. 26-25-5088800_25213-AS (09/26) 

RBC Institutional Consulting Program Form ADV, Part 2A: Firm Brochure September 30, 2026 This firm brochure provides information about the qualifications and business practices of RBC Wealth Management (“RBC WM”), a division of RBC Capital Markets, LLC (“RBC CM”). If you have any questions about the contents of this brochure, please contact us at (800) 759-4029. 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. Additional information about RBC CM and RBC WM also is available on the SEC’s website at www.adviserinfo.sec.gov. Registration with the SEC does not imply a certain level of skill or training. RBC Wealth Management 250 Nicollet Mall | Minneapolis, MN 55401-1931 (800) 759-4029 | www.rbcwealthmanagement.com PLEASE RETAIN A COPY OF THIS DOCUMENT FOR YOUR RECORDS Investment and insurance products offered through RBC Wealth Management are not insured by the FDIC or any other federal government agency, are not deposits or other obligations of, or guaranteed by, a bank or any bank affiliate, and are subject to investment risks, including possible loss of the principal amount invested. © 2026 RBC Wealth Management, a division of RBC Capital Markets, LLC, registered investment adviser and Member NYSE/FINRA/SIPC. All rights reserved. 26-25-5088800_25264 (09/26) HNW_NRG_B_Inset_NoMask ITEM 2: MATERIAL CHANGES This section discusses the material and other important changes made to this Form ADV brochure since it was last amended on March 31, 2026. Clients are encouraged to review this brochure carefully, in its entirety. For more details on any specific update, please see the item in this brochure referred to in the summary below. • The following section was added to Item 4: Advisory Business, subsection B. RBC Institutional Consulting Advisory Services Offered: Annuity Marketplaces RBC WM has no authority over or responsibility for any annuity marketplaces offered within a retirement plan and/or held by a client and will not provide any recommendations or ongoing monitoring of the prudence or appropriateness of annuity marketplaces as a plan participant distribution option. If you hold an annuity marketplace in your account serviced by RBC WM, you acknowledge and understand that annuities are complicated, complex products that are subject to limited liquidity, market risk, inflation risk, and fees, charges and other expenses. RBC Institutional Consulting Program Disclosure Document Page 2 of 20 26-25-5088800_25264 (09/26)  ITEM 3: TABLE OF CONTENTS ITEM 2: MATERIAL CHANGES ........................................................................................................................................................... 2 ITEM 4: ADVISORY BUSINESS .......................................................................................................................................................... 4 A. About RBC Capital Markets ...............................................................................................................................................................4 B. RBC Institutional Consulting Advisory Services Offered ................................................................................................................4 C. How we Tailor our Advisory Services ................................................................................................................................................ 7 D. Wrap Fee Programs ............................................................................................................................................................................ 7 E. Assets Under Management ................................................................................................................................................................8 ITEM 5: FEES AND COMPENSATION ................................................................................................................................................. 8 A. Program Fees ......................................................................................................................................................................................8 B. Billing Practices ..................................................................................................................................................................................8 C. Fees/Other Charges Not Covered by Your Program Fee .................................................................................................................9 D. Termination of Program Agreement ..................................................................................................................................................9 E. Compensation to Financial Advisors .................................................................................................................................................9 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .................................................................................... 10 ITEM 7: TYPES OF CLIENTS ............................................................................................................................................................ 10 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ........................................................................ 10 A. Methods of Analysis and Investment Strategies ........................................................................................................................... 10 B. Risks of Loss ....................................................................................................................................................................................... 11 ITEM 9: DISCIPLINARY INFORMATION............................................................................................................................................13 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .......................................................................................17 A. Broker Dealer Registration ..............................................................................................................................................................17 B. Commodity Futures Registration .....................................................................................................................................................17 C. Material Relationships with Related Persons .................................................................................................................................17 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING .......................18 A. Code of Ethics and Personal Trading .............................................................................................................................................. 18 B. Participation or Interest in Client Transactions and Personal Trading ....................................................................................... 18 ITEM 12: BROKERAGE PRACTICES ................................................................................................................................................. 19 ITEM 13: REVIEW OF ACCOUNTS .................................................................................................................................................... 19 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ......................................................................................................... 19 ITEM 15: CUSTODY ......................................................................................................................................................................... 20 ITEM 16: INVESTMENT DISCRETION .............................................................................................................................................. 20 ITEM 17: VOTING CLIENT SECURITIES ........................................................................................................................................... 20 ITEM 18: FINANCIAL INFORMATION ............................................................................................................................................... 20 RBC Institutional Consulting Program Disclosure Document Page 3 of 20 26-25-5088800_25264 (09/26)  ITEM 4: ADVISORY BUSINESS A. About RBC Capital Markets RBC Capital Markets, LLC (“RBC CM”) is an indirect, wholly owned subsidiary of the Royal Bank of Canada (“RBC”), a publicly held and global, integrated investment services firm and one of the world’s largest financial services firms. Founded in 1909, RBC CM is a registered investment adviser and broker-dealer with the U.S. Securities and Exchange Commission (“SEC”) and a member of the Financial Industry Regulatory Authority (“FINRA”), the New York Stock Exchange (“NYSE”), and other major securities exchanges. RBC CM, through its RBC Wealth Management (“RBC WM”) division, offers clients (“you” or “your”) products and services, including financial planning and portfolio management, in its capacity as investment adviser and as sponsor of various wrap fee programs, as well as offering the institutional consulting services described in this brochure. For purposes of this brochure, RBC WM and RBC CM will be collectively referred to as “RBC WM,” the “Firm,” “we,” “us,” or “our.” This brochure provides information about RBC WM and the RBC Institutional Consulting Program (the “Program”) it offers through its “Financial Advisors” (each, a “Financial Advisor”). Information about the other advisory and wrap fee programs offered by RBC WM, including Wrap Fee Advisory Programs, Clearing and Custody Advisory Programs, and Financial Planning, is contained in separate ADV brochures which are available upon request, from your Financial Advisor, or at the SEC’s website: www.adviserinfo.sec.gov. B. RBC Institutional Consulting Advisory Services Offered Through the Program, RBC WM offers clients non-discretionary advisory and consulting services (“Non-Discretionary Services,” each, a “Non-Discretionary Service”) and discretionary advisory and consulting services (“Discretionary Services,” each, a “Discretionary Service”) (collectively, the “Services”) that are available for selection by you. This brochure describes the Services offered in the Program, along with the features and fees, and provides you with information that should be reviewed and considered before deciding to enroll in the Program. To enroll in the Program, clients are required to enter into a written investment advisory agreement with RBC WM known as the “RBC Institutional Consulting Program Agreement and Disclosure” (hereinafter, the “Program Agreement”). The Program offers a range of Services, as described below, and is generally available to both non-retirement plan and retirement plan clients, including employer-sponsored retirement plans, trusts, businesses, endowments, foundations, health savings account sponsors, and other suitable investors. A retirement plan is any “employee pension benefit plan” as defined in section 3(2) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and includes, for example, defined benefit pension plans, money purchase pension plans, cash balance plans, 401(k) plans, profit sharing plans, governmental plans and certain 403(b) plans. In the Program Agreement, you will be presented the range of available Services offered through the Program, and you will select the Service(s) you would like RBC WM to perform, subject to eligibility requirements and mutual agreement by us. When you participate in the Program, we are a fiduciary to you under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). As a fiduciary, we will act in your best interest and seek to provide you access to material facts and information relating to the Program and Services including by providing this brochure, and material and other updates thereto, to meet our disclosure obligations. In addition, we reasonably expect to provide the investment advisory services in the Program as a “fiduciary” (as that term is defined in Section 3(21)(A) of ERISA, and/or Section 4975 of the Internal Revenue Code of 1986, as amended (the “Code”), with respect to Non-Discretionary Services and advice to retirement plans (as described under “Non-Discretionary Services” below). When providing Discretionary Services to retirement plans subject to ERISA (as described under “Discretionary Services” below), we provide the relevant Discretionary Services as an “investment manager” as that term is defined in Section 3(38) of ERISA. Certain defined contribution retirement plan clients that meet eligibility requirements may elect to participate in the “Group Retirement Plan.” If you participate in the Group Retirement Plan, RBC WM takes on the role of 3(38) fiduciary in lieu of the Financial Advisor. Thus, clients in the Group Retirement Plan will receive certain Discretionary Services from RBC WM, as well as certain Non-Discretionary Services from a Financial Advisor upon client request to their Financial Advisor. Non-Discretionary Services The Non-Discretionary Services, described below, are available for selection to all clients in the Program, including Group Retirement Plan clients, unless noted otherwise. If you elect to receive any of the Non-Discretionary Services in the Program Agreement, subject to RBC WM’s mutual agreement to provide said Non-Discretionary Service(s), you are under no obligation to take any action in response to the non-discretionary advice provided by RBC WM. Although we provide guidance and recommendations, you retain final decision-making authority. Further, should you choose to implement any recommendations made by RBC WM, you are under no obligation to do so through or with us. RBC Institutional Consulting Program Disclosure Document Page 4 of 20 26-25-5088800_25264 (09/26)  Plan Services and Expense Review If selected by you, RBC WM will assist with the review of various fees and plan expenses related to the services provided by the retirement plan, including the overall assessment of current services and expenses, as well as a comparison of such services and expenses to those incurred by other retirement plans of similar size and composition. RBC WM will also assist in reviewing utilization of plan features by participants, including a comparison to other plans of similar size and composition. Provider Search and Evaluation If selected by you, RBC WM will assist you in reviewing and evaluating service providers, including recordkeepers, third-party administrators, trustees, custodians, and/or participant education providers. RBC WM will apply criteria provided by you to identify and present potential service providers, coordinate the solicitation of quotes from service providers, issue requests for proposals (“RFPs”) on behalf of the Client, and evaluate RFPs received from prospective service providers. Client will be responsible for selection and engagement of any service providers. Investment Policy Statement If selected by you, RBC WM will assist you in the development, preparation, and periodic review of an investment policy statement (“IPS”), which covers investment selection and review criteria. RBC WM will assist with identifying the categories or asset classes of investments to be made available and provide guidance for the monitoring and evaluation of the performance of the investments and investment managers. You will be responsible for final approval and ongoing adherence to the IPS. If you are enrolled in Group Retirement Plan, we will provide you with our template IPS. You are not required to utilize the template IPS provided, but must verify that your IPS is consistent with the screening processes described in the RBC WM IPS template. Asset Allocation If selected by you, RBC WM will review your asset allocation and, as appropriate, make asset allocation recommendations in accordance with information provided to RBC WM including, but not limited to, stated investment objectives, risk tolerance, and liquidity requirements. You will be solely responsible for the accuracy of the information provided to RBC WM. This Non-Discretionary Service is not available to clients enrolled in Group Retirement Plan or who are receiving Discretionary Services. Selection of Third-Party Investment Managers In limited circumstances, you may request that your Financial Advisor recommend suitable investment alternatives, including the recommendation of one or more suitable third-party investment manager(s), as appropriate. This Non-Discretionary Service is not available to clients enrolled in the Group Retirement Plan or who are receiving Discretionary Services. Investment Monitoring and Evaluation If selected by you, RBC WM will provide ongoing monitoring and evaluation of your investment options, including customized investment reports which will provide the following information, as applicable: analysis of the investment style characteristics for each investment relative to peers and an applicable index; analysis of risk and return for each investment relative to its peers and an applicable index; illustration of the investment allocation by asset class, geographic region, sector and industries; and analysis of the operations of the investment, such as expenses, trading frequency, asset concentration, and tenure of key personnel. Investment Search If selected by you, RBC WM will review your current investments, and as appropriate, recommend investment options for inclusion based on information provided by you regarding investment objectives. For each modification to an investment option, RBC WM will identify, and present for your consideration, multiple alternatives that meet your stated investment objectives based on both qualitative and quantitative factors. You will be responsible for the final selection and implementation of investment options. This Non-Discretionary Service is not available to clients who are enrolled in Group Retirement Plan or who are receiving Discretionary Services. RBC Institutional Consulting Program Disclosure Document Page 5 of 20 26-25-5088800_25264 (09/26)  Investment Model Portfolio Consulting In limited circumstances, RBC WM will provide risk-based model portfolio advice. If you select this Non-Discretionary Service, RBC WM will recommend certain investment choices from your investment menu within model portfolios and recommend that you rebalance the models periodically in order adhere to the target asset allocation for each portfolio. Additionally, if requested by you, RBC WM will provide this service and the model portfolios to third- party investment managers and other financial professionals to assist them in managing your accounts. This Non-Discretionary Service is not available to clients who are enrolled in Group Retirement Plan. Responsible Investment Screening In limited circumstances, for clients not subject to ERISA, RBC WM will assist the client with environmental or social screening of investments. This Non-Discretionary Service is not available to clients who are enrolled in Group Retirement Plan or who are receiving Discretionary Services. Education If selected by you, RBC WM will provide the following educational services to ERISA-covered retirement plan sponsors and/or retirement plan participants. • Plan sponsors: RBC WM will provide general education to plan sponsors, regarding topics such as retirement plan administration, fiduciary responsibilities, enrollment procedures, and investment options. • Plan participants: RBC WM will work with you to develop strategies for ongoing participant education and will deliver education to participants on retirement plan features, enrollment procedures and investment options. Upon your request, RBC WM will provide general education seminars to participants on topics such as plan participation, saving for retirement, retirement and distribution planning, and other related topics that RBC WM makes available. Any seminars will be scheduled as mutually agreeable to you and RBC WM. For non-retirement plan clients and retirement plans not covered by ERISA, RBC WM will provide educational services to the client’s employees, business owners, board of trustees, plan participants (as applicable), and/or other relevant parties identified by the client. This assistance can include planning and/or conducting informational, educational meetings or sessions, and providing various written materials. Educational services provided by RBC WM will not include individual investment advice. Discretionary Services Certain defined contribution retirement plan clients that meet eligibility requirements, including clients in the Group Retirement Plan, can elect to receive the following Discretionary Services, in addition to having the ability to select certain Non-Discretionary Services outlined above, as applicable. By selecting Discretionary Services, you appoint RBC WM as investment manager, as defined in Section 3(38) of ERISA, and grant RBC WM investment management discretion over your retirement plan investments. Investment Management If selected by you, RBC WM will provide the selection, ongoing monitoring, removal and replacement of the retirement plan’s designated investment alternatives in a manner consistent with the retirement plan’s investment policy statement. Additionally, RBC WM will select and monitor a default investment option (“DIA”) for the retirement plan, if requested by you. Participant account balances will be invested in the retirement plan’s DIA if a plan participant fails to select an investment under the retirement plan, subject to the retirement plan’s terms. RBC WM will not have discretion over employer stock funds, participant loans, and self-directed brokerage accounts. While RBC WM is granted discretion over the investment lineup, RBC WM may require assistance from the client if the recordkeeper will not implement investment menu changes within a reasonable timeframe. RBC WM does not assume discretion over a plan participant’s investment selection, nor does RBC WM provide fiduciary advice to such participants. Discretionary Model Portfolio Management In limited circumstances, RBC WM will provide risk-based discretionary model portfolio management, and RBC WM will implement certain investment choices from your investment menu within model portfolios. RBC WM will have discretion to rebalance the models periodically in order to adhere to the target asset allocation for each portfolio. While RBC WM is granted discretion over the investment lineup including implementation, RBC WM may require assistance from the client if the retirement plan’s vendor(s) will not implement investment menu changes within a reasonable timeframe. RBC Institutional Consulting Program Disclosure Document Page 6 of 20 26-25-5088800_25264 (09/26)  Limitations on Services The following limitations apply to both the Non-Discretionary and Discretionary Services offered by RBC WM through the Program. Selection of Investment Managers You are responsible for providing a copy of any additional written investment guidelines or restrictions to each investment manager you select and for communicating any material changes in the information provided to the investment managers. Investment managers are selected by you unless RBC WM is providing Discretionary Services. Other than in connection with our consulting responsibilities as described above, we do not assume responsibility for the conduct of investment managers selected by you, including their performance or compliance with law or regulations. Employer Stock Fund RBC WM has no authority over or responsibility for employer stock funds and will not provide any ongoing monitoring of the prudence or appropriateness of employer stock as an investment under a retirement plan. If a retirement plan includes an employer stock fund, you acknowledge and understand that the employer stock fund is not diversified, may be extremely volatile, and may result in large losses. There may be circumstances when investment in employer stock is not prudent and when the lack of diversification is not appropriate. However, RBC WM may provide general education or asset allocation information that may include employer stock fund assets. Digital Assets RBC WM has no authority over or responsibility for any digital assets (i.e., crypto assets, virtual assets, or cryptocurriences) held by a client and will not provide any recommendations or ongoing monitoring of the prudence or appropriateness of digital assets as an investment. If you hold digital assets in your account serviced by RBC WM, you acknowledge and understand that digital assets are complicated, complex products that are subject to extreme volatility, limited liquidity, potential fraud and pose additional risk to investors (i.e., the risk of losing all of your investment is significant). Annuity Marketplaces RBC WM has no authority over or responsibility for any annuity marketplaces offered within a retirement plan and/or held by a client and will not provide any recommendations or ongoing monitoring of the prudence or appropriateness of annuity marketplaces as a plan participant distribution option. If you hold an annuity marketplace in your account serviced by RBC WM, you acknowledge and understand that annuities are complicated, complex products that are subject to limited liquidity, market risk, inflation risk, and fees, charges and other expenses. Affiliated and Proprietary Investments With respect to retirement plans clients (including those subject to ERISA), RBC Global Asset Management (U.S.) Inc. (“RBC GAM – U.S.”), RBC Rochdale, LLC (“RBC Rochdale”) Funds, or other RBC WM affiliated funds present a conflict of interest when held by clients enrolled in the Program. RBC WM proprietary or affiliated investment options may be required to be sold or liquidated within a reasonable time frame in order to avoid conflicts of interest. RBC WM mitigates the conflict of interest by excluding the value of those funds when assessing the RBC WM Program asset-based fee. Tax, Accounting and Legal Considerations You understand that neither RBC WM nor its affiliates or employees provide legal, accounting or tax advice. All legal, accounting or tax decisions regarding your accounts and any transactions or investments entered into in relation to such accounts, should be made in consultation with your independent advisors. No information, including but not limited to written materials, provided by RBC WM or its affiliates or employees should be construed as legal, accounting or tax advice. C. How we Tailor our Advisory Services RBC WM tailors Services in the Program to the individual needs of Program clients. Based on the information you provide to us, your Financial Advisor will work with you to select a suite of Services tailored to your objectives, goals, and circumstances and any other reasonable restrictions or criteria you may impose. Not all Financial Advisors may offer all Services described above. If your Financial Advisor is not able to offer a particular level of Service, you may be able to participate through another Financial Advisor. D. Wrap Fee Programs Outside of the Program, RBC WM provides portfolio management services, and, in some wrap fee programs we sponsor, our Financial Advisors act as discretionary portfolio managers. We receive a wrap fee for those services and share a portion of RBC Institutional Consulting Program Disclosure Document Page 7 of 20 26-25-5088800_25264 (09/26)  that fee with Financial Advisors who participate in the wrap fee programs. Details of the programs are available in our Wrap Fee Disclosure Brochure which is available from your Financial Advisor. Our activities as portfolio manager and sponsor of wrap fee programs are separate from our Program Services. The Program does not include the participation in or offering of portfolio management services in wrap fee programs. E. Assets Under Management As of June 30, 2026, we had $345,747,567,752 in assets under management, $263,708,872,591 of which was managed on a discretionary basis and $82,038,695,161 of which was managed on a non-discretionary basis. ITEM 5: FEES AND COMPENSATION A. Program Fees Program Fee The fee that you pay for the Program is negotiable, and the Financial Advisor servicing your account will receive a portion of that fee. The amount of any negotiated fee will depend upon the nature and complexity of your situation and needs, the Services to be performed, and other relevant factors. You may pay higher or lower fees depending on considerations such as the amount of your assets the Financial Advisor is providing Services on, the amount of time you have been a client of ours, the total amount of business you conduct through us, and other relevant criteria. For Services provided under the Program Agreement, excluding clients enrolled in Group Retirement Plan, you may elect to pay us either 1) a negotiated fee based on percentage of assets in the Program; 2) a negotiated one-time flat fee; or 3) an annual flat fee. The maximum asset-based program fee that may be charged to clients in the Program, expressed as an annual rate, is 1.00% for clients with assets equal to or above $1,000,000. For clients with assets below $1,000,000, the maximum Program fee that may be charged to clients is $10,000. Your total cost of each of the Services provided through the Program, if purchased separately, could be more or less than the costs of the Program. Cost factors may include the costs to: • obtain the desired Services; • retain the desired investment manager(s), where applicable; • obtain expertise in selecting and monitoring investment managers and other service providers, where applicable; • obtain consulting services similar to those provided in the Program; and • obtain reports comparable to those provided through the Program. When making cost comparisons, you should be aware that the combination of Services available through the Program may not be available separately or may require multiple accounts, documentation and fees. Group Retirement Plan Fees The fee that you pay for Group Retirement Plan Services is negotiable, and the Financial Advisor servicing your account will receive a portion of that fee. For Non-Discretionary Services provided under the Group Retirement Plan Program Agreement, you can elect to pay either 1) a negotiated fee based on percentage of assets in the Program, or 2) an annual flat fee. This fee is paid to RBC WM and your Financial Advisor. For Discretionary Services, you pay an additional 0.05% fee based on percentage of assets in the Program. This additional fee is not paid to your Financial Advisor. The combined maximum asset- based Program fee that may be charged to clients in the Group Retirement Plan for Discretionary and Non-Discretionary Services, expressed as an annual rate, is 1.00% for clients with assets equal to or above $1,000,000. For clients with assets below $1,000,000, the maximum Program fee that may be charged to clients is $10,000. You may request a brochure that contains more detailed information about the other advisory programs RBC WM offers by contacting your Financial Advisor. B. Billing Practices As directed by you, fees may be billed to you directly, deducted from a separate RBC WM account of yours, or in cases of a retirement plan, fees can be calculated and paid by the plan provider from the assets of, or generated by, the retirement plan. Except in the case of a one-time flat fee, fees are generally payable in advance on a monthly or quarterly basis. Additionally, fees may be payable in arrears on a monthly or quarterly basis. For asset-based fees you will provide us in a timely manner (or will cause any applicable investment manager, record keeper, administrator or custodian to provide in a timely manner) RBC Institutional Consulting Program Disclosure Document Page 8 of 20 26-25-5088800_25264 (09/26)  all information which we may require and request for our calculation of fees. Unless otherwise noted herein, asset-based fees are generally assessed on all client assets in the Program, including securities, cash, and money market balances. One- time flat fees will be billed in their entirety upon completion and delivery of the contracted Services. Program fees include compensation for the Services selected as set forth in the Program Agreement. C. Fees/Other Charges Not Covered by Your Program Fee The Program fees described above cover only the Services provided by us under the Program Agreement for the Program. Any fee payable by you to each selected investment manager or other service provider will be charged by each investment manager or service provider directly to you, and those fees will be in addition to fees and other charges as applicable payable to us. Examples of additional fees paid directly to service providers or investment managers include, but are not limited to, custody fees imposed by other financial institutions, recordkeeping fees, trust fees, plan administration fees, redemption fees and transaction-based charges you may incur by implementing advice received by RBC WM. D. Termination of Program Agreement You may terminate your Program Agreement with us at any time by written notice to us. The Program Agreement will terminate automatically upon our receipt of your written notice of termination. We may terminate the Program Agreement upon written notice to you. Termination of the Program Agreement does not terminate any investment advisory agreement directly between you and any investment manager (if applicable). If you select the one-time flat fee payment method for Services pursuant to the Program Agreement, the Program Agreement will terminate upon the completion and delivery of contracted Services. You will need to execute a new Program Agreement to re-engage us for further Services. You should note that termination will end the investment advisory fiduciary relationship between us and you as it pertains to the terms of the Program. The Program Agreement will no longer apply to this account. Fee Refund If the Program Agreement is terminated prior to the last day of the calendar quarter, a pro rata portion of any fees paid by you based upon the days remaining in the quarter will be refunded as required by law. E. Compensation to Financial Advisors Advisory Fees If you select Services described in this brochure, we pay your Financial Advisor, on an ongoing basis, a portion of the fees payable to us in connection with the Service(s) selected by you. The Financial Advisor may receive different compensation depending on which Service(s) you select. If you select Service(s) described in this brochure, the Financial Advisor has the ability to charge a fee less than the maximum fee stated above. The amount of the fee you pay is a factor we use in calculating the compensation we pay your Financial Advisor. Therefore, Financial Advisors have a financial incentive not to reduce fees. Recruitment RBC WM offers recruiting packages to Financial Advisors joining from other firms. Under these packages, Financial Advisors are eligible for two types of promissory notes in designated amounts. The first note is issued to the Financial Advisor once his or her securities license is transferred to RBC WM. Depending upon the recruiting package, RBC WM will either forgive, or collect, the principal and interest amount of the this note each month, so long as the Financial Advisor remains employed and in good standing for a predetermined period of time. Although there are no set production goals for the note to be forgiven, a Financial Advisor must maintain a certain production to remain employed. Thus, these loans create a conflict of interest because they provide incentives for our Financial Advisors to encourage you to effect more investment transactions and to effect investment transactions in greater amounts, and to recommend products and Services that generate more revenue for us. The second type of note is issuable each year for a fixed number of years if the Financial Advisor meets specified production goals. After issue, depending upon the recruiting package, RBC WM either forgives, or collects, these loans each month so long as the Financial Advisor remains employed and in good standing for a predetermined period of time. This loan also creates a conflict of interest because it provides incentives for our Financial Advisors to encourage you to effect more investment transactions and to effect investment transactions in greater amounts, and to recommend products and Services that generate more revenue for us. We mitigate the recruitment conflicts through disclosure and by subjecting the calculation of promissory notes to applicable laws, including regulations under ERISA and the Code. If the inclusion of certain promissory notes is prohibited by applicable law, then such amounts may be excluded from the calculation of such notes. RBC Institutional Consulting Program Disclosure Document Page 9 of 20 26-25-5088800_25264 (09/26)  Rewards, Incentive Compensation and Bonuses Your Financial Advisor is eligible to qualify for both recognition programs and practice development and training programs. These rewards, such as trips to a specified destination, incentive compensation, such as deferred compensation, and bonuses are based on the amount of your Financial Advisor’s compensation, length of service, and the amount of compensation your Financial Advisor generates for us over time. Awards given in the form of deferred compensation have minimum vesting schedules and are subject to forfeiture under certain circumstances. The practice development and training programs provide the opportunity for a Financial Advisor to participate in a practice management, business development, and/or training program that may include travel to a specified destination. Each program allows the Financial Advisors to interact with both peers and industry experts and to exchange ideas on business practices and development. These rewards, incentive compensation, and bonuses create a conflict of interest because they provide an incentive for your Financial Advisor to encourage you to engage in more investment transactions in order to qualify for such rewards, incentive compensation, and bonuses. Branch Directors and Complex Directors, who may also be Financial Advisors, perform supervisory responsibilities over other Financial Advisors for the branch or region in which they are located. We compensate these individuals for their supervisory activities through a base salary, but also pay a bonus to these individuals that is based on meeting certain internal benchmarks, which include revenue generated by the Financial Advisors in their branch or region. This is a conflict of interest as supervisors have an incentive to encourage the recommendations of products, Services and investments that generate greater revenue for RBC WM in order to meet the revenue portion of the internal benchmark. We mitigate this conflict by not compensating our supervisors directly based on the recommendation of any specific products, Services, or investments, but instead on attainment of specific internal benchmarks, which include revenue goals. Option to Purchase through Others Clients have the option to purchase investment products that RBC WM may recommend through other brokers or agents that are not affiliated with RBC WM. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT RBC WM does not charge any performance-based fees in any of its advisory programs. ITEM 7: TYPES OF CLIENTS The Program is generally intended for individuals and entities with institutional consulting needs, such as trusts, estates, nonprofit organizations, employee benefit plans, government entities, and business entities. When providing Services to clients who are subject to ERISA, we may rely on various Prohibited Transaction Exemptions (“PTEs”) available under ERISA, including PTE 84-14, which is only available to qualified professional asset managers (the “QPAM Exemption”). On March 5, 2024, the French Court of Appeal rendered a judgment of conviction (the “Conviction”) against Royal Bank of Canada Trust Company (Bahamas) Limited (“RBCTC Bahamas”), an affiliate of RBC CM, and other parties regarding a charge of complicity in estate tax fraud relating to actions taken relating to a trust for which RBCTC Bahamas serves as trustee. In 2016, RBC was granted an exemption by the U.S. Department of Labor that allowed RBC and its current and future affiliates to continue to qualify for the QPAM Exemption under ERISA despite the conviction of RBCTC Bahamas in the French proceeding for a temporary one-year period from the date of conviction. In 2025, the Department of Labor granted RBC an exemption providing longer-term relief, which is effective from August 12, 2025, through March 4, 2030. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. Methods of Analysis and Investment Strategies RBC WM and/or your Financial Advisor may conduct analysis using a quantitative and/or qualitative approach and present that analysis via performance monitoring reports and evaluations. Four primary areas of analysis include firm and product, investment professionals, investment approach, and investment performance. Our investment searches are limited to the investment options that are offered at the recordkeeper platform. In connection with performing certain Services described in of the Program Agreement, we and our Financial Advisors may obtain and utilize information and data from a wide variety of public and private sources including: financial publications; company press releases and securities filings; research and due diligence material prepared by RBC WM, our affiliates and third parties; rating or timing services; regulatory and self-regulatory reports; third-party data; information obtained directly from investment management firms; and research providers, professionals and other public sources. RBC Institutional Consulting Program Disclosure Document Page 10 of 20 26-25-5088800_25264 (09/26)  All investments carry the risk of loss that you should be prepared to bear. To understand the risks associated with investment options, it is important that you review the fund prospectuses and documents, investment monitoring reports we provide to you, and other available investment information in order to ensure the investments selected match your investment goals and/or written Policy. B. Risks of Loss Investing in securities involves risk of loss that clients should be prepared to bear. There is no guarantee of performance for any investment strategy implemented or recommended, and the value of a client’s investments will fluctuate due to market conditions and other factors. Investments are subject to various risks, including, but not limited to, market, liquidity, currency, economic, and political risk, and will not necessarily be profitable. Past performance does not predict or guarantee any level of future performance. Below are certain material risk factors associated with the Program. There are certain other risk factors described throughout this brochure. All trading in your account is at your risk, and you are urged to consult with your Financial Advisor to discuss the risks associated with any investment strategy, particular investments and securities, and/or transactions recommended in the Program. Some of the material risks are as follows: • Market Risk. The value of securities owned by an investor may go up or down, sometimes rapidly or unpredictably, due to factors affecting certain industries and/or securities markets generally. • Interest Rate Risk. Fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. • Economic Conditions Risk. The economic, political, or financial developments will, from time to time, result in periods of volatility or other adverse effects that could negatively impact your account. • Credit Risk. Investors could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. • Liquidity Risk. Investors would not be able to sell or redeem an investment quickly without significantly affecting the price. Liquidity risk is heightened when markets are distressed. Generally, alternative investments have higher liquidity risk than securities traded on exchanges, fixed income securities or mutual funds and exchange traded funds (“ETFs”) (collectively, “Funds,” each a “Fund”). • Risks Relating to Equities. The price may rise or fall, sometimes rapidly or unpredictably, because of changes in a company’s financial condition. These price movements can result from economic changes or macro factors such as the economic performance of a particular country, interest rate movements, and international developments. Sector or industry developments as well as changes in government regulations may affect equity prices. • Risk Relating to Debt Securities. Debt securities, such as bonds, involve interest rate risk, credit risk, extension risk, prepayment risk, and other types of risks. In addition, the value of debt securities may fluctuate in response to market movements or issues that affect particular industries or issuers. When interest rates fall, the issuers of debt securities may repay principal more quickly than expected, and investors may have to reinvest the proceeds at a lower interest rate. This is known as “prepayment risk.” When interest rates rise, debt securities may be repaid more slowly than expected, and the value of the debt security can fall sharply. This is known as “extension risk.” Certain types of debt securities may be subject to “call and redemption risk,” which is the risk that the issuer may call a bond for redemption before it matures, and the investor may lose income. • Risks Relating to Specific Styles. Different types of stocks tend to shift in and out of favor depending on market and economic conditions. To the extent a portfolio emphasizes a value or growth style of investing, a portfolio runs the risk that undervalued companies’ valuations will never improve or that growth companies may be more volatile than other types of investments, respectively. • Risks Relating to Money Market Funds. An investment in a money market fund is neither insured nor guaranteed by the FDIC or any other government agency. Although money market funds seek to preserve the value of your investment at $1.00 per share, there is no assurance that will occur, and it is possible to lose money if the fund value per share falls. Moreover, in some circumstances, money market funds may be forced to cease operations when the value of a fund drops below $1.00 per share. If this happens, the fund’s holdings are liquidated and distributed to the fund’s shareholders. This liquidation process is likely to take a month or more. During that time, these funds would not be available to you to support purchases, withdrawals and, if applicable, check writing or other money movement debits from your account. • Concentration Risk. To the extent a client concentrates their investments by investing a significant portion of its assets in the securities of a single issuer, industry, sector, country or region, the overall adverse impact on the client of adverse developments in the business of such issuer, such industry or such government could be considerably greater than if they did not concentrate their investments to such an extent. RBC Institutional Consulting Program Disclosure Document Page 11 of 20 26-25-5088800_25264 (09/26)  • Sector Risk. To the extent a client account invests more heavily in particular sectors, industries, or sub-sectors of the market, its performance will be especially sensitive to developments that significantly affect those sectors, industries, or sub-sectors. An individual sector, industry, or sub-sector of the market may be more volatile, and may perform differently, than the broader market. The several industries that constitute a sector may not all react in the same way to economic, political, or regulatory events. A client account’s performance could be affected if the sectors, industries, or sub-sectors do not perform as expected. Alternatively, the lack of exposure to one or more sectors or industries may adversely affect performance. • Risks Relating to Foreign Securities and Emerging Markets. Investments in securities of foreign issuers denominated in foreign currencies are subject to risks in addition to the risks of securities of U.S. issuers. These risks include political and economic risks, civil conflicts and war, greater volatility, expropriation and nationalization risks, sanctions or other measures by the United States or other governments, currency fluctuations, higher transactions costs, delayed settlement, possible foreign controls on investment, liquidity risks, and less stringent investor protection and disclosure standards of some foreign markets. Events and evolving conditions in certain economies or markets may alter the risks associated with investments tied to countries or regions that historically were perceived as comparatively stable becoming riskier and more volatile. These risks are magnified in countries in emerging markets, which may have relatively unstable governments and less-established market economies than those of developed countries. Emerging markets may face greater social, economic, regulatory, and political uncertainties. These risks make emerging market securities more volatile and less liquid than securities issued in more developed countries. For more information, see the “Risks Related to Foreign Securities and Foreign Currencies section” in the Client Account Agreement, available on our public website at www.rbcwm.com/ disclosures. • Risks Relating to Annuities. Annuities are long-term investments and can offer tax-deferred accumulation with options for downside protection, death benefits and lifetime income. Variable annuities are securities that offer a range of investment options, called sub accounts, across different asset classes. Registered indexed linked annuities may also offer sub accounts and a choice of index strategies and provides certain protection against downside market risk and limited participation in index gains without directly investing in the market or an index. Fixed indexed annuities offer a choice of index strategies and provides protection against downside market risk combined with limited participation in gains tied to a particular index without directly investing in the markets or an index. Variable annuities and registered indexed linked annuities have market risk because the contract value fluctuates based on the investment performance of the sub accounts or the index accounts selected. Because the value of a variable annuity and a registered indexed linked annuity is tied to the performance of the investment options chosen, it is subject to investment risk. The value of your annuity will vary and could decline to less than the value of the premiums you have paid. You must pay the annuity fees, charges, and other expenses, regardless of how the annuity performs. Optional guaranteed benefits, which can normally only be elected at the time your annuity contract is issued, could restrict your investment options and in some cases cannot be reversed. You will pay additional charges for optional benefits and guarantees whether utilized or not. If you want to withdraw or terminate your annuity contract, your withdrawal may be subject to surrender charges or a market value adjustment. These charges are described in the annuity contract and prospectus/ statement of understanding. In addition, your contract with the annuity issuer may include specific guarantees and payment commitments. Those are obligations of the insurance company and are not guaranteed by RBC WM. For information, please consult the annuity product and underlying fund prospectuses which can be obtained from your Financial Advisor or directly from the insurance carrier. • High Yield Securities Risk. Certain strategies invest in securities and instruments that are issued by companies that are highly leveraged, less creditworthy, or financially distressed. These investments (known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties, and potential illiquidity. For more information see the “High-Yield Securities Disclosure” on our public website at www.rbcwm.com/disclosures. • Counterparty Risk. An account may have exposure to the credit risk of counterparties with which it deals in connection with the investment of its assets, whether engaged in exchange traded or off-exchange transactions or through brokers, dealers, custodians, and exchanges through which it engages. In addition, many protections afforded to cleared transactions, such as the security afforded by transacting through a clearing house, might not be available in connection with over-the-counter (“OTC”) transactions. Therefore, in those instances in which an account enters into OTC transactions, the account will be subject to the risk that its direct counterparty will not perform its obligations under the transactions and will sustain losses. • Mutual Funds and Exchange Traded Funds. Funds are sold by prospectus. Please read the prospectus and offering documents carefully before deciding to invest in a particular Fund. Shareholders of these investments pay fees to the service providers of the Funds, for example, management and administrative fees. The actual returns of your investment RBC Institutional Consulting Program Disclosure Document Page 12 of 20 26-25-5088800_25264 (09/26)  will be reduced by those fees and expenses. The return and principal value of Funds will fluctuate so that shares may be worth more or less than their original cost when redeemed. There are risks involved with investing, including possible loss of principal. There is no guarantee that the investments will appreciate during the time that you hold them and some or all may depreciate in price. The risks for each investment will vary depending on the investment objective and underlying investments of each Fund. The prospectus lists the applicable risks. Please review those risks carefully before investing. Purchasing ETF shares provides you an interest in an underlying basket of securities, designed to obtain investment results that correspond generally to price and yield performance of a particular index of securities, such as the S&P 500. There is no assurance that the ETF investments will match the index it aims to replicate. Investors in ETFs are subject to different risks than investors in mutual funds, as some of these instruments do not issue and redeem shares on a continuous basis. As a result, these securities may not be as liquid as open-end mutual funds. The price of these securities trading on an exchange can move independently of, and at a discount to, the net asset value (NAV) of securities comprising the ETF’s portfolio. We recommend that you read the prospectus and/or offering documents carefully and consider investment objectives, risks, fees and expense before investing. If you have any questions, please contact your Financial Advisor. • Collective Investment Trusts or Funds. A collective trust fund is not open to individual investors. The strategies may be speculative and involve significant risk. Unlike a Fund, the only way that an investor can gain access to a collective trust fund is through a retirement plan such as a 401(k) plan. Additionally, regulation of Funds and collective trust funds varies. For instance, the Fund industry is governed by the SEC. Funds lay out an investment strategy in legal documents that are filed with financial regulators in a region so investors are aware of the risks and rewards that are likely with a Fund. Managers of collective funds are not regulated by the SEC. Instead, these investment advisers adhere to less stringent guidelines and are overseen by the U.S. Office of the Comptroller of the Currency or by a state banking authority. As a result of less stringent governance, managers of collective funds must disclose fund performance and the components of a portfolio only once a year, although most collective fund managers communicate performance to investors on a more frequent basis. • Stable Value Funds. The objective of most stable value funds is to provide safety of principal and an investment return that is generally higher than a money market return, while providing participants the ability to withdraw their assets for ordinary transactions at book rather than market value. The ability to withdraw stable value assets at book value has limitations based on the insurance contracts that wrap the underlying assets. In addition, most stable value funds require a hold period before assets can be withdrawn from the fund by the plan sponsor at book value and may refuse to honor book value withdrawals after communications from a plan sponsor or plan fiduciaries that it determines caused participants’ withdrawals. The plan is often restricted from offering investment alternatives or plans that are viewed as competitive with the stable value offering such as money market mutual funds or short-term bond funds. Stable value funds are subject to counterparty risk of the insurers that provide the fund’s book value liquidity. • Group Annuities. In considering whether to purchase a particular group annuity for the Plan, clients should consider that a group annuity is a contract between the plan sponsor or the Plan trustee and the issuing insurance company that cover the participants in the Plan. A group variable annuity consists of separate accounts that typically invest in underlying investment portfolios the value of which fluctuates with the market value of the securities in the portfolio. Although a group annuity is issued by an insurance company, the annuity’s investment returns are not “insured” or guaranteed and risk of loss of principal does exist; however, the product may offer participants an option to purchase an annuity with a guaranteed component instead of a cash payout. Any such guarantee for an individual annuity is subject to the claims- paying ability of the insurance company. A group annuity contract generally is not a registered security and separate account is generally not a registered separate account. Therefore, the contract and separate account are not subject to registration or regulation by the SEC under the Securities Act of 1933, the Securities Exchange Act of 1934 or the Investment Company Act of 1940. A group annuity held in a qualified retirement plan does not provide any additional tax deferred treatment of earnings for the plan or participants beyond the treatment provided by the plan itself. A group annuity contract typically includes fees and expenses, including administrative fees for certain services of the insurance company, such as recordkeeping and administrative fees. These fees and expenses are in addition to the fees and expenses of the underlying investment options, which a participant will indirectly bear by investing in those investment options through the group annuity. ITEM 9: DISCIPLINARY INFORMATION The following is a summary of certain adverse disciplinary events and regulatory settlements during the last 10 years that may be material to your decision of whether to retain us for your investment advisory needs. You can find additional RBC Institutional Consulting Program Disclosure Document Page 13 of 20 26-25-5088800_25264 (09/26)  information regarding these settlements in Part 1 of our Form ADV at: adviserinfo.sec.gov as well as the FINRA website located at www.finra.org/brokercheck. • In June 2025, RBC CM entered into a settlement (the “Settlement”) with the Securities Division of the Office of the Secretary of the Commonwealth of Massachusetts regarding allegations that RBC CM charged unreasonable commission for certain equity transactions, and did not reasonably supervise these transactions in violation of § 204(a) (2)(J) of the Massachusetts Uniform Securities Act. RBC CM agreed to pay restitution in an amount no less than $113,295.06, plus 6% compounded interest, to affected Massachusetts customers. RBC CM also agreed to provide restitution, plus 6% compounded interest, to affected customers of other jurisdictions that agree to the terms of an agreement (“Term Sheet”) between RBC CM and a multi-state group, including Massachusetts, executed contemporaneously with the Settlement. RBC CM agreed to pay an administrative fine in an aggregate amount not to exceed $1,095,000 to the jurisdictions agreeing to the terms of the Term Sheet, which includes $25,000 to be paid to Massachusetts. • On August 14, 2024, RBC CM entered into a settlement order with the SEC in connection with RBC CM’s recordkeeping practices concerning business-related electronic communications sent or received by firm personnel using non-approved channels or methods (“off-channel communications”). The SEC found that from at least June 2019 to August 2024, RBC CM willfully violated Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder in connection with RBC CM’s failure to maintain and preserve the substantial majority of off- channel communications of its personnel that were records required to be maintained under Exchange Act Rule 17a-4(b) (4) and/or Advisers Act Rule 204-2(a)(7); and therefore, failed to reasonably supervise its personnel within the meaning of Section 15(b)(4)(E) of the Exchange Act and Section 203(e)(6) of the Advisers Act. RBC CM admitted to the facts in the settlement order and acknowledged its conduct violated the federal securities laws. The SEC ordered RBC CM to cease and desist from committing or causing any violations and any future violations of Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and Section 204 of the Advisers Act and Rule 204-2 thereunder, censured it for its conduct, ordered it to pay a civil monetary penalty in the amount of $45,000,000, and ordered it to comply with the undertakings enumerated in the settlement order. • RBC CM consented to FINRA sanctions and findings that its supervisory system did not provide certain customers with mutual fund sales charge waivers and fee rebates to which they were entitled through rights of reinstatement offered by mutual fund companies, which resulted in the payment of $264,939.44 in excess sales charges and fees by eligible customers. On July 2, 2024, RBC CM was censured, fined $75,000 and required to certify that it had remediated the issues and implement reasonably designed supervisory system, including written supervisory procedures (“WSPs”). The firm also made full restitution, plus interest, to the affected customers. • RBC CM consented to FINRA sanctions and findings that it sent trade confirmations to customers that contained inaccurate information. The findings stated that the firm sent its institutional customers confirmations for fixed income transactions, including certain municipal securities transactions, that inaccurately stated that the transactions were executed in an agency capacity, when they were executed in a principal capacity. The firm also sent its institutional customers trade confirmations that inaccurately stated that certain transactions that were solicited were unsolicited and vice versa. In addition, the firm failed to deliver trade confirmations to customers that had requested electronic delivery of trade confirmations and failed to send trade confirmations for millions of dividend reinvestment program (“DRIP”) transactions. The findings also stated that the firm failed to establish, maintain, and enforce a supervisory system, including WSPs, reasonably designed to achieve compliance with trade confirmation requirements. The findings also included that the firm violated Regulation T promulgated by the board of governors of the federal reserve system under Section 7 of the Exchange Act by extending credit to certain customers of the firm and its introducing firms, which resulted in hundreds of incorrectly executed trades in those accounts and the frequent selling of the positions at issue to generate proceeds to cover the purchases. In connection with these transactions, customer accounts incurred commissions, markups, markdowns, and fees totaling $392,525.50, that they would not otherwise have incurred had the firm cancelled the trades. In addition, introducing firm customer accounts incurred $1,308 in fees in connection with these trades that they would not have incurred had the firm cancelled the trades. On April 29, 2024, RBC CM was censured, fined $375,000, ordered to pay $393,833.50 in restitution to customers, and required to certify that it has remediated the issues and implemented a supervisory system, including WSPs. • On November 2, 2023, RBC CM entered into a settlement with the SEC resulting in the SEC issuing an order (the “Order”). RBC CM consented to the entry of the Order that found that RBC CM failed to make and keep books, records, and accounts, which, in reasonable detail, accurately and fairly reflected the transactions and dispositions of the assets of the issuer, and failed to devise and maintain a system of internal account controls sufficient to provide reasonable assurance that transactions are recorded to permit preparation of financial statements in conformity with generally accepted accounting principles. The Order directs that RBC CM cease-and-desist from committing or causing any violations and any future RBC Institutional Consulting Program Disclosure Document Page 14 of 20 26-25-5088800_25264 (09/26)  violations of Sections 13(B)(2)(A) and 13(B)(2)(B) of the Exchange Act. On November 2, 2023, without admitting or denying the findings, RBC CM consented to the Order and was fined $6,000,0000. • In May 2023, RBC CM entered into a settlement with the Commonwealth of Virginia’s State Corporation Commission’s Division of Securities and Retail Franchising (the “Division”) regarding allegations that it employed an investment adviser representative in the Commonwealth of Virginia without that person being duly registered with the Division, in violation of § 13.1-504 c (ii) of the Virginia Securities Act. RBC CM agreed to pay a $10,000 monetary penalty and $1,000 for the cost of the investigation. • In April 2023, without admitting or denying the findings, RBC CM reached a settlement with FINRA and consented to sanctions and the entry of findings that it failed to establish and maintain a supervisory system reasonably designed to achieve compliance with its suitability obligations in connection with syndicate preferred stock in brokerage accounts. The findings stated that while the firm’s procedures called for supervisors to closely examine representatives’ short-term trading of preferred stocks, the firm’s electronic surveillance of short-term trading in preferred stock was unreasonably designed, and it failed to monitor for that activity. Although the surveillance system had certain alerts that specifically monitored for short-term trading in other products, such as closed-end funds, it did not have any alerts that specifically monitored for short-term trading in preferred stock. The firm also did not have any other alerts that flagged the purchase and sale within 180 days of syndicate preferred stock. Certain of the firm’s registered representatives recommended that a number of the firm’s retail customers purchase syndicate preferred stocks, and then sold the positions within 180 days, and such customers sustained losses on these transactions. The firm earned $653,313 in selling concessions from these syndicate purchases and $128,643 in sales commissions from the subsequent sales. The firm conducted a substantial syndicate preferred stock business yet did not maintain a reasonable supervisory system to monitor whether its representatives recommended short-term trading of syndicate preferred securities that was unsuitable, including for the purpose of capturing sales concessions and commissions. The firm was censured, fined $300,000, ordered to pay $128,643.17, plus interest, in restitution to customers, ordered to pay $653,312.83, plus interest, in disgorgement, and required to certify that it has remediated the issues identified in this AWC and implemented a supervisory system, including WSPs, reasonably designed to achieve compliance with FINRA Rule 3110 regarding the issues identified in this AWC. • On March 3, 2022, RBC CM affiliate and registered investment adviser, CNR, reached a settlement with the SEC concerning CNR’s breach of its fiduciary duty relating to the use of proprietary Funds and certain share classes in advisory accounts. Those Funds generated fees for CNR and its affiliates, rather than competitor funds within the same asset classes that may not have generated such fees, and created a conflict that was not disclosed. The SEC determined that CNR willfully violated sections 206(2) and 206(4) of the Advisers Act as well as Rule 206(4)-7 by failing to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. Under the terms of the settlement, CNR paid $30,361,804 in fines, disgorgement, and interest. • Without admitting or denying the findings, RBC CM consented to the sanctions and to the entry of findings that it failed to establish, maintain, and enforce a supervisory system, including WSPs, reasonably designed to achieve compliance with FINRA and Municipal Securities Rulemaking Board (“MSRB”) rules with respect to representatives’ recommendations of high-yield corporate and municipal bonds. The findings stated that the firm’s policies and procedures did not sufficiently address the suitability factors that representatives should consider before recommending high-yield bonds. On December 15, 2021, RBC CM was censured, fined $550,000, and ordered to pay $456,155, plus interest, in restitution to customers. • On September 17, 2021, RBC CM entered into a settlement with the SEC resulting in the SEC issuing an order (the “Order”). RBC CM consented to the entry of the Order which found that from 2014-2017, RBC CM engaged in improper conduct in connection with the allocation, purchase, and sale of certain new issue municipal bond offerings in violation of internal procedures, as well as MSRB and SEC rules. The Order found that RBC CM’s conduct violated MSRB and SEC rules. The Order censured RBC CM and required RBC CM to pay disgorgement of $552,440, prejudgment interest of $160,886.97, and $150,000 as a civil penalty to the SEC. Such payments were made by RBC CM on September 22, 2021. • The Virginia State Corporation Commission found that, from December 1, 2017, through November 27, 2020, RBC CM employed an investment adviser representative (“IAR”) who was registered in the District of Columbia but not Virginia and that RBC CM failed to enforce its WSPs regarding IAR registration. On September 8, 2021, RBC CM executed the settlement order which states that RBC CM neither admits nor denies the Virginia state corporation commission’s allegations and paid a $10,000 civil penalty. • It was found by the New York Stock Exchange (“NYSE”) that RBC CM violated NYSE Rule 3110(a) and (b) (Supervision) by failing to establish and maintain a supervisory system and WSPs reasonably designed to detect and prevent errors in market on close orders. On July 6, 2021, RBC CM entered into a letter of acceptance, waiver and consent with the NYSE under which RBC CM consented to the sanctions and was censured and fined $10,000. RBC Institutional Consulting Program Disclosure Document Page 15 of 20 26-25-5088800_25264 (09/26)  • It was found that RBC CM violated SEC Rule 15c3-5(b) and (c)(1)(ii) and Rules 3.2 and 5.1 of the CBOE BZX Exchange, Inc., CBOE EDGA Exchange, Inc., CBOE BYX Exchange, Inc., and CBOE EDGX Exchange, Inc. due to the fact that the Firm’s financial risk management controls and supervisory procedures were not reasonably designed to (i) prevent the entry of erroneous orders, (ii) reject orders that exceed appropriate price or size parameters, on an order-by-order basis or over a short period of time, or (iii) reject duplicative orders. On March 30, 2021, without admitting or denying the findings, RBC CM was censured and fined $45,000 by CBOE BZX Exchange, Inc., $45,000 by CBOE EDGA Exchange, Inc., $70,000 by CBOE BYX Exchange, Inc. and $45,000 by CBOE EDGX Exchange, Inc. • The Massachusetts Securities Division found that RBC CM failed to adequately supervise its representatives with respect to concentration and suitability of master limited partnership energy and telecom positions in certain client accounts. On February 2, 2021, without admitting to any supervisory deficiencies, RBC CM agreed to the described sanctions and fines totaling $320,267.41. • Without admitting or denying the findings, on December 15, 2020, RBC CM consented to the sanctions and to the entry of findings that it failed to establish and maintain a supervisory system reasonably designed to supervise representatives’ recommendations to customers to purchase particular share classes of 529 college savings plans. The findings stated that RBC CM did not provide adequate guidance to representatives regarding the importance of considering share class differences when recommending 529 plans and had no procedures requiring supervisors to review 529 plan share class recommendations for suitability. RBC CM updated its procedures to include such a requirement, but the updated procedures failed to adequately instruct supervisors to consider either the age of the beneficiary or the number of years until expected withdrawals, both critical factors in determining the suitability of the recommended share class. Also, RBC CM did not consistently provide supervisors with the information necessary to review the suitability of 529 plan share class recommendations. Later, RBC CM issued a company-wide compliance alert that provided guidance to representatives regarding 529 plan share class recommendations. RBC CM then updated its supervisory systems and procedures with respect to 529 share class recommendations. Among other things, RBC CM instructed supervisors to consider the age of the beneficiary when assessing the suitability of a representative’s 529 share class recommendation. RBC CM has agreed to pay restitution and interest relating to the sale of class C shares to certain 529 plan customers in the estimated amount of $839,803. • The SEC found that from at least July 2012 through August 2017, RBC CM disadvantaged certain retirement plan and charitable organization brokerage customers who maintained accounts at RBC CM (“Eligible Customers”) by failing to ascertain that they were eligible for a less expensive share class and recommending and selling them more expensive share classes in certain open-end Funds when less expensive share classes were available. RBC CM did so without disclosing that it would receive greater compensation from the Eligible Customers’ purchases of the more expensive share classes. Eligible Customers did not have sufficient information to understand that RBC CM had a conflict of interest resulting from compensation it received for selling the more expensive share classes. Specifically, RBC CM recommended and sold these Eligible Customers class A shares with an up-front sales charge, or class B or class C shares with a back- end contingent deferred sales charge (a deferred sales charge the purchaser pays if the purchaser sells the shares during a specified time period following the purchase) and higher ongoing fees and expenses, when these Eligible Customers were eligible to purchase load-waived class A and/or no-load class R shares. RBC CM omitted material information concerning its compensation when it recommended the more expensive share classes. RBC CM also did not disclose that the purchase of the more expensive share classes would negatively impact the overall return on the Eligible Customers’ investments, in light of the different fee structures for the different fund share classes. In making those recommendations of more expensive share classes while omitting material facts, RBC CM violated sections 17(a)(2) and 17(a)(3) of the Securities Act. These provisions prohibit, respectively, in the offer or sale of securities, obtaining money or property by means of an omission to state a material fact necessary to make statements made not misleading, and engaging in a course of business which operates as a fraud or deceit on the purchaser. As a result of the conduct described above, RBC CM willfully violated sections 17(a)(2) and 17(a)(3) of the Securities Act. On April 24, 2020, RBC CM was censured and paid disgorgement of $2,607,676, prejudgment interest of $631,331, plus a civil monetary penalty of $650,000. • Without admitting or denying the findings, RBC CM consented to the sanctions and the entry of findings that RBC CM entered 670 principal orders with incorrect origin codes, indicating that the orders were for customers instead of RBC CM. The findings state that RBC CM ignored red flags and failed to remedy the pattern of entering and executing orders with incorrect origin codes. In addition, for the calendar year 2018 RBC CM conducted 11 of 12 monthly origin code reviews late because RBC CM failed to enforce its procedures requiring timely origin code reviews. Between August 28, 2019, and October 2, 2019, RBC CM settled for a total of $100,000 across eight exchanges (NASDAQ PHLX LLC $7,138; NASDAQ Stock Markets/The NASDAQ Options Market $5,687; CBOE BZX Exchange, Inc. $28,271; NASDAQ ISE, LLC Fine $6,721; NYSE American LLC $4,098; NYSE ARCA, Inc. $5,509; CBOE Exchange, Inc.: $36,592; and CBOE C2 Exchange, Inc., $5,984). RBC Institutional Consulting Program Disclosure Document Page 16 of 20 26-25-5088800_25264 (09/26)  • FINRA found that from March 2008 to June 2016, RBC CM failed to make the statutorily required delivery of prospectuses to customers who purchased approximately 165,000 ETFs and notes and hundreds of thousands of open-end and closed- end mutual funds. RBC CM failed to design, implement, and enforce a reasonable supervisory system, procedures and set of controls to comply with prospectus delivery rules for Funds and as a result, failed to discover the delivery failures until FINRA’s investigation into the matter. On October 17, 2019, RBC CM was censured and fined in the amount of $2,900,000. • RBC CM self-reported to the SEC the violations described below pursuant to the Division of Enforcement’s Share Class Selection Disclosure Initiative (“SCSD Initiative”). The SEC found that RBC CM, during the period of January 1, 2014, through March 27, 2017, failed to make adequate disclosures, in its Form ADV or otherwise, regarding its Fund share class selection practices, and the 12b-1 fees it received, in connection with advisory account transactions. Specifically, at times during the relevant period, RBC CM purchased, recommended, or held in advisory accounts Fund share classes that charged 12b-1 fees instead of lower cost share classes in the same fund. The SEC found that RBC CM failed to adequately disclose the receipt of the 12b-1 fees and the associated conflict of interest, thereby willfully violating Sections 206(2) and 207 of the Advisers Act. On March 11, 2019, without admitting or denying the findings, the SEC issued, and the firm consented to the entry of an order (the “Order”) that censured RBC CM and directs it to cease-and-desist from committing or causing any violations and any future violations of Sections 206(2) and 207 of the Advisers Act. Additionally, the Order requires Respondent to pay disgorgement of $10,494,813.38, prejudgment interest of $1,220,581.34, and to comply with the other undertakings enumerated in the Order as part of the settlement. ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS A. Broker Dealer Registration RBC WM is registered with the SEC as a broker-dealer and investment adviser. Certain of RBC WM’s management personnel and all of its Financial Advisors and their supervisors are registered with FINRA as representatives of RBC WM in its capacity as a broker-dealer. B. Commodity Futures Registration RBC WM is also registered with the Commodity Futures Trading Commission (“CFTC”) as a futures commission merchant and swap firm. C. Material Relationships with Related Persons Program assets will not be held at RBC WM, and you are not required to purchase products that RBC WM distributes, or otherwise transact business with RBC WM, RBC CM, or any of our affiliates in order to participate in the Program. However, we have multiple affiliated entities engaged in many different business activities, and below is a list of affiliated entities of RBC CM that you may end up doing business with if you so choose. RBC GAM – U.S. RBC GAM – U.S. is an affiliate of RBC CM. RBC GAM – U.S. is a federally registered investment adviser that provides portfolio management services to institutional separate accounts, registered investment companies, pooled vehicles, and portfolio management services for wrap fee accounts and model portfolios offered by other providers. RBC WM makes RBC GAM – U.S. available for clients to select as an investment manager and a model provider in certain wrap free advisory programs that RBC WM sponsors. On occasion, RBC CM solicits clients for RBC GAM – U.S. RBC GAM – U.S. may also serve as investment adviser and/ or sub-advisor to Funds that may be recommended by RBC CM. This is a conflict of interest as we are incented to recommend the RBC Funds or other affiliate funds over a non-RBC Fund. We address this conflict of interest by proper disclosure and by not charging certain fees to retirement accounts, including accounts subject to Title I of ERISA and individual retirement accounts. City National Bank In certain instances, we, through our Financial Advisors, will refer clients to City National Bank (“CNB”) for certain banking products and services, or CNB will refer clients to us for brokerage and other investment services. In such cases, the referring party will, as permitted by applicable law, receive fees and compensation in connection with these products and services. We address this conflict of interest through proper disclosure. RBC Rochdale RBC Rochdale is a subsidiary of CNB. RBC Rochdale is a federally registered investment adviser that provides investment management services to high-net-worth individuals, families, and foundations. RBC Rochdale may also serve as investment RBC Institutional Consulting Program Disclosure Document Page 17 of 20 26-25-5088800_25264 (09/26)  adviser and/or sub-adviser to Funds that may be recommended by RBC WM. This is a conflict of interest as we are incented to recommend Funds and/or third-party Funds sub-advised by RBC Rochdale, over a non-RBC Fund. This conflict of interest is addressed by proper disclosure and by rebating or not charging certain fees to retirement accounts, including accounts subject to Title I of ERISA and IRAs. RBC US Holdco Corporation RBC CM, RBC GAM – U.S., and CNB are wholly-owned subsidiaries of RBC USA Holdco Corporation, which is a wholly-owned indirect subsidiary of RBC. RBC Global Asset Management (UK) Limited (“GAM UK”) is a wholly owned indirect subsidiary of RBC and an affiliate of RBC CM. GAM UK serves as an investment sub-adviser to certain U.S. registered Funds for which RBC GAM – U.S. or other third-parties serve as the investment adviser. Such Funds may be recommended by RBC CM. This is a conflict of interest as we have an incentive to recommend funds that are sub-advised by our affiliates over other products. To the extent permitted by applicable law, this conflict is addressed by proper disclosure and by not charging certain fees to retirement accounts, including accounts subject to Title I of ERISA and individual retirement accounts. Trust and Estate Settlement Services Clients can select CNB, a nationally chartered bank and trust company, or its subsidiary RBC Trust Company (Delaware) Limited (“RBC Trust”), a Delaware chartered trust company, as a professional trust and estate settlement service provider. RBC WM and its Financial Advisors are generally prohibited from serving as trustees. Clients can also select TrustCorp America (“TCA”), a Washington, D.C. chartered trust company, as a professional trust and estate settlement service provider. RBC CM has a minority interest in TCA. For more information, see the “City National Referral Disclosure Statement” on our public website at www.rbcwm.com/disclosures. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. Code of Ethics and Personal Trading RBC WM has adopted an Investment Adviser Code of Ethics (the “IA Code of Ethics”) in accordance with Rule 204A-1 of the Advisers Act, which applies to all RBC WM employees, contingent workers, contract workers and interns (“Covered Persons”), with limited exceptions. The IA Code of Ethics sets forth the standards of business conduct applicable to RBC WM and its Covered Persons (i.e., to act with integrity, honesty, and professionalism and to always act in the best interests of our clients) and is designed to ensure that RBC WM and its Covered Persons comply with applicable federal and state securities laws and regulations. The IA Code of Ethics also highlights that as an investment adviser and fiduciary, the Firm and its Covered Persons have an affirmative duty to always act in the best interest of our advisory clients which means their interests must always come first. This means that when acting in an investment advisory capacity, Covered Persons are responsible to: (i) put client interests before their own; (ii) act with utmost good faith; (iii) provide full and fair disclosure of all material facts; (iv) not mislead clients; and (v) disclose all potential, perceived, and/or actual conflicts of interest to clients. The IA Code of Ethics also includes guidelines regarding personal securities transactions of, and the maintenance of personal securities accounts by, its Covered Persons (with the exception of interns) in accordance with the Firm’s policies on outside securities accounts, and employee/employee-related accounts. More specifically, the IA Code of Ethics outlines the Firm requirements contained in such policies, including that Covered Persons and their immediate family members (i) maintain their personal securities accounts and accounts in which they have a beneficial interest at RBC WM, unless the Firm has given its prior express written permission to open and/or maintain an account outside of RBC WM, (ii) report their personal securities transactions and holdings to RBC WM, and (iii) obtain pre-approval for investments in private placements and initial public offerings, among others. In addition, the IA Code of Ethics also contains information on standards relating to prohibited and illegal activities associated with the possession of material non-public information (e.g., further disclosure, trading), the administration and enforcement of the IA Code of Ethics, and maintenance of certain records relating to the IA Code of Ethics. As part of RBC WM’s annual Compliance questionnaire process, Covered Persons are required to certify to their receipt and review of, and compliance with, the IA Code of Ethics. A copy of the IA Code of Ethics is available to clients or prospective clients upon request. B. Participation or Interest in Client Transactions and Personal Trading Many of the conflicts related to participation or interest in client transactions and personal trading may not apply in the context of the Program because assets are not custodied at RBC and we do not require you to establish accounts, purchase products or otherwise transact business with us. Nevertheless, we attempt to address potential conflicts of interest through this and other disclosure documents. RBC Institutional Consulting Program Disclosure Document Page 18 of 20 26-25-5088800_25264 (09/26)  In addition to sponsoring the Program, RBC WM sponsors other investment advisory programs and engages in a broad range of brokerage and other financial services. These include public and private investment banking and underwriting, retail and institutional brokerage and trading, institutional research and numerous other brokerage, advisory and financial services. As a full-service broker-dealer, on an ongoing basis and as permitted be applicable law, we may, when appropriate: • act as broker or agent, effect securities transactions for compensation for you; • recommend to you that you buy or sell securities or investment products in which we or a related person or a family member of an employee has some financial interest; • buy or sell for ourselves securities that we also recommend to you; or • sell or convert Fund shares or other unbilled assets, which will subject proceeds to the Program fee. We have adopted internal policies and procedures with respect to conflicts of interest between us and our clients. Pursuant to these policies and procedures, we, when engaging in the activities enumerated above, treat your orders fairly and do not give our own orders preference over your orders. As required by applicable law and/or exchange rules, including, but not limited to, the Advisers Act, we obtain the consent of affected clients in advance of any transactions in which we will be engaging in the activities referenced above. When we engage in the activities referenced above, all statements and/ or confirmations of such transactions contain the disclosures required by applicable law and exchange rules. Employees and their immediate family members must maintain their personal securities accounts and accounts in which they have a beneficial interest at RBC WM, unless the firm has given its prior express written permission to open and/or maintain an account outside of RBC WM, and securities activities in those accounts are monitored daily to detect and prevent employees from trading ahead of client accounts. Additionally, RBC WM and/or its employees may recommend that clients in the Program make investment options available to plan participants at or about the same time that RBC WM or an employee buys or sells the same securities for its own account. This constitutes a conflict of interest. When this occurs, where required by applicable law or exchange rules, we obtain the consent of affected clients in advance of any transactions in which we will be engaging in the activities referenced above. When we engage in the activities referenced above, all statements and/or confirmations of such transactions contain the disclosures required by applicable law and exchange rules. RBC WM and its affiliates are not obligated to effect any transaction that they believe would violate federal or state law, or the regulations of any regulatory or self-regulatory body. ITEM 12: BROKERAGE PRACTICES While providing Program Services, RBC WM does not select or recommend broker-dealers for client transactions. Thus, the Program does not include the review or recommendation of broker-dealers for client transactions. ITEM 13: REVIEW OF ACCOUNTS RBC WM provides fiduciary investment advice in the Program to its clients at the plan-level; it does not provide fiduciary investment advice to plan participants, unless we have a direct contractual relationship with the plan participant outside of the Program. When RBC WM does provide fiduciary investment advice to clients in the Program, RBC WM has instituted policies and procedures for the supervision and oversight of the Program. The supervisory structure is designed to ensure RBC WM complies with the requirements of the Advisers Act and ERISA, where applicable, along with other applicable rules and regulations. RBC WM Financial Advisors conduct periodic (but at least annual) reviews with their clients in the Program with the frequency agreed upon between RBC WM and the client. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION We have referral agreements with independent third parties (each, a “Promoter”) whereby a Promoter will refer prospective clients to us for Services. Under one of these arrangements, we will pay the Promoter for these referrals by sharing with the Promoter a portion of the Program fee (generally about 25%, although it can be higher than 25%, depending on facts and circumstances) that we receive from a referred client who opens an account in the Program. Under a separate arrangement, we will pay the Promoter a one-time flat fee of up to $695, based on the potential level of investable assets for each referral, with such fee payable regardless of whether the referred party opens an account with us. This arrangement presents a conflict of interest for us and our Financial Advisors because it has the potential to incentivize a recommendation that such prospective clients become clients to recoup the cost of the referral payment. RBC Institutional Consulting Program Disclosure Document Page 19 of 20 26-25-5088800_25264 (09/26)  We receive referral fees from third-party or affiliated investment advisers and lending institutions, for successful client referrals made by our Financial Advisors. The lending institution pays a referral fee pursuant to a referral agreement between us and the lending institution. The investment adviser shares a portion of the advisory fee it receives from the client with us pursuant to a referral agreement between us and the investment adviser. In the case where a Financial Advisor receives compensation for a client referral, there is a monetary incentive for us and the Financial Advisor to recommend that party over other parties that do not pay us and the Financial Advisor referral compensation. With referrals to affiliates, our firm may be subject to pressure from those affiliates to protect their business interests. This pressure creates a conflict of interest because it incentivizes us to make recommendations to you, or refrain from making recommendations to you, in a manner which best protects those business interests. Our Financial Advisors are eligible to receive compensation for referrals of clients and prospects to CNB for certain banking products and services. However, CNB may not be the lowest cost service provider to which our Financial Advisors could refer you. Compensation in the form of a production credit will be awarded to the Financial Advisor based on the type of banking product and service selected. This credit is calculated as a percentage of the net revenue generated by the relationship and/or originated mortgage amount over a set period that varies by product. The Financial Advisor’s receipt of referral compensation creates a conflict of interest because it provides an incentive for the Financial Advisor to refer clients to CNB as opposed to other service providers that do not pay for such referrals. The Financial Advisor’s receipt of referral compensation creates a conflict of interest because it provides an incentive for the Financial Advisor to refer clients to CNB as opposed to other service providers that do not pay for such referrals. An RBC WM employee or an affiliate may also refer a client to an RBC WM Financial Advisor. As an incentive, the referring employee will receive a percentage, or a portion of the fees paid by the client for selected Services. In addition, Financial Advisors are eligible to receive a one-time payment to refer existing client accounts to the RBC Advantage team. The referring employee’s role in the ongoing client relationship, if any, will vary depending on each client’s particular situation. The amount of the referral fee paid to us by a third-party investment adviser or by us to an employee providing a referral varies depending on the facts and circumstances. The client acknowledges the referral fee arrangement by signing the investment adviser’s consent and disclosure document. ITEM 15: CUSTODY We do not provide custody to Program assets. You will receive account statements from the broker-dealer, bank or other qualified custodian that is holding the Program assets. We urge you to carefully review your statements upon receipt. ITEM 16: INVESTMENT DISCRETION If you have selected Discretionary Services under the Program Agreement, we accept the discretionary authority to select the available investment options for your retirement plan as disclosed in the Program Agreement. Clients are permitted to limit this discretion in accordance with the provisions of their plan or any other restrictions they negotiate with RBC WM. Before assuming this discretionary authority, we require an executed Program Agreement delegating us this power. Refer to “Discretionary Services” section above for more information about RBC WM’s investment discretion. ITEM 17: VOTING CLIENT SECURITIES Our Program Services generally do not include proxy voting services. You will receive your proxy materials directly from the custodian or transfer agent. You may contact your Financial Advisor to discuss any proxy solicitation. ITEM 18: FINANCIAL INFORMATION We are not required to include a balance sheet in this brochure because we do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. We do not have any financial conditions that are reasonably likely to impair our ability to meet our contractual commitments to clients. RBC CM, RBC WM, and their predecessors have not been the subject of a bankruptcy petition during the past 10 years. 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