Reynders, McVeigh Capital Management, LLC

Reynders, McVeigh Capital Management, LLC Form ADV Part 2A Firm Brochure Reynders, McVeigh Capital Management, LLC 10 Post Office Square, Suite N1010 Boston, MA 02109 Phone: (617) 226-9999 Fax: (617) 226-9998 www.reyndersmcveigh.com Brochure prepared as of March 31, 2026 This brochure (the “Brochure”) provides information about the qualifications and business practices of Reynders, McVeigh Capital Management, LLC (“Reynders, McVeigh” or the “Firm), an investment adviser registered with the United States Securities and Exchange Commission (“SEC”). Questions about the contents of this Brochure should be directed to our Chief Compliance Officer at (617) 226-9999 or info@reyndersmcveigh.com. The information in this Brochure has not been approved or verified by the SEC or by any state securities authority. Additional information about Reynders, McVeigh Capital Management, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Reynders, McVeigh is a registered investment adviser. Registration as an investment adviser does not imply a certain level of skill or training. i  Item 2: Material Changes This Brochure, dated March 31, 2026, is the Firm’s annual update for the fiscal year ended December 31, 2025. The Firm has not made any material changes to the Brochure since its last annual update on March 31, 2025. The Firm has made certain non-material, clarifying revisions throughout the Brochure. Clients are encouraged to review this Brochure carefully and contact the Firm with any questions. ii  Item 3: Table of Contents TABLE OF CONTENTS Item 2: Material Changes .................................................................................................................................... ii Item 3: Table of Contents .................................................................................................................................. iii Item 4: Advisory Business .................................................................................................................................. 1 Item 5: Fees and Compensation ......................................................................................................................... 1 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................... 2 Item 7: Types of Clients ...................................................................................................................................... 3 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 3 Item 9: Disciplinary Information .......................................................................................................................... 7 Item 10: Other Financial Industry Activities and Affiliations ................................................................................ 7 Item 11: Code of Ethics ...................................................................................................................................... 7 Item 12: Brokerage Practices .............................................................................................................................. 8 Item 13: Review of Accounts .............................................................................................................................. 9 Item 14: Client Referrals and Other Compensation ........................................................................................... 10 Item 15: Custody .............................................................................................................................................. 11 Item 16: Investment Discretion ......................................................................................................................... 11 Item 17: Voting Client Securities – Proxy Voting ............................................................................................... 12 Item 18: Financial Information .......................................................................................................................... 12 iii  Item 4: Advisory Business Reynders, McVeigh Capital Management, LLC (“Reynders, McVeigh” or the “Firm”) is an investment adviser founded in 2005 and organized as a limited liability company under the laws of the Commonwealth of Massachusetts. The Firm is majority owned by Charlton Reynders III, Chairman and Chief Executive Officer, and Patrick McVeigh, President and Chief Investment Officer. The Firm provides investment advisory services with a focus on long-term, sustainable investing, integrating fundamental analysis with consideration of environmental, social, and governance factors. investment management services, under which it provides The Firm offers discretionary investment management services to separately managed accounts and a mutual fund, whereby the Firm has authority to make investment decisions and execute transactions on behalf of clients. The Firm investment also provides non-discretionary recommendations and arranges for the execution of transactions upon client approval. In addition, the Firm provides investment advice to institutional clients, including trustee law firms and family offices, typically without discretionary authority. The Firm also offers investment consulting services, including investment research, model portfolio advice, and strategies. Clients are responsible for determining how and to what extent they implement such advice, and the Firm does not execute transactions in connection with these services. Assets associated with investment consulting services are not included in the Firm’s regulatory assets under management or assets under advisement. The Firm generally provides financial planning services to retail investor clients who meet and maintain the minimum investment requirement for separately managed accounts. The Firm also serves as investment adviser to the Reynders, McVeigh Core Equity Fund (the “Fund”), a mutual fund series of Capitol Series Trust, a registered open-end management investment company registered with the SEC under the Investment Company Act of 1940, as amended. Investment advice and portfolio management services are provided on a continuous basis, including the selection of equity and fixed income securities and the allocation of these assets, in combination with cash, for client portfolios. The Firm may also provide guidance on retirement planning, estate planning considerations, and other financial matters, and may serve as trustee for certain client accounts. Upon request and where appropriate, the Firm may recommend impact investments, which seek to generate environmental or social benefits alongside financial returns. Reynders, McVeigh tailors its advisory services to clients’ objectives and constraints. The Firm assists clients in assessing their investment objectives, setting reasonable goals, and designing investment plans to meet their needs. Each portfolio is assigned to a counselor, and most portfolios also have a portfolio manager who works with the counselor on the client relationship. Either the counselor or portfolio manager, as applicable, is responsible for the day- to-day management of the account. Clients may impose restrictions on investing in specific issuers or types of securities at any time by notifying their portfolio manager or counselor or by including such restrictions in their Investment Management Agreement. These restrictions are maintained in the Firm’s trading systems to ensure portfolios adhere to client directives. Assets Under Management: As of December 31, 2025, the Firm managed approximately $4.2 billion in client assets, including approximately $4.1 billion on a discretionary basis and $139.9 million on a non-discretionary basis. In addition, the Firm provided advisory services on approximately $3.2 billion in assets through non-discretionary and consulting relationships. Item 5: Fees and Compensation SMA Management Fees: Reynders, McVeigh’s standard annual fee rate for managed accounts is 1 percent of the household’s first $3 million under management, and 0.75 percent on any assets under management in excess of $3 million. Accounts invested solely in the Firm’s fixed income strategy are charged an annual management fee of 0.30 1  percent. Management fees are negotiable based upon circumstances and relationships with clients, including the scope of the Firm’s services. Certain legacy client relationships are subject to flat-fee arrangements, which are generally not available to new clients. The Firm’s management fee for a separately managed account (the “SMA management fee”) is calculated based on the quarter-end value of the account. SMA management fees are generally billed quarterly in advance, meaning that clients are invoiced at the beginning of each billing period. Fees may be billed in arrears upon request. Either party may terminate services at any time upon written notice, and any unearned fees paid in advance will be refunded. SMA management fees are typically deducted directly from client accounts with prior written authorization. Clients may direct that fees be deducted from another account under the Firm’s management, except that retirement accounts may not be used to pay fees for other accounts. Clients may also elect to be invoiced directly. In all cases, clients receive fee calculations from the Firm. Fund Management Fees: The Reynders, McVeigh Core Equity Fund pays a management fee of 0.75% to the Firm. In addition to the management fee, the Fund also pays expenses (capped at 0.20%) related to the organization, offering, and administration of the Fund. These expenses are set forth in the prospectus and Statement of Additional Information (“SAI”) for the Fund, and investors in the Fund bear a pro-rata share of the Fund’s fees and expenses. Client assets invested in the Fund are excluded from the assets used to calculate the Firm’s SMA management fee. As a result, the Firm does not receive both an SMA management fee and a Fund management fee on the same assets. Reynders, McVeigh is not compensated for the sale of Fund shares or shares of any other mutual funds, ETFs, or other investment products. Fees for Other Advisory Services: The Firm does not maintain a standard fee schedule for its other advisory services. Fees are negotiated on a case-by-case basis depending upon the nature and the scope of the services provided. The Firm does not charge a separate fee for financial planning services and generally provides financial planning only to clients who meet and maintain the Firm’s minimum account size. Other Fees and Expenses: Clients incur additional fees and expenses, depending on specific circumstances, as summarized below (see Item 12 herein for additional information on brokerage and other transaction costs). Internal fees and expenses charged by mutual funds, ETFs, and private investment vehicles; • Custodial fees associated with maintaining client accounts; • Brokerage commissions, mark-ups, or mark-downs on securities transactions (particularly fixed income); • Exchange fees, if these are passed on to clients by the broker-dealer executing the transaction; • SEC fees on exchange-listed equity transactions; • • Deferred sales charges (on mutual funds or annuities); • Transfer taxes; • Wire transfer and electronic fund processing fees. Reynders, McVeigh does not earn revenue from any of the following fees or expenses. Item 6: Performance-Based Fees and Side-By-Side Management Reynders, McVeigh does not charge performance-based fees (i.e., fees based on a portion of capital gains or on capital appreciation of assets invested). Reynders, McVeigh manages accounts with different fee structures and rates. These differences may reflect variations in the scope of services provided or negotiated arrangements with clients. As a result, the Firm has an incentive to favor accounts that are likely to generate higher fees. 2  The Firm addresses this conflict of interest through its fiduciary duty to clients, internal policies and procedures, and trade allocation practices designed to ensure that all clients are treated fairly over time. See Item 12 for additional information regarding trade allocation and aggregation. Item 7: Types of Clients Reynders, McVeigh provides discretionary and non-discretionary investment management services and investment advice to the following types of clients: individuals, including high net-worth individuals; trusts, estates, and charitable organizations; corporations and other businesses; pension and profit-sharing plans; family offices; and trusts administered by law firm trust departments, as well as a mutual fund, as described in Items 4, 10 and 11. The Firm also provides financial planning services to retail investor clients and investment consulting services (in the form of model portfolio advice and strategies) to institutional clients. In order to establish or maintain an investment advisory relationship, Reynders, McVeigh generally requires a minimum of $1,000,000, which may be aggregated across related accounts. The Firm retains discretion to accept or maintain client relationships below this minimum. The Firm may also provide supplemental services, such as financial planning, gift planning and legacy planning, to clients who maintain the minimum account size. When Reynders, McVeigh provides investment advice to clients regarding retirement plan accounts or individual retirement accounts, the Firm acts as a fiduciary within the meaning of applicable law, including the Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code. The way the Firm is compensated may create conflicts with retirement clients’ interests; however, the Firm is required to act in the best interests of such clients. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Method of Analysis Three core principles define Reynders, McVeigh’s equity investment discipline. First, companies that are financially strong and consistently increase dividends provide the foundation of an investment portfolio. Second, companies with innovative products or services may disrupt industries while benefiting both shareholders and society. Third, and equally important, analysis of a company’s sustainability profile is crucial for a deeper understanding of the risks and opportunities that can impact operating performance. The Firm’s internal research process integrates traditional financial analysis with consideration of environmental, social and governance (ESG) factors. ESG considerations are incorporated alongside financial analysis and are not applied as a separate overlay. The Firm evaluates factors such as balance sheet strength, earnings quality, management effectiveness, and long-term growth prospects, together with ESG-related risks and opportunities. The Firm focuses on internally generated ideas developed through in-house research, supplemented by external research resources. The Firm’s research process includes analysis of financial statements, valuation metrics, business models, and growth catalysts, supported by company engagement and external research. A commitment to sustainable investing is core to the Firm’s identity. The Firm seeks to identify companies with strong or improving ESG profiles by evaluating environmental practices, social responsibility, and corporate governance. The Firm may exclude certain sectors, such as firearms, fossil fuels, and tobacco, and may apply additional restrictions based on client preferences. The consideration of ESG factors may vary depending on the strategy, client mandate, and availability of data, and ESG factors may not be determinative in all investment decisions. New companies considered for inclusion on the Firm’s Approved Securities List (“ASL”) are subject to internal research and review by the Investment Committee. The Firm monitors securities on the ASL and may sell or reduce positions 3  based on changes in fundamentals, valuation, competitive positioning, management, sustainability profile, or other factors. The Firm believes that active shareholder engagement is an important component of long-term investing. The Firm seeks to engage with companies to encourage responsible corporate behavior and long-term value creation. The Firm’s fixed income strategy seeks to generate income and provide stability within a portfolio. The Firm focuses on high-quality issuers and generally avoids undue credit risk and long-duration exposures. Fixed income investments may include U.S. Treasury securities, foreign government bonds, and municipal and corporate bonds. Fixed income portfolios are typically constructed using laddered individual securities and are managed with a target duration generally ranging from approximately 18 months to four years. Fixed income strategies are generally managed separately from equity strategies and are typically offered as a distinct investment strategy. Investment Strategy Reynders, McVeigh’s investment philosophy is growth at a reasonable price (GARP). This philosophy is applied consistently across the portfolios, although asset allocation may vary based on client objectives and constraints. Equity Strategy: Portfolios invested in the equity strategy typically consist of 30 to 50 holdings. The Firm generally avoids heavily regulated industries, and sector allocations do not necessarily align with the weighting of the S&P 500 or MSCI World Index. The Firm’s equity management process is grounded in the belief that well-established companies with strong earnings and the potential for sustained dividend growth, when purchased at reasonable valuation levels, can generate attractive long-term results. Accounts invested in the equity strategy typically maintain equity exposures of 90% and greater. For accounts that are not large enough to fully implement the equity strategy, the Firm may recommend mutual funds or exchange-traded funds. The Firm may also recommend investment in the Reynders, McVeigh Core Equity Fund, which was developed to provide investors, regardless of portfolio size, with access to the Firm’s equity strategy. As discussed above in Item 5, the Firm’s SMA management fee does not apply to assets invested in the Fund. Fixed Income Strategy: Fixed income portfolios are tailored to each client’s individual circumstances. Tax status, liquidity requirements, and income objectives are key considerations in determining the appropriate allocation. The Firm monitors activity along the yield curve and may adjust maturities over time as securities mature. Balanced Strategy: Balanced portfolios combine the Firm’s equity and fixed income strategies with cash. Asset allocations are determined based on each client’s objectives, including growth, income, capital preservation, and liquidity needs. The Firm works with clients to establish target allocation ranges and reviews these allocations periodically. Allocations may be adjusted over time based on changes in client circumstances or market conditions Impact Investments: On a non-discretionary basis, the Firm may recommend that clients invest a portion of their portfolios in impact investments, which are bonds, private equity funds, or other investment products that seek environmental or social return alongside a financial return. Clients are counseled on the nature and risks of such investments prior to implementation. Impact investments may focus on social justice in low-income communities, affordable housing, food and sustainable agriculture, climate change, and global microfinance. The Firm will never invest in impact investments without the prior written consent of clients, even in an account over which the Firm otherwise has discretionary authority. Equity Investments Model: The Firm maintains an equity investment model to guide the investment of new capital in certain accounts. This model reflects the Firm’s current investment views and research, representing a standard for how the Firm implements its best ideas across accounts. Client portfolios may differ from the model due to factors such as client restrictions, tax considerations, and timing of implementation. Rebalancing may occur over a long period of 4  time. The Investment Committee maintains the model, and any changes to the model are communicated to the investment team promptly. Risks Related to Investment Strategies There are risks involved with any type of investment program. The list below is not a comprehensive list of the risks related to the investment strategies and products managed by Reynders, McVeigh. General Risks Investing involves risk of loss that clients should be prepared to bear. Reynders, McVeigh does not guarantee future performance. Securities respond differently to market developments. Investment performance depends on the judgment and expertise of the Firm’s investment professionals. There is no assurance that the Firm’s strategies will achieve their intended results. Errors in judgment, market movements that differ from expectations, or the loss of key investment personnel could adversely affect the value of client investments. Equity Securities: Investment portfolios may include positions in common stocks, preferred stocks, and convertible securities of U.S. issuers and non-U.S. issuers. Equity securities are subject to market risk and may fluctuate in value due to company-specific developments, industry conditions, and broader economic and market factors. Investments in small- and mid-capitalization companies may involve greater risk, including less predictable earnings, increased price volatility, and lower liquidity compared to larger, more established companies. Investments in foreign securities involve additional risks, including currency fluctuations, exchange control regulations, and economic, political, or monetary developments. Changes in foreign currency exchange rates relative to the U.S. dollar may adversely affect the value of assets denominated in foreign currency and impact clients’ overall returns. Investments in Fixed Income Securities: Investments in fixed income securities are subject to several risks, including credit risk, interest rate risk, and liquidity risk. Credit risk refers to the possibility that an issuer may be unable to meet principal and interest payments. Interest rate risk reflects the potential for changes in interest rates to adversely affect the value of fixed income securities. Liquidity risk may limit the ability to sell securities at desired times or prices. The value of fixed income investments may also be affected by changes in market conditions and perceptions of an issuer’s creditworthiness. Environmental, Social and Governance (ESG):The Firm’s commitment to social responsibility and ethical action is incorporated into its investment discipline, which also includes consideration of ESG criteria. The use of ESG criteria may result in the exclusion of certain securities for non-financial reasons. As a result, portfolios managed by the Firm may forego certain investment opportunities and may perform differently, including underperforming, compared to portfolios that do not incorporate ESG considerations. Proxy voting decisions are guided by ESG criteria and may not always support corporate initiatives that could produce maximum short-term gains in the value of underlying securities. The consideration of ESG factors may vary depending on the strategy, client mandate, and availability of data. Impact Investments: Impact investments involve a number of risks and may differ materially from traditional investments. These investments may be more volatile and could result in significant losses. Many impact investments are less liquid than publicly traded securities and may require extended holding periods, during which investors may be unable to access their capital. Impact investments may also involve higher minimum investment requirements, higher fees and expenses, and less transparency than traditional investments. In some cases, valuations may be less readily available or based on estimates, which may affect reported performance. In addition, impact investments may be more concentrated and may lack a long operating history, which can increase investment risk. 5  Clients should carefully review the offering and disclosure documents for each impact investment for a more detailed discussion of the associated risks. Registered Funds: Reynders, McVeigh may invest clients’ assets in open-end mutual funds and closed-end funds. Investments in these funds are subject to market risk, and their values will fluctuate. Registered funds involve additional fees and expenses, which are separate from and in addition to the Firm’s management fees described in Item 5. Closed-end funds may trade at a premium or discount to their net asset value and may be less liquid than open-end mutual funds. Exchange Traded Funds (ETFs): Investments in exchange-traded funds (“ETFs”) are subject to market risk and will fluctuate in value based on the performance of their underlying securities. ETFs involve additional fees and expenses, and as a result, the cost of investing in ETFs may exceed the cost of investing directly in the underlying securities. ETF shares trade on an exchange and may trade at prices above or below their net asset value (“NAV”). As a result, the Firm may purchase ETF shares at a premium to NAV or sell shares at a discount. ETF market prices are influenced by supply and demand and may be more volatile than the underlying portfolio of securities. In addition, ETFs may be subject to liquidity risk, which could limit the Firm’s ability to buy or sell positions at desired times or prices and may impact performance. Market Disruption: Significant market disruptions, including pandemics, natural or environmental disasters, war, terrorism, or other unforeseen events, may adversely affect local and global markets and normal market operations. Such events may result in increased market volatility, trading halts, or the closure of domestic or foreign exchanges and markets. Market disruptions may also negatively impact economic activity, individual companies, and investor sentiment, and may affect the value and liquidity of client investments. In addition, such events may exacerbate other risks described in this Brochure and may cause client accounts or the Fund to fail to meet their investment objectives. These events may also disrupt the operations of the Firm or its service providers, which could affect the Firm’s ability to manage client accounts or execute transactions. Cybersecurity Risk: The increasing use of technology in the financial services industry exposes the Firm and its service providers to cybersecurity risks. Cyber incidents may result from unauthorized access to systems, networks, or data, or from failures of technology infrastructure. Cybersecurity events may lead to the loss, misuse, or unauthorized access to confidential client information, disruptions in the Firm’s operations, the inability to process transactions, or financial losses. Such events may also result in regulatory penalties, legal liability, reputational damage, and additional costs. Cybersecurity risks are also present for issuers of securities in which client accounts invest, which may negatively affect the value of such investments. Although the Firm maintains policies and procedures designed to reduce cybersecurity risks, there can be no assurance that such measures will be effective, particularly with respect to systems outside the Firm’s control, including those of service providers and other third parties. Artificial Intelligence (AI): The Firm’s use of artificial intelligence (“AI”) tools may introduce operational, legal, and regulatory risks. These risks may arise from the use of AI in data processing, analysis, and other business activities. 6  AI tools may produce inaccurate, incomplete, or misleading outputs, which could lead to errors in decision-making, portfolio management, or other business functions. In addition, the use of AI may present risks related to the unauthorized use or disclosure of confidential or proprietary information, including the Firm’s or third parties’ intellectual property. The use of AI may also result in legal or regulatory risks, including potential violations of intellectual property rights, data protection requirements, or other applicable laws and regulations. The Firm maintains policies and procedures designed to govern the use of AI tools; however, there can be no assurance that such measures will be effective. In addition, evolving regulatory developments related to AI may impact the Firm’s ability to use such tools and may adversely affect the Firm’s operations. Item 9: Disciplinary Information Reynders, McVeigh is required to disclose any legal or disciplinary events that would be material to a client’s or prospective client’s evaluation of the Firm. The Firm has no such disciplinary events to report. Item 10: Other Financial Industry Activities and Affiliations Other Affiliations Reynders, McVeigh serves as the investment adviser to the Reynders, McVeigh Core Equity Fund (the “Fund”), a series of Capitol Series Trust. This relationship poses a risk of conflict of interest because the Firm has an incentive to recommend the Fund, as it receives management fees at the Fund level. The Firm addresses this conflict by disclosing the applicable fees and conflicts to clients and by waiving its asset-based SMA management fee on assets invested in the Fund. Clients should be aware that, in some cases, the fees and expenses associated with the Fund may exceed the fees that would otherwise be charged under the Firm’s SMA fee schedule. The Firm may recommend the Fund where it believes such investment provides appropriate exposure to the Firm’s strategy or offers diversification or other portfolio benefits. Prior to investing in the Fund, clients are provided with relevant disclosure documents, including the Fund’s prospectus and Statement of Additional Information (“SAI”). Reynders, McVeigh is affiliated with Highwood Productions, Inc., a Massachusetts corporation, through Charlton Reynders III, who serves as its president of this corporation. Highwood Productions, Inc. is the managing member of Dolphin Film Production, LLC. Item 11: Code of Ethics Reynders, McVeigh maintains a Code of Ethics (the “Code”) pursuant to Rule 204A-1 of the Investment Advisers Act of 1940. The Code requires all employees to place client interests first and comply with applicable laws and regulations. In summary, the Code addresses: 1) Personal trading by Access Persons and immediate family; 2) The use of material non-public information by the Firm or its employees; 3) The identification of conflicts of interest; and 4) The resolution of actual or potential conflicts. In addition to the Code, the Firm maintains policies addressing specific conflicts of interest, including outside business activities, gifts and entertainment, the protection of material non-public information, falsification or alteration of records, political contributions, and payments to government officials or employees. 7  A copy of the Code of Ethics is available to any client or prospective client upon request by contacting the Chief Compliance Officer at 617-226-9999. Reynders, McVeigh permits employees to invest in the same securities that are recommended to or purchased for clients, which creates a potential conflict of interest. The Code is designed to mitigate this conflict through restrictions on personal trading. These include pre-clearance requirements for covered securities, limitations on trading in close proximity to client transactions, and blackout periods intended to ensure that clients are given priority in investment opportunities. Employees are required to disclose all personal securities accounts to the Chief Compliance Officer and to report their personal securities transactions and holdings on a periodic basis. Employees must also certify annually that they have reviewed and complied with the Code. The Chief Compliance Officer, or her designee, monitors employee activity to ensure compliance with the Code and to prevent conflicts of interest between the Firm and its clients. The conflicts of interest associated with the Firm’s role as investment adviser to the Reynders, McVeigh Core Equity Fund are described in Item 10. Employees are permitted to invest in the Fund; however, such investments are subject to restrictions designed to prevent conflicts, including a minimum holding period, pre-clearance requirements, and monitoring for potential market timing activity. Employees are prohibited from making political contributions for the purpose of soliciting business from state or local governments. All contributions, regardless of established de minimis thresholds, require pre-clearance, and all political contributions must be reported to the Chief Compliance Officer on an annual basis. Employees are also required to report the receipt of, or intent to give, any gift, service, or entertainment above established de minimis thresholds to enable Compliance to evaluate the appropriateness of such activity. Item 12: Brokerage Practices Selection of Broker-Dealers Reynders, McVeigh seeks to obtain best execution for client transactions, taking into account both qualitative and quantitative factors. The Firm is not obligated to select the broker offering the lowest commission rate and may select a broker that provides superior execution or other services. In selecting broker-dealers, the Firm considers factors including: the experience and skill of the broker’s traders; the reasonableness of commission rates; the size and type of transaction; the broker’s history of prompt and reliable execution; financial strength and stability; the ability to handle large or complex trades; the ability to maintain confidentiality of trading activity; and administrative efficiency. Reynders, McVeigh is available as an investment adviser on certain custodial platforms maintained by broker-dealers that serve as custodians for a significant portion of client assets. These custodians may offer low or zero commission trading and administrative efficiencies, which may result in the Firm frequently selecting them to execute transactions, consistent with its duty to seek best execution. Please refer to “Brokerage for Client Referrals” and Item 14 for additional information regarding these arrangements. The Firm periodically reviews its broker-dealer relationships to evaluate execution quality and overall service. Soft Dollar Benefits Reynders, McVeigh does not engage in soft dollar practices and does not receive research or other products or services in exchange for client brokerage. The Firm may, however, receive market data, research reports, and other information from broker-dealers without charge. Such information is received without any agreement or obligation to direct client transactions to those broker-dealers. 8  Brokerage for Client Referrals Reynders, McVeigh participates in the Fidelity Wealth Advisor Solutions® Program (“WAS Program”), which creates a conflict of interest because the Firm has an incentive to recommend the use of Fidelity Brokerage Services, LLC (“FBS”) and its affiliates. Despite this incentive, the Firm’s participation in the WAS Program does not limit its duty to seek best execution for client transactions. Please see Item 14 for additional information regarding this arrangement. Directed Brokerage Reynders, McVeigh permits clients to direct brokerage. When clients do so, the Firm may be unable to achieve best execution and may be unable to aggregate trades with other client accounts. As a result, clients may pay higher transaction costs and receive less favorable execution. When brokerage is directed, the Firm does not have the authority to negotiate commissions or seek more favorable execution, and transactions will be executed through the selected broker at the rates established by that broker. Lower fees for comparable services may be available from other providers, including discount brokerage firms. Trade Allocation and Aggregation Reynders, McVeigh may aggregate orders for the purchase or sale of the same security across multiple client accounts, subject to its duty to seek best execution. The Firm is not obligated to include any particular client account in a block trade and will do so only when it believes it is in the client’s best interest. When trades are aggregated, the Firm seeks to allocate executions in a manner that is fair and equitable over time and does not systematically disadvantage any client. Trade Errors A trade error is a mistake in the execution of a transaction. Errors in investment judgment are not considered trade errors. While the Firm seeks to avoid errors, they may occur and will be corrected promptly. Clients will not bear the cost of trade errors. The Firm and/or the executing broker-dealer will bear any associated costs. Internal Cross Transactions Reynders, McVeigh may engage in internal cross transactions for fixed income securities, in which a security is transferred between client accounts at the same price. The Firm does not engage in internal cross transactions for equity securities. These transactions create a conflict of interest because they are not executed in the open market. The Firm will only effect such transactions when they are executed on equal terms for each client involved and in a manner that the Firm believes is fair and appropriate for both clients. The Firm does not receive compensation, and its employees do not receive compensation, in connection with internal cross transactions. Item 13: Review of Accounts Portfolios are reviewed at least quarterly. Fixed income positions and allocations are reviewed on an ongoing basis for balanced and fixed income portfolios. At the outset of each client relationship, the Firm establishes investment parameters with the client that guide the review process. 9  Material changes in a client’s financial circumstances or in market or economic conditions may result in more frequent reviews. Clients are responsible for notifying the Firm of any changes in their circumstances that may affect their investment objectives. The Firm may also provide investment advice between formal reviews. For the Firm’s sub-advisory relationships, the Firm relies on the primary investment manager or adviser responsible for the overall client relationship to conduct periodic reviews and assess the continued appropriateness of the account. Accordingly, the Firm generally does not independently perform such reviews and relies on the primary adviser or client to communicate any relevant changes in circumstances. The Firm provides clients with quarterly reports that include portfolio holdings, performance information, and market commentary. Clients may elect to receive reports electronically. Clients also receive account statements directly from their custodian, which reflect account holdings and activity. For certain investments, including impact investments, market values may not be readily available and may be based on estimates or carried at cost. The Firm may, at its discretion, provide financial plans to certain clients who meet minimum account requirements. Financial planning services are not considered part of the Firm’s investment advisory services under its investment advisory agreements with its clients. They are generally provided on a point-in-time basis and are not updated unless otherwise agreed. Item 14: Client Referrals and Other Compensation Reynders, McVeigh may, from time to time, provide compensation for client referrals. In any such case, the Firm will provide disclosures to prospective clients regarding the referral arrangement in accordance with applicable SEC rules. Participation in Fidelity Wealth Advisor Solutions®: Reynders, McVeigh participates in the Fidelity Wealth Advisor Solutions® Program (the “WAS Program”), through which the Firm receives referrals from Strategic Advisers LLC (Strategic Advisers), a registered investment adviser and Fidelity Investments company. This arrangement creates a conflict of interest because the Firm has a financial incentive to participate in the WAS Program and to recommend Fidelity and its affiliates. Reynders, McVeigh is not affiliated with Strategic Advisers or any Fidelity Investments company. Strategic Advisers does not supervise or control Reynders, McVeigh, and Strategic Advisers has no responsibility or oversight for the Firm’s provision of investment management or other advisory services. Under the WAS Program, Strategic Advisers acts as a solicitor for Reynders, McVeigh, and Reynders, McVeigh pays referral fees to Strategic Advisers for each referral received based on the Firm’s assets under management attributable to each client referred by Strategic Advisers or members of each client’s household. The WAS Program is designed to help investors find an independent investment advisor, and any referral from Strategic Advisers to Reynders, McVeigh does not constitute a recommendation by Strategic Advisers of the Firm’s particular investment management services or strategies. More specifically, Reynders, McVeigh pays the following amounts to Strategic Advisers for referrals: the sum of (i) an annual percentage of 0.10% of any and all assets in client accounts where such assets are identified as “fixed income” assets by Strategic Advisers and (ii) an annual percentage of 0.25% of all other assets held in client accounts. In addition, Reynders, McVeigh has agreed to pay Strategic Advisers an annual program fee of $50,000 to participate in the WAS Program. These referral fees are paid by Reynders, McVeigh and not the client. To receive referrals from the WAS Program, Reynders, McVeigh must meet certain minimum participation criteria, but the Firm has been selected for participation in the WAS Program as a result of its other business relationships with Strategic Advisers and its affiliates, including Fidelity Brokerage Services, LLC (“FBS”). Strategic Advisers’ receipt of compensation for the client referrals to Reynders, McVeigh creates a conflict of interest for Strategic Advisers because Strategic Advisers has a financial incentive to refer clients only to advisers that participate in the WAS Program, including the Firm. As a result of its participation in the WAS Program, Reynders, McVeigh also has a 10  conflict of interest with respect to its decision to use certain affiliates of Strategic Advisers, including FBS, for execution, custody and clearing for certain client accounts, and the Firm could have an incentive to suggest the use of FBS and its affiliates to its advisory clients, whether or not those clients were referred to Reynders, McVeigh as part of the WAS Program. Under an agreement with Strategic Advisers, Reynders, McVeigh has agreed that the Firm will not charge clients more than the standard range of advisory fees disclosed in its Form ADV 2A Brochure to cover solicitation fees paid to Strategic Advisers as part of the WAS Program. Reynders, McVeigh generally does not discount its standard fee rates for individual client accounts. However, because of the fees paid to Strategic Advisers as part of the WAS Program, Reynders, McVeigh may be less willing to negotiate discounted advisory fees with clients referred by Strategic Advisers than would be the case with clients for which no referral fees are paid. To participate in the WAS Program, Reynders, McVeigh has agreed not to solicit clients to transfer their brokerage accounts from affiliates of Strategic Advisers or establish brokerage accounts at other custodians for referred clients other than when Firm’s fiduciary duties would so require, and Reynders, McVeigh has agreed to pay Strategic Advisers a one-time fee equal to 0.75% of the assets in a client account that is transferred from Strategic Advisers’ affiliates to another custodian; therefore, Reynders, McVeigh has conflict of interest because of the financial incentive to suggest that referred clients and their household members maintain custody of their accounts with affiliates of Strategic Advisers. However, participation in the WAS Program does not limit Reynders, McVeigh’s duty to select brokers on the basis of best execution. Despite these arrangements, the Firm remains obligated to act in the best interests of its clients and to seek best execution for all transactions. Item 15: Custody Reynders, McVeigh is deemed to have custody of client assets in certain circumstances, including when the Firm is authorized to deduct its management fees from client accounts and when Firm personnel serve as trustees for advised trust accounts. For accounts over which the Firm has custody due to trustee relationships, an independent public accountant conducts an annual surprise examination in accordance with Rule 206(4)-2 under the Investment Advisers Act of 1940 (the “Custody Rule”). Clients should receive account statements at least quarterly from the qualified custodian (e.g., broker-dealer or bank) that holds their assets. The Firm urges clients to carefully review these custodial statements and compare them to any reports provided by the Firm. Differences may occur due to accounting methods, reporting dates, or valuation methodologies. For tax and other official purposes, the custodial statement should be relied upon as the authoritative record of the account. Item 16: Investment Discretion Reynders, McVeigh determines whether it has investment discretion over a client’s account at the outset of each advisory relationship through the Investment Management Agreement. This agreement specifies the scope of the Firm’s authority, including any limitations or restrictions imposed by the client. Clients may impose restrictions on investments in specific securities or asset classes, which are maintained in the Firm’s systems. In addition, the Firm requires separate client authorization prior to investing in impact investments. 11  Item 17: Voting Client Securities – Proxy Voting Reynders, McVeigh votes proxies on behalf of clients, unless a client directs otherwise, to the extent that the client’s custodian provides access to proxy voting by advisers. Proxy voting decisions are guided by the Firm’s policies and procedures, which incorporate environmental, social, and governance considerations. Clients may elect not to have the Firm vote proxies on their behalf or may direct the Firm’s vote for a particular proxy by providing timely written instructions. The Firm reviews its proxy voting policies and procedures periodically and may revise them as appropriate. The Firm seeks to vote proxies in a manner consistent with its investment approach, including consideration of environmental, social, and governance factors, and in the best interests of clients. Conflicts of interest may arise in connection with proxy voting. When a conflict is identified, the matter is reviewed by the Firm’s management and voted in accordance with the Firm’s policies and procedures. Reynders, McVeigh utilizes a third-party service provider to assist with the administration of proxy voting. Clients may obtain information about how their securities were voted and may request a copy of the Firm’s proxy voting policies and procedures by contacting the Firm. Item 18: Financial Information Reynders, McVeigh is required to provide certain financial information under this Item. The Firm has no financial commitments that are reasonably likely to impair its ability to meet contractual or fiduciary obligations to clients and has not been the subject of a bankruptcy proceeding. The Firm does not require or solicit prepayment of fees of $1,200 or more per client, six months or more in advance. 12