Summit Trail Advisors, LLC

SUMMIT TRAIL ADVISORS, LLC SEC FILE NUMBER: 801 – 99352 Disclosure Brochure Dated: March 31, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Summit Trail Advisors, LLC (“Summit Trail” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact us at (212) 812-7010. The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Summit Trail Advisors, LLC and its investment adviser representatives (“Advisory Persons”) is also available on the SEC’s website at http://www.adviserinfo.sec.gov by searching with our firm name or our firm CRD# 220519. Registration with the SEC or with any state securities authority does not imply a certain level of skill or training. Contact: Joseph Erigo, Chief Compliance Officer 2 Grand Central Tower, 140 E 45th Street, 28th Floor, New York, NY 10017 Phone: (212) 812-7010 www.summittrail.com  ITEM 2: MATERIAL CHANGES Certain routine updates and clarifying changes have been made to this Disclosure Brochure since the last filing and distribution to Clients, however, there have been no material changes. 2 | Summit Trail Advisors, LLC March 31, 2026  Item 3: Table of Contents 2 ITEM 2: MATERIAL CHANGES 3 ITEM 3: TABLE OF CONTENTS 4 ITEM 4: ADVISORY BUSINESS 10 ITEM 5: FEES AND COMPENSATION 16 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT 16 ITEM 7: TYPES OF CLIENTS 16 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 21 ITEM 9: DISCIPLINARY INFORMATION ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 22 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING 24 25 ITEM 12: BROKERAGE PRACTICES 27 ITEM 13: REVIEW OF ACCOUNTS 27 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION 29 ITEM 15: CUSTODY 29 ITEM 16: INVESTMENT DISCRETION 30 ITEM 17: VOTING CLIENT SECURITIES 30 ITEM 18: FINANCIAL INFORMATION 3 | Summit Trail Advisors, LLC March 31, 2026  ITEM 4: ADVISORY BUSINESS A. Firm Information Summit Trail Advisors, LLC (“Summit Trail” or the “Advisor”) is a limited liability company formed on July 6, 2015 in the state of Delaware. Summit Trail is a wholly owned subsidiary of Summit Trail Holdings, LLC and is operated by Jack Petersen (Managing Partner), David Romhilt, CFA (Chief Investment Officer) and Joseph Erigo (Chief Compliance Officer). The Advisor became a registered Investment advisor with the U.S. Securities and Exchange Commission (“SEC”) in June 2015. The Advisor’s Chief Compliance Officer (“CCO”) remains available to address any questions that a Client or prospective Client may have regarding this Disclosure Brochure. B. Advisory Services Offered The Advisor offers investment advisory services to individuals, business entities, trusts, estates, charitable organizations, and pension and profit sharing plans (each a “Client”). To the extent specifically requested by a Client, the Advisor will also provide financial planning and related consulting services. In the event that the Client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of the Advisor), the Advisor may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written agreement with the Client. The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Advisory Services The Client can determine whether to engage the Advisor for investment advisory services on a discretionary and/or non-discretionary basis. Clients who choose to engage the Advisor on a non- discretionary basis must be willing to accept that the Advisor cannot execute any account transactions without obtaining the Client’s prior consent to any such transaction(s). Therefore, in the event that the Advisor would like to make a transaction for a Client’s account, and Client is unavailable, the Advisor will be unable to execute the account transaction (as it would for its discretionary Clients) without first obtaining the Client’s consent. to, investment performance, fund manager tenure, As part of its investment advisory services, Summit Trail will review Client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited style drift, account additions/withdrawals, and/or a change in the Client’s investment objective. Based upon these 4 | Summit Trail Advisors, LLC March 31, 2026  factors, Summit Trail can determine that during extended periods of time changes to a Client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Summit Trail will be profitable or equal any specific performance level(s). Summit Trail invests in and recommends mutual funds on behalf of Clients. When investing in mutual funds, Summit Trail seeks to allocate Client capital to non-retail or institutional classes when possible. Due to specific custodial or mutual fund company constraints, material tax considerations, and/or systematic investment plans, Summit Trail will at times be unable to allocate Client capital to non-retail or institutional classes and will instead invest on a Client’s behalf in a mutual fund share class that has a higher expense ratio than a non-retail or institutional share class, as described in Item 5. Summit Trail will seek to select the lowest cost share class available that is in the best interest of each Client and will ensure the selection aligns with the Client’s financial objectives and stated investment guidelines. Use of Independent Managers – For those Clients that require an enhanced and/or specialized level of investment management services, the Advisor may also recommend that certain Clients authorize the active discretionary management of a portion of their assets by and/or among certain independent investment manager(s) (“Independent Managers”). To the extent applicable, the Advisor will recommend Independent Managers consistent with the Client’s investment objectives. Factors which the Advisor will consider in recommending Independent Managers include the Client’s stated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The Advisor will continue to render advisory services to the Client relative to the ongoing monitoring and reviewing of account performance, for which the Advisor will receive an annual advisory fee per Item 5 below which is based upon a percentage of the market value of the assets being managed by the designated Independent Managers. Clients who choose to engage the Advisor and elect to utilize Independent Managers will incur costs in addition to the Advisor’s advisory fee. Management fees charged by Independent Managers, together with the fees charged by the broker-dealer/custodian of the Client’s assets, and any independent manager platform provider fee are exclusive of, and in addition to, Advisor’s investment advisory fee. Additionally, the Advisor may provide investment advisory services to executives and/or principals of certain unaffiliated Independent Managers, thereby creating a conflict of interest. To the extent that the Advisor believes that the utilization of these investment managers is appropriate for a Client, the Advisor shall disclose the conflict to the Client and give the Client the right to restrict, in writing, the Advisor’s use of an Independent Manager. Private Fund Investments - The Advisor provides investment advice or investment-related services regarding affiliated and unaffiliated private investment funds. Unaffiliated Funds – The Advisor’s role relative to any unaffiliated private investment fund is limited to its initial and ongoing due diligence and investment monitoring services. If a Client decides to become an investor in an unaffiliated private fund, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of the Advisor calculating its investment advisory fee per Item 5 below 5 | Summit Trail Advisors, LLC March 31, 2026  (unless the Client purchases the fund from the Advisor’s affiliated broker- dealer, where a separate placement fee is assessed - see Item 10 below). The Advisor’s Clients are under no obligation to consider or make an investment in an unaffiliated private investment funds. Affiliated Funds - The Advisor is the General Partner and/or Investment Advisor to various private funds issued by Ascent Private Capital Management (the Affiliated Fund[s]). If a Client determines to invest in an Affiliated Fund, the amount of assets invested in the Affiliated Fund will be included as part of “assets under management” for purposes of the Advisor calculating its investment advisory fee per Item 5 below. The Advisor’s Clients are under no obligation to consider or make an investment in an Affiliated Fund. The Advisor does not receive a separate advisory fee or any other form of compensation for its investment advisory services to any Affiliated Funds. Rather, the Advisor’s only compensation is the advisory fee that it receives from any value included as a part of assets under management. Outsourced Chief Investment Officer Services investment managers, and monitoring and evaluating Certain Institutional Clients engage the Advisor for Outsourced Chief Investment Officer services (“OCIO Services”). The OCIO Services include assistance in defining investment policies and objectives, selecting investment performance of the Institutional Clients’ end retail clients (“End Retail Clients”). The OCIO Services are expressly limited to investment consulting services and do not include financial planning or any other related or unrelated services. Institutional Clients will ultimately determine, in their sole discretion, whether the Advisor’s recommendations are suitable for a particular End Retail Client. In the event that the Advisor is requested to provide consulting services with respect to investments in a retirement plan for an End Retail Client, the Advisor’s recommendations are limited to the investment options provided by the retirement plan. The Advisor’s OCIO services are provided solely pursuant to a written agreement between the Advisor and the Institutional Client. Institutional Clients enrolled in the OCIO Services maintain the exclusive responsibility to accept/reject or implement any of the Advisor’s recommendations or advice provided pursuant to the OCIO Services. Through the Advisor’s OCIO Services, Institutional Clients can also access certain advisory products offered by the Advisor such as private fund investments, model portfolios and other Advisor- managed investment vehicles. Additionally, an End Retail Client may also engage the Advisor individually for its investment advisory services. Each of the services and engagements described in this section are at the Client’s discretion. Financial Planning and Consulting Services The Advisor provides certain Clients with financial planning and/or consulting services. Clients can also engage the Advisor for stand-alone financial planning services and related consulting services regarding non-investment related matters, including, but not limited to, estate planning, tax planning and insurance needs. Prior to engaging the Advisor to provide stand-alone financial planning or consulting services, Clients are generally required to enter into a Financial Planning and Consulting Agreement with Advisor setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the Client prior to Advisor commencing services. 6 | Summit Trail Advisors, LLC March 31, 2026  If requested by the Client, the Advisor may recommend the services of other professionals for implementation purposes (i.e., attorneys, accountants, brokers, insurance agents, etc.). The Client is under no obligation to engage the services of any such recommended professional. The Client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Advisor or its Advisory Persons. If a Client engages an unaffiliated recommended professional, and a dispute arises thereafter relative to such engagement, the Client’s recourse is typically contractually limited exclusively to the engaged professional. Additionally, it remains the Client’s responsibility to promptly notify the Advisor if there is any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising the Advisor’s previous recommendations and/or services. If the Advisor has been engaged to provide non-discretionary consulting services relative to Client investment assets for which the Advisor does not maintain any trading authority, including assets managed by the Client’s other unaffiliated investment professionals, (the “Excluded Assets”), the Client and/or the Client’s other investment professionals/advisors that maintain trading authority, and not the Advisor will be exclusively responsible for the investment performance of the Excluded Assets. The Advisor disclaims any responsibility for the actions and/or omissions of the Client’s other investment professionals/advisors. The Client is under absolutely no obligation to accept any of Advisor’s advice or recommendations relative to the Excluded Assets. In the event the Client desires that the Advisor provide investment management services for the Excluded Assets, the Client may engage the Advisor to do so pursuant to the terms and conditions of an investment advisory agreement between the Advisor and the Client. The Advisor also provides periodic reporting services which can incorporate all of the Client’s investment assets, including Excluded Assets. Generally, unless otherwise specifically agreed in writing, Advisor’s service relative to the Excluded Assets is limited to reporting only. Notwithstanding the preceding sentence, if the Advisor has, from time to time, been engaged to monitor and/or allocate the assets within a Client’s 401(k) account maintained at the custodian directed by the Client’s employer. As such, except with respect to a Client’s 401(k) account (if applicable), Advisor does not maintain any trading authority for the Excluded Assets. Rather, the Client and/or the Client’s designated other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. In the event a Client desires that Advisor provide investment management services for the Excluded Assets, the Client must engage the Advisor to do so pursuant to the terms and conditions of the Investment Advisory Agreement between Advisor and the Client. In addition to the other services it offers, the Advisor also offers certain family office services to Clients. Clients have the option to select from a number of services, which include but are not limited to: Active Estate Management – Aggregating family and financial information to develop plans and investment solutions that address overall needs and objectives. Advisor Coordination – Support services including coordination of advisory teams (banks, legal, insurance, tax accountants, family services, benefit organization), due diligence support, and accounting support. 7 | Summit Trail Advisors, LLC March 31, 2026  Reporting – Dashboard created to help navigate financial and legal landscape, consolidated balance sheets, estate plan analysis, and maintaining relevant documentation. Philanthropy – Assist with philanthropic goals through account structure and funding, grant review and administration and investment opportunities. Cash Management – Assist with cash and lending needs. Tax Planning– Coordination and oversight of personal tax planning and coordination with tax preparers. Additional services include estate planning, structuring of trusts and foundations, residential and lifestyle management and insurance. Summit Trail does not serve as an attorney or accountant, and no portion of our services should be construed as legal or tax advice. Accordingly, Summit Trail does not prepare legal documents or tax returns. Retirement Plan Advisory Services Summit Trail provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations by providing education services to the Plan and its participants. These services are provided by Summit Trail serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Summit Trail’s fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. Miscellaneous Retirement Plan Rollovers – No Obligation / Conflict of Interest: A Client or prospective Client leaving an employer typically has four options regarding an existing retirement plan (and has the ability to select a combination of these options): (i) leave the assets in the former employer’s retirement plan, if permitted, (ii) roll the assets over to the new employer’s retirement plan, if one is available and if rollovers are permitted, (iii) roll the assets over to an individual retirement account (“IRA”), or (iv) cash out the account value (which could, depending upon the Client’s age, result in adverse tax consequences). If the Advisor recommends that a Client roll over their retirement plan assets into an account to be managed by the Advisor, such a recommendation presents a conflict of interest if the Advisor will earn new (or increase its current) compensation as a result of the rollover. The Advisor does not generally provide recommendations to Clients on rollovers. However, if the Advisor provides a recommendation as to whether or not a Client should engage in a rollover, Advisor is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No Client is under any obligation to rollover retirement plan assets to an account managed by the Advisor. 8 | Summit Trail Advisors, LLC March 31, 2026  Bitcoin, Cryptocurrency, and Digital Assets. The Advisor does not recommend or advocate for the purchase of, or investment in, Bitcoin, cryptocurrencies, or digital assets. Such investments are considered speculative and carry significant risk. For clients who want exposure to Bitcoin, cryptocurrencies, or digital assets, the Advisor, may advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Bitcoin and cryptocurrencies are digital assets that can be used for various purposes, including transactions, decentralized applications, and speculative investments. Most digital assets use blockchain technology, an advanced cryptographic digital ledger to secure transactions and validate asset ownership. Unlike conventional currencies issued and regulated by monetary authorities, cryptocurrencies generally operate without centralized control, and their value is determined by market supply and demand. While regulatory oversight of digital assets has evolved significantly since their inception, they remain subject to variable regulatory treatment globally, which may impact their risk profile and liquidity. Given that cryptocurrency investments are speculative and subject to extreme price volatility, liquidity constraints, and the potential for total loss of principal, the Advisor does not exercise discretionary authority to purchase cryptocurrency investments for client accounts. Any investment in cryptocurrencies must be expressly authorized by the client. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility, regulatory risk, technological risk, security and custody risk, and complete loss of principal. C. Client Account Management The Advisor shall provide investment advisory services specific to the needs of each Client. Prior to providing investment advisory services, an Advisory Person will ascertain each Client’s investment objective(s). Thereafter, the Advisor will allocate and/or recommend that the Client allocate investment assets consistent with the designated investment objective(s). The Client may, at any time, impose reasonable restrictions, in writing, on the Advisor’s services. Cash Sweep Accounts: Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, Advisor shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless the Advisor reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the Client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the Client of an imminent need for such cash, or the Client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within an actively managed investment strategy (the cash balances for which shall generally remain in the custodian 9 | Summit Trail Advisors, LLC March 31, 2026  designated cash sweep account), an indication from the Client of a need for access to such cash, assets allocated to an unaffiliated investment manager and cash balances maintained for fee billing purposes. The Client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any unmanaged accounts. D. Wrap Fee Program The Advisor no longer offers a wrap fee program to new Clients, however, the Advisor has legacy Clients where securities transaction fees are combined with a n investment advisory fee into a single asset-based fee. E. Assets Under Management As of January 2, 2026, the Advisor had assets under management of $19,941,615,810. This includes $11,063,331,227 that is managed on a discretionary basis and $8,878,284,583 on a non- discretionary basis. ITEM 5: FEES AND COMPENSATION A. Fees for Advisory Services Investment Advisory Services The Advisor’s annual fee for investment advisory services shall generally be based upon a percentage (%) of the market value and type of assets placed under the Advisor’s management, payable quarterly in advance. Investment advisory fees range up to 1.50% annually based on several factors, including: the complexity of the services to be provided, the level of assets to be managed, and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. Alternatively, the Advisor can choose to offer its investment advisory services on a flat fee basis. To the extent offered, the Advisor’s flat fee will be based upon various subjective and objective factors and will not exceed the above fee rate. The Advisor’s annual fee is billed and payable on a pro-rata basis, quarterly in advance, based upon the market value of the assets being managed by Summit Trail on the last day of the previous quarter. Reconciliations are performed on a quarterly basis to capture the difference in the market value of the assets on the last day of the previous quarter and the average daily balance of the assets for the quarter. An adjustment will be made in the form of a credit or debit to reflect the difference. In the event the portfolio management agreement is terminated, the fee for the final billing period will be prorated through the effective date of termination, and the outstanding or unearned portion of the fee will be charged or refunded to you, as appropriate. Summit Trail management fee is negotiable, depending on individual Client circumstances. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which will be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. 10 | Summit Trail Advisors, LLC March 31, 2026  Use of Independent Managers - For Client accounts implemented through an Independent Manager, the Client’s overall fees will include Summit Trail’s investment advisory fee (as noted above) plus advisory fees and/or platform fees charged by the Independent Managers, as applicable, unless otherwise agreed to by Summit Trail. The Independent Manager may assume responsibility for calculating the Client’s fees and deducting all fees from the Client’s accounts. In such instances, Summit Trail will not charge its fee separately on those assets. Turnkey asset management programs (“TAMP”) related charges are not included in the investment management fee paid to Summit Trail. Clients will be charged, separate from and in addition to their investment management fee, any applicable TAMP fees as well as applicable Independent Manager fees. The Advisor is affiliated with Dynasty Financial Partners, LLC (“Dynasty”), Dynasty is also a TAMP provider (See Item 10 below). The Advisor does not receive any portion of the fees paid directly to Dynasty or the service providers made available through Dynasty’s TAMP, including the Independent Managers. TAMP and Independent Manager fees are determined by the particular TAMP and Independent Managers with which Client assets are invested, and are calculated based upon a percentage of assets under management, as applicable. The program fee generally ranges up to 0.45% annually. Clients should note the total fees reflected on custodial statements represent the aggregate of Summit Trail’s investment management fee, TAMP fee and Independent Manager fee, accordingly. Clients are urged to review such statements to determine the total amount of fees associated with assets placed with Independent Managers. Client should also review the investment management agreement with Summit Trail to determine the investment management fee paid to the Advisor. Outsourced Chief Investment Officer Services OCIO Services are subject to an annual fee of approximately $150,000 per year charged quarterly in advance. For investments in the Advisor’s funds, full details concerning fees are disclosed within the fund’s offering documents. If an End Retail Client chooses to engage the Advisor for investment advisory services, the Advisor would retain approximately 30%-40% of the investment advisory fee disclosed above, subject to a 0.25% minimum floor in accordance with the Institutional Client’s standard billing practices. The remainder of this fee will be portioned out to the Institutional Client. Financial Planning and Consulting Services The Advisor also provides financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand- alone separate fee basis. The Advisor’s planning and consulting fees are negotiable, but generally range from $5,000 to $100,000 per year on a fixed fee basis, and from $500 to $1,000 on an hourly basis, depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). Certain Clients begin their engagement with the Advisor pursuant to the planning and consulting arrangement described in the preceding paragraph and then, when their assets under management with the Advisor reach a certain threshold, become subject to the fee arrangement for advisory services as described above. Any unearned fees paid by the Client will be reconciled 11 | Summit Trail Advisors, LLC March 31, 2026  and refunded or credited to the Client in accordance with the procedures applied for reconciliation of fees with respect to advisory services described above. Family Office Services Family office services are either inclusive of the investment management fees disclosed above or are charged as a separate fixed fee ranging up to a total of $300,000, pursuant to the written agreement. Fixed fees are comprised of a one-time fee and/or ongoing fee, based on the engaged upon services. These fees are negotiable depending on the nature, complexity and scope of services to be rendered. Retirement Plan Advisory Services Fees Fees for retirement plan advisory services are charged an annual asset-based fee ranging between 0.20% to 0.50%, billed in advance, pursuant to the terms of the agreement. Retirement plan fees are based on the market value of assets under management at the end of the prior calendar quarter. Fees are negotiable at the sole discretion of the Advisor. B. Fee Billing Investment Advisory Services Clients may elect to have investment advisory fees deducted from their account(s) at the custodian. Both the Advisor's Investment Advisory Agreement and the custodial/clearing agreement authorize the custodian to debit each account for the amount of the Advisor's investment advisory fee and to directly remit that management fee to the Advisor in compliance with regulatory procedures. In the limited event that the Advisor bills the Client directly, payment is due upon receipt of the Advisor’s invoice. Unless otherwise agreed, the Advisor shall deduct fees and/or bill Clients quarterly in advance, based upon the market value of the Client’s assets during the previous billing period (“Billing Period”) as valued by the custodian of the assets. No increase in the annual fee percentage shall be effective without prior consent. Clients may make additions to and withdrawals from their account(s) at any time. However, reconciliations are performed on a quarterly basis to capture the difference in the market value of the assets on the last day of the previous quarter and the average daily balance of the assets for the quarter. An adjustment will be made in the form of a credit or debit to reflect the difference. For the initial period of an engagement, the fee is calculated on a pro rata basis through the end of the quarter. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the unearned portion is refunded to the Client, as appropriate. Use of Independent Managers – Client accounts implemented through Independent Managers will be billed in accordance to the separate agreements with the respective parties. These parties will typically add Summit Trail’s investment advisory fee and deduct the overall fee from the Client’s accounts. Private Fund Investments – The Advisor may also provide investment advisory services with respect to unaffiliated and affiliated private fund investments, which are not held at the Primary Custodian. In such instances, the Client shall be required to complete the applicable private placement and/or account opening documents to establish these investments. The Advisor will debit its fee for providing investment advisory services with respect to these relationships directly from a brokerage account designated by the Client held at the Primary Custodian. For certain 12 | Summit Trail Advisors, LLC March 31, 2026  non-custodial partnership/private fund investments, the Advisor may not receive quarter-end investment valuations prior to its fee billing calculation. In such instances, the Advisor will use the most recent period-end valuation available for the calculation of investment advisory fees. The Advisor will recalculate its fee upon receipt of final valuations. Adjustments are reflected in the fee calculations for the next quarterly period. Financial Planning and Consulting Services Financial planning and consulting fees will be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverables. Retirement Plan Advisory Services Fees Summit Trail is compensated for its services at the beginning/end of the quarter before/after advisory services are rendered, as applicable. Fees will be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms of the retirement plan advisory agreement. C. Other Fees and Expenses Certain clients will incur fees or charges imposed by third parties in connection with investments made on behalf of the Client’s accounts. The Client is responsible for all securities execution and custody fees charged by the Custodian, if applicable. Certain recommended Custodians do not charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and condition of the Custodian's brokerage requirements. However, the Custodians typically charge for mutual funds and other types of investments. The fees charged by the Advisor are separate and distinct from these custody and execution fees. For certain legacy clients, the Advisor includes securities transaction costs and Client-directed trades as part of its overall investment advisory fee through the Advisor’s wrap fee program. Please see Appendix 1 – Wrap Fee Program Brochure. In addition, mutual funds and ETFs generally charge fees and expenses to their shareholders. These fees and expenses are described in each fund’s prospectus and are in addition to the fees and expenses charged by the Advisor. A Client may be able to invest in these products directly, without the services of the Advisor. Accordingly, Clients should review both the fees charged by the funds and the fees charged by the Advisor to fully understand the total fees and expenses they will bear. Please refer to Item 12 – Brokerage Practices for additional information. Tradeaway/Prime Broker Fees - Relative to its discretionary investment advisory services, when beneficial to the Client, individual fixed income transactions can be effected through broker- dealers other than the account custodian, in which event, the Client generally will incur both the fee (commission, mark-up/mark-down) charged by the executing broker-dealer and a separate “tradeaway” and/or prime broker fee charged by the account Custodian. Clients who engage the Advisor on a wrap fee basis may be exempt from tradeaway and/or prime broker fees. 13 | Summit Trail Advisors, LLC March 31, 2026  D. Advance Payment of Fees and Termination Investment Advisory Services The Advisor is compensated for its services at the beginning of the quarter before investment advisory services are rendered. Either party may request to terminate the investment advisory agreement with the Advisor, at any time, by providing advance written notice to the other party. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers - In the event that a Client should wish to terminate their relationship with an Independent Manager, the terms for termination will be set forth in the respective agreements between the Client and the Independent Manager. Summit Trail will assist the Client with the termination and transition as appropriate. Outsourced Chief Investment Officer Services The Advisor is compensated for its services at the beginning of the quarter before OCIO Services are rendered. Either party may terminate the OCIO Services agreement by providing advance written notice to the other party. Upon termination, the Client will be billed for the percentage of the engagement scope completed by the Advisor. The Advisor will refund any unearned, prepaid fees from the effective date of termination. The Client’s OCIO Services agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning and Consulting Services The Advisor may require an advance deposit as described above. Either party may terminate the financial planning and consulting agreement by providing advance written notice to the other party. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. The Advisor will refund any unearned, prepaid planning fees from the effective date of termination. The Client’s financial planning and consulting agreement with the Advisor is non-transferable without the Client’s prior consent. Family Office Services The Advisor may require an advance deposit as described above. Either party may terminate the family office services by providing advance written notice to the other party. Upon termination, the Client shall be billed for the percentage of the engagement scope completed by the Advisor. The Advisor will refund any unearned, prepaid planning fees from the effective date of termination. The Client’s agreement with the Advisor is non-transferable without the Client’s prior consent. Retirement Plan Advisory Services Fees Either party may request to terminate their services with Summit Trail in whole or in part, by providing advance written notice to the other party. The Client shall be responsible for investment advisory fees up to and including the effective date of termination. The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s retirement plan services agreement with the Advisor is non-transferable without the Client’s written approval. 14 | Summit Trail Advisors, LLC March 31, 2026  E. Compensation for Sales of Securities Broker-Dealer Affiliation In the event that the Client desires, the Client can engage certain Advisory Persons, in their individual capacities, as registered representatives of Summit Trail Securities, LLC (“STS”), an SEC registered and FINRA member broker-dealer, owned by the Advisor, to implement investment recommendations for a placement fee. In the event the Client chooses to purchase investment products through STS, STS will charge a placement fee to effect securities transactions, a portion of which placement fee STS will pay to the representative, as applicable. The placement fee charged by STS can be higher or lower than those charged by other broker- dealers. 1. Conflict of Interest: The recommendation that a Client purchase a placement fee product from STS presents a conflict of interest, as the receipt of placement fees provide an incentive to recommend investment products based on placement fees to be received, rather than on a particular Client’s need. No Client is under any obligation to purchase any products from an Advisor representative. 2. Clients may purchase investment products recommended by Advisor through other, non- affiliated broker-dealers. 3. The Advisor does not receive more than 50% of its revenue from advisory Clients as a result of placement fees or other compensation for the sale of investment products the Advisor recommends to its Clients. 4. When a representative sells an investment product, the Advisor does not charge an advisory fee in addition to the placement fees paid by the Client for such product. However, a Client may engage the Advisor to provide investment management services on an advisory fee basis and separate from such advisory services purchase an investment product from an Advisory Person on a separate placement fee basis. Certain Advisory Persons are also registered representatives of The Leaders Group, Inc. (“Leaders”). Leaders is a registered broker-dealer (CRD# 37157), member FINRA, SIPC. In Advisory Person’s separate individual capacity as a registered representative of Leaders, the Advisory Person will implement securities transactions and/or wrap investment portfolios under a private placement life insurance policy (“PPLI”) offered and supervised by Leaders, and not through or by Summit Trail. In such instances, the compensation earned by the Advisory Person as a registered representative is separate and in addition to the Advisor’s fees. This practice presents a conflict of interest because the Advisory Person who is a registered representative has an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on the Client. Clients are not obligated to implement any recommendation provided by the Advisor nor Advisory Persons. Advisory Persons and the Advisor stand to financially benefit for any PPLI recommendation, where Advisory Persons are incentivized to recommend a PPLI to its Clients. To mitigate this conflict, the Advisor will assess the overall fee charged to the Clients to determine the Client’s total cost is reasonable. The Advisor will also determine that the PPLI recommendation is in the best interest of the Client. Please see Item 10 – Other Financial Industry Activities and Affiliations. 15 | Summit Trail Advisors, LLC March 31, 2026  ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT The Advisor recommends Investment Managers and investment funds, including affiliated private funds, that assess a performance-based fee. To the extent an affiliated fund pays a performance- based fee, it shall be paid to the fund’s general partner. In certain instances, the general partner of an affiliated fund will be an affiliate of the Advisor. To the extent there is an affiliation between the Advisor and the general partner, such relationship shall be disclosed in the private fund’s disclosure documentation, along with the payment of any performance-based fee to the Advisor’s affiliate. A recommendation to invest with an Investment Manager or investment fund with a performance-based fee arrangement would be preceded by an assessment as to the suitability and appropriateness of such an investment, relative to other similar investments, if any, that do not have a performance-based fee arrangement. ITEM 7: TYPES OF CLIENTS The Advisor’s Clients generally include individuals, high net worth individuals, business entities, trusts, estates, charitable organizations, and pension and profit-sharing plans. The amount of each type of Client is available on the Advisor's Form ADV Part 1A. These amounts can change over time and are updated at least annually by the Advisor. The Advisor, in its sole discretion, reserves the right to charge a lesser investment advisory fee, or a flat fee, based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, competition, negotiations with Client, etc.). The Advisor generally does not impose a minimum relationship size for establishing a relationship. However, certain of the Advisor’s strategies may require a minimum asset amount in order to achieve optimal returns based on the needs of the Client, which the Advisor can waive in its sole discretion. As a result, similarly situated Clients could pay different fees. In addition, similar advice available from other investment advisers for similar or lower fees. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. The Advisor’s investment process encompasses three major areas: 1.) Asset Allocation, 2.) Investment Selection, and 3.) Portfolio Construction. The investment process is designed to be customized to each Client and their particular attributes. 1. Asset Allocation is the process for determining a long-term asset allocation that is appropriate for an investor, as well as considering how each asset class will fare in the intermediate-term in relation to its long-term expectations. The first step is to define which asset classes exist and how to categorize the world of investments. Asset classes must be unique, and investable for consideration. We believe there are roughly 15 asset classes that exist today for sophisticated investors. It is also important to classify these asset classes more broadly into groups that investors can understand. We believe all asset classes serve one of three purposes: Growth, Preservation, or Inflation Protection. Any asset class can be classified in one of these categories. By using broad categories that establish a clear goal and objective, we believe investors can better determine their proper allocation among the three groups, and therefore have portfolios that better fit their risk profile. 16 | Summit Trail Advisors, LLC March 31, 2026  2. Investment selection is the process of determining how to invest in each asset class. We primarily utilize an open architecture, in that we do not generally select individual securities within our firm. Whenever possible, we build portfolios by selecting specialists in each asset class who focus their research process on a specific area of the investment marketplace. We typically utilize a combination of ETFs, separate accounts, mutual funds, and private investment funds to invest our Client’s portfolios. In researching an active management organization, we utilize a research process built by the investment team at prior firms. We look at investment firms in four parts: Organization, Investment Process, Performance, and Operations. Our review of the organization is focused on determining whether the organization is likely to impede the investment process over the life of our investment. We seek to invest in firms that have positive attributes we prefer around ownership structure, compensation, product distribution, capacity management and numerous other items. In reviewing an investment process, we seek to understand the quality of the information the manager possesses, how they have utilized that information, and how they make portfolio decisions. This is a process that can review many individual investments over multiple years. We then will review performance, which is essentially the result of the investment process. Not all strong performance track records are the same, and we seek to understand in depth how manager has added value, and whether the nature of that added value is likely to continue. Finally, we review the firm’s operational capabilities, in terms of their operational policies and documents. In the case of private investment funds, we conduct a review of the operations to ensure we are comfortable with the custodian, administrator, auditor, as well as other items. Ongoing due diligence is a critical component of our recommended manager selection, and it is necessary to continue to review all four aspects of our active managers on a forward- looking basis. While our ongoing due diligence includes Client’s legacy managers, we expect to undergo a more thorough level of due diligence of our recommended managers. We continue to monitor the organization for any changes or signs of maturity or decline. We analyze data regarding the portfolios, and how the portfolios change over time. For marketable investments, we review performance monthly, and based on the type of investment will analyze performance drivers like attribution analysis on a quarterly basis. If there are changes to any of the key attributes of our managers, we will make decisions about continuing to use a manager in Client portfolios, and could lead us to termination or redemption from an existing manager. 3. Portfolio construction is a process that marries the asset allocation and investment selection with the key attributes of the Client. Doing our review process with a Client, we will seek to understand their investment risk tolerance, engagement, belief in skill, tax status, income and spending needs, as well as numerous other factors. We will then create an investment policy on allocation to our three major asset class buckets: 1) Growth, 2) Preservation, or 3) Inflation Protection. Portfolio construction for a Client will continue to be an ongoing process as well. Making sure that as their needs and goals change over time, our portfolios change as well. The Advisor may utilize the following methods of security analysis: 17 | Summit Trail Advisors, LLC March 31, 2026  • Fundamental – (analysis performed on historical and present data, with the goal of making financial forecasts) • Technical – (analysis performed on historical and present data, focusing on price and trade volume, to forecast the direction of prices) The Advisor may utilize the following investment strategies when implementing investment advice given to Clients: • Long Term Purchases (securities held at least a year) • Short Term Purchases (securities sold within a year) • Margin Transactions (use of borrowed assets to purchase financial instruments) • Options (contract for the purchase or sale of a security at a predetermined price during a specific period of time) Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by the Advisor) will be profitable or equal any specific performance level(s). B. Every method of analysis has its own inherent risks. To perform an accurate market analysis, the Advisor must have access to current/new market information. The Advisor has no control over the dissemination rate of market information; therefore, unbeknownst to the Advisor, certain analyses compiled with stale information, will severely limit the value of the Advisor’s analysis. Furthermore, an accurate market analysis can only produce a forecast of the direction of market values. There can be no assurances that a forecasted change in market value will materialize into actionable and/or profitable investment opportunities. The Advisor’s primary investment strategies - Long Term Purchases and Short Term Purchases - are fundamental investment strategies. However, every investment strategy has its own inherent risks and limitations. For example, longer term investment strategies require a longer investment time period to allow for the strategy to potentially develop. Shorter term investment strategies require a shorter investment time period to potentially develop but, as a result of more frequent trading, will likely incur higher transactional costs when compared to a longer term investment strategy. In addition to the fundamental investment strategies discussed above, the Advisor may also implement and/or recommend the use of margin and options transactions. The Advisor may also recommend the investment into certain private fund investments. These strategies have a high level of inherent risk. Margin is an investment strategy with a high level of inherent risk. A margin transaction occurs when an investor uses borrowed assets to purchase financial instruments. The investor generally obtains the borrowed assets by using other securities as collateral for the borrowed sum. The effect of purchasing a security using margin is to magnify any gains or losses sustained by the purchase of the financial instruments on margin. To the extent that a Client authorizes the use of margin, and margin is thereafter employed by the Advisor in the management of the Client’s investment portfolio, the market value of the Client’s account(s) and corresponding fee payable by the Client to the Advisor may be increased. As a result, in addition to understanding and assuming the additional principal risks associated with 18 | Summit Trail Advisors, LLC March 31, 2026  the use of margin, Clients authorizing margin are advised of the conflict of interest whereby the Client’s decision to employ margin may correspondingly increase the management fee payable to the Advisor. Accordingly, the decision as to whether to employ margin is left totally to the discretion of Client. Borrowing Against Assets/Risks. A Client who has a need to borrow money could determine to do so by using: • Margin-The account custodian or broker-dealer lends money to the Client. The custodian charges the Client interest for the right to borrow money, and uses the assets in the Client’s brokerage account as collateral; and, • Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a loan to the Client, the Client pledges its investment assets held at the account custodian as collateral. These above-described collateralized loans are generally utilized because they typically provide more favorable interest rates than standard commercial loans. These types of collateralized loans can assist with a pending home purchase, permit the retirement of more expensive debt, or enable borrowing in lieu of liquidating existing account positions and incurring capital gains taxes. However, such loans are not without potential material risk to the Client’s investment assets. The lender (i.e., custodian, bank, etc.) will have recourse against the Client’s investment assets in the event of loan default or if the assets fall below a certain level. For this reason, Summit Trail does not recommend such borrowing unless it is for specific short-term purposes (i.e., a bridge loan to purchase a new residence). Summit Trail does not recommend such borrowing for investment purposes (i.e., to invest borrowed funds in the market). Regardless, if the Client was to determine to utilize margin or a pledged assets loan, the following economic benefits would inure to Summit Trail: • by taking the loan rather than liquidating assets in the Client’s account, Summit Trail continues • • to earn a fee on such account assets; and, if the Client invests any portion of the loan proceeds in an account to be managed by Summit Trail, Summit Trail will receive an advisory fee on the invested amount; and if Summit Trail’s advisory fee is based upon the higher margined account value, Summit Trail will earn a correspondingly higher advisory fee. This could provide Summit Trail with an incentive to encourage the Client to use, or to continue the use, of margin. The Client must accept the above risks and potential corresponding consequences associated with the use of margin or a pledged assets loan. Options Strategies The Advisor may engage in options transactions for the purpose of hedging risk and/or generating portfolio income. The use of options transactions as an investment strategy can involve a high level of inherent risk. Option transactions establish a contract between two parties concerning the buying or selling of an asset at a predetermined price during a specific period of time. During the term of the option contract, the buyer of the option gains the right to demand fulfillment by the seller. Fulfillment may take the form of either selling or purchasing a security, depending upon the nature of the option contract. Generally, the purchase or sale of an option contract shall be with the intent of “hedging” a potential market risk in a Client’s portfolio and/or generating income for a Client’s portfolio. 19 | Summit Trail Advisors, LLC March 31, 2026  Certain options-related strategies (i.e., straddles, short positions, etc.), may, in and of themselves, produce principal volatility and/or risk. Therefore, a Client must be willing to accept these enhanced volatility and principal risks associated with such strategies. In light of these enhanced risks, Client may direct Summit Trail, in writing, not to employ any or all such strategies for their accounts. There can be no guarantee that an options strategy will achieve its objective or prove successful. No Client is under any obligation to enter into any option transactions. However, if the Client does so, he/she must be prepared to accept the potential for unintended or undesired consequences (i.e., losing ownership of the security, incurring capital gains taxes). Covered Call Writing Covered call writing is the sale of in-, at-, or out-of-the-money call options against a long security position held in a Client portfolio. This type of transaction is intended to generate income. It also serves to create partial downside protection in the event the security position declines in value. Income is received from the proceeds of the option sale. Such income may be reduced or lost to the extent it is determined to buy back the option position before its expiration. There can be no assurance that the security will not be called away by the option buyer, which will result in the Client (option writer) to lose ownership in the security and incur potential unintended tax consequences. Covered call strategies are generally better suited for positions with lower price volatility. Long Put Option Purchases Long put option purchases allow the option holder to sell or “put” the underlying security at the contract strike price at a future date. If the price of the underlying security declines in value, the value of the long put option can increase in value depending upon the strike price and expiration. Long puts are often used to hedge a long stock position to protect against downside risk. The security/portfolio could still experience losses depending on the quantity of the puts bought, strike price and expiration. In the event that the security is put to the option holder, it will result in the Client (option seller) to lose ownership in the security and to incur potential unintended tax consequences. Options are wasting assets and expire (usually within months of issuance). Summit Trail does not utilize options transactions without the express prior direction of the Client. Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency. A complete discussion of these risks are set forth in each fund’s respective offering documents, which will be provided to each Client for review and consideration. Unlike liquid investments that a Client may maintain, private investment funds do not provide daily liquidity or pricing. Sustainable Investing Limitations. Sustainable Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the active investment manager investment process assessment. This assessment process is a capability the Advisor continues to develop. Investment managers have varying views about how to incorporate ESG data in their investment process. Some managers do not use ESG at all in their process. Others may choose to use it extensively. In our assessment of investment managers, we seek over time to understand how they may use ESG data or processes, if at all. There are a variety of ways an investment manager may use ESG data. While there are a wide variety of approaches, we may seek to develop an understanding of how they use Environmental data (i.e., considers how a company considers the environment in its business 20 | Summit Trail Advisors, LLC March 31, 2026  operations); Social data (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance data (i.e., company management considerations. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by STA), there can be no assurance that investment in strategies that use ESG data will be profitable, prove successful, or outperform strategies that do not use ESG data. Cybersecurity Risk. The information technology systems and networks that Advisor and its third-party service providers use to provide services to Advisor’s clients employ various controls that are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Advisor’s operations and/or result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. In accordance with Regulation S-P, the Advisor is committed to protecting the privacy and security of its clients' non-public personal information by implementing appropriate administrative, technical, and physical safeguards. The Advisor has established processes to mitigate the risks of cybersecurity incidents, including the requirement to restrict access to such sensitive data and to monitor its systems for potential breaches. Clients and Advisor are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur financial losses and/or other adverse consequences. Although the Advisor has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that the Advisor does not control the cybersecurity measures and policies employed by third-party service providers, issuers of securities, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchanges, and other financial market operators and providers. In compliance with Regulation S-P, the Advisor will notify clients in the event of a data breach involving their non-public personal information as required by applicable state and federal laws. C. Currently, the Advisor primarily allocates Client investment assets among various individual equity and fixed income securities, mutual funds and/or ETFs, Independent Managers, and separately managed accounts on a discretionary and non-discretionary basis in accordance with the Client’s designated investment objective(s). From time to time, and only in those cases where the Client is eligible to do so, the Advisor may recommend participating in initial and secondary public offerings (“IPOs”). In addition to the risks set forth above, given the nature of such offerings they may have more volatility in price than existing equities that are currently traded and have a trading history. Accordingly, the decision as to whether to participate in initial or secondary offerings is left totally to the discretion of Client. ITEM 9: DISCIPLINARY INFORMATION The Advisor has not been the subject of any disciplinary actions. 21 | Summit Trail Advisors, LLC March 31, 2026  ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Neither the Advisor, nor its Advisory Persons, are registered or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or a representative of the foregoing. Broker-Dealer Affiliation As disclosed above in Item 5.E, certain Advisory Persons of the Advisor are also registered representatives of STS, which is owned by the Advisor. Clients can choose to engage an Advisory Person, and/or other related persons of STS in their individual capacities as registered representatives of STS, to implement securities brokerage transactions on a placement fee basis, i.e., placement agent services for private investment funds for which the Advisor is the named Investment Advisor. The recommendation by an Advisory Person that a Client purchase a securities product presents a conflict of interest, as the receipt of placement fees provides an incentive to recommend investment products based on placement fees received, rather than based on a particular Client’s need. In addition, the Advisor shall benefit from any revenue generated for fees earned by STS. No Client is under any obligation to purchase any products from an Advisory Person in his/her capacity as a registered representative of STS. Clients are reminded that they may purchase securities products recommended by the Advisor through other, non-affiliated registered representatives and through other non-affiliated broker-dealers. As noted in Item 5.E, certain Advisory Persons are also registered representatives of The Leaders Group, Inc. In one’s separate capacity as a registered representative, the Advisory Person will receive commissions for the implementation of recommendations for commissionable transactions. Advisory Persons and the Advisor stand to financially benefit for any PPLI recommendation, or the recommendation of other insurance products, where Advisory Persons are incentivized to recommend a PPLI or other product to its Clients. To mitigate this conflict, the Advisor will assess the overall fee charged to the Client to determine that the Client’s total cost is reasonable. Prior to recommending a PPLI or other insurance product, the Advisor will conduct appropriate due diligence to determine that any such recommendation to a Client aligns with the Client’s investment needs and objectives. In addition, the Advisor will provide additional disclosure information to each Client that will include relevant details regarding material financial interests and compensation surrounding the recommendation. There is no requirement for the Advisor to recommend a PPLI or other insurance product to Clients, nor are Clients obligated to invest in any such products. Dynasty Financial Partners, LLC Affiliation The Advisor maintains a business relationship with Dynasty, which provides the Advisor with operational and back-office support including access to a network of service providers. Through the Dynasty network of service providers, the Advisor has access to discounts on trading technology, reporting, custody, brokerage, compliance and other related services. While the Advisor believes this open architecture structure for operational services best serves the interests of its advisory Clients, this relationship may present certain conflicts of interest due to the fact that Dynasty retains a portion of the platform or other third-party fees paid by the Advisor or Clients for the services referenced above. In light of the foregoing, the Advisor seeks at all times 22 | Summit Trail Advisors, LLC March 31, 2026  to ensure that any material conflicts are disclosed and handled in a manner that is aligned with its Clients’ best interests. The Advisor does not receive any portion of the fees paid directly to Dynasty, its affiliates or the service providers made available through Dynasty’s platform. In addition, the Advisor reviews all such relationships, including the service providers engaged through Dynasty, on an ongoing basis in an effort to ensure Clients are receiving competitive rates in relation to the quality and scope of the services provided. Dynasty’s subsidiary, Dynasty Wealth Management, LLC (“DWM”), a registered investment advisor, also provides access to a range of investment services, including separately managed accounts (“SMAs”), mutual fund and exchange-traded fund (“ETF”) asset allocation strategies and unified managed accounts (“UMAs”) managed by external third party managers (collectively the “Investment Programs”). The Advisor may receive more advantageous pricing as assets increase, which poses a conflict of interest with the Client. In light of the foregoing, the Advisor seeks at all times to determine that any such conflicts are addressed on a fully-disclosed basis and investment decisions are handled in a manner that is aligned with its Clients’ best interests. Summit Trail does not receive any portion of the fees paid directly to Dynasty or the service providers made available through its platform, and the Summit Trail reviews all such relationships on an ongoing basis in an effort to ensure Clients are receiving competitive rates in light of the services they receive. The Advisor has obtained financing for its business through Dynasty Advisors Financing Services, LLC (“DAFS”), a wholly-owned subsidiary of Dynasty Financial Partners, LLC (and affiliate of Dynasty Wealth Management, LLC). DAFS, in partnership with various independent banks, has provided the Advisor with a lending facility to assist with business transition expenses and other costs associated with launching the Advisor. The Advisor is not obligated to utilize the DAFS lending facility in order to obtain other services from Dynasty. All lending is subject to standard underwriting requirements. A portion of this loan may be furnished directly from Dynasty as a co- lender. In such situations, the Advisor will be subject to the same lending facility criteria and requirements as applied by the independent bank. The fee for these services is included in the fees paid by the Client (See Item 5. Fees and Compensation). Referral Engagements In certain instances, the Advisor may refer a Client or prospective Client to an unaffiliated asset manager. The Advisor receives compensation for the referral, pursuant to a written agreement, in accordance with the requirements of Rule 206(4)-1 of the Investment Advisers Act of 1940, and any corresponding state securities law requirements. The receipt of the referral fee is solely from the unaffiliated asset manager’s fee. In such arrangements the Advisor will not charge any additional advisory fees for the referred assets or engagement. Insurance Company The Advisor also serves as a licensed insurance agency, and as such, may offer insurance products on a commission basis. The Advisor may also introduce the Client to an unaffiliated insurance agency to manage the insurance process. In such event, the Advisor shall receive a portion of the insurance commission earned by the unaffiliated insurance agency. No Client shall be under any obligation to purchase any insurance products from the Advisor or such introduced insurance agency. The recommendation by an Advisory Person that a Client purchase an insurance product 23 | Summit Trail Advisors, LLC March 31, 2026  presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend insurance products based on commissions to be received, rather than based on a particular Client’s need. Clients are reminded that they remain free to purchase insurance products through other unaffiliated or non-introduced insurance agencies. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. The Advisor maintains a Code of Ethics (the “Code”) that is applicable to all individuals associated with the Advisor (our “Supervised Persons”). In addition, the Advisor maintains an investment policy relative to personal securities transactions for Supervised Persons with access to Client investment information (our “Access Persons”). This investment policy is part of the Advisor’s overall Code, which serves to establish a standard of business conduct that is based upon fundamental principles of openness, integrity and honesty, a copy of which is available upon request. In accordance with Section 204A of the Advisers Act, the Advisor also maintains and enforces written policies and procedures reasonably designed to prevent the misuse of material non-public information by the Advisor or any Supervised Person. The Advisor and its Supervised Persons may give and/or receive gifts, services or other items to/from any person or entity that does business with or potentially could conduct business with or on behalf of the Advisor, subject to limitations established by the Advisor. The Advisor has adopted policies and procedures governing gifts and business entertainment, which includes disclosure of gifts and business entertainment in excess of certain de minimis thresholds and pre-clearance by the Chief Compliance Officer prior to giving/receiving gifts above a certain de minimis threshold. As disclosed above, the Advisor may recommend participation in initial and secondary offerings to eligible Clients. In such cases, offerings may be available in limited quantities wherein the Advisor may need to allocate shares to Clients in a lesser proportion than as requested by the Client. These situations create a conflict of interest and in such cases the Advisor will manage such conflicts through applicable policies and procedures. B. As disclosed above, related persons have a financial interest in the affiliated private funds. The terms and conditions for participation in each affiliated private fund, including management fees, conflicts of interest, and risk factors, are set forth in the fund’s offering documents. C. The Advisor and/or its Access Persons may buy or sell securities that are also recommended to Clients. This practice may create a situation where the Advisor and/or its Access Persons are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a conflict of interest. The Advisor has adopted the following procedures in an effort to minimize such conflicts: The Advisor requires its Access Persons to preclear only certain limited offerings and initial public offerings in their personal accounts with the Chief Compliance Officer, who may deny permission to execute the transaction. In addition, the Advisor’s Code prohibits all Access Persons from executing personal securities transactions of any kind in any securities on a restricted securities list maintained by the Chief Compliance Officer. All of the Adviser’s Access Persons are required to disclose their securities transactions on a quarterly basis. In addition, the Adviser’s Access Persons are required to disclose the holdings in their personal accounts within ten (10) days of the commencement of their employment with the Advisor and 24 | Summit Trail Advisors, LLC March 31, 2026  on an annual basis thereafter. The Advisor’s Access Persons are required to provide broker confirmations of each transaction in which they engage and quarterly certification of such transactions. The Advisor’s Access Persons are also required to provide quarterly brokerage statements. Trading in the personal accounts of the Advisor’s Access Persons is reviewed by the Chief Compliance Officer and compared with transactions for client accounts and reviewed against the restricted securities list. D. The Advisor and/or its Access Persons may buy or sell securities, at or around the same time as those securities are recommended to Clients. This practice creates a situation where the Advisor and/or its Access Persons are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a conflict of interest. As indicated above in Item 11.C, the Advisor has a personal securities transaction policy in place to monitor the personal securities transaction and securities holdings of each of the Advisor’s Access Persons. ITEM 12: BROKERAGE PRACTICES A. In the event that the Client requests, that the Advisor recommend a broker-dealer/custodian for custody and execution services (exclusive of those Clients that may direct the Advisor to use a specific broker-dealer/custodian). The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize the Advisor to direct trades to this Custodian as agreed upon in the investment advisory agreement. The Client may also authorize the Advisor to trade securities away from the Custodian and arrange for delivery of these securities to the Client’s accounts at the Custodian or another custodian designated by the Client. For such “trade-away” arrangements, the Custodian will charge a separate trade-away fee in addition to the securities commissions. These trade-away fees are in addition to any commissions and other brokerage fees charged by the executing broker-dealer. While the Advisor does not exercise discretion over the selection of a Custodian, it reserves the right to recommend a Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a broker-dealer/custodian not recommended by the Advisor. However, the Advisor will likely be limited in the services it can provide if the recommended Custodian is not engaged. The Advisor reserves the right to recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, its reputation, and/or the location of the Custodian’s offices. The Advisor generally recommends that investment management accounts be maintained at Pershing LLC (“Pershing”), Fidelity Clearing & Custody Solutions, a related entity of Fidelity Investments, Inc. (collectively “Fidelity”), Charles Schwab & Co., Inc. (“Schwab”) and Interactive Brokers, LLC (“IB”), each of which is a FINRA-registered broker-dealer and member SIPC. The Advisor maintains an institutional relationship with Pershing, Fidelity and Schwab, whereby the Advisor receives economic benefits from Pershing, Fidelity and Schwab. Please see below and Item 14. 1. Research and Additional Benefits Although not a material consideration when determining whether to recommend that a Client utilize the services of Pershing, Fidelity or Schwab (or another broker-dealer/custodian, investment platform, unaffiliated investment manager, vendor, unaffiliated product/fund sponsor, or vendor), Advisor receives from Pershing, Fidelity or Schwab without cost (and/or at a discount) support services and/or products, certain of which assist Advisor to better 25 | Summit Trail Advisors, LLC March 31, 2026  monitor and service Client accounts maintained at such institutions. Included within the support services that may be obtained by Advisor may be investment-related research, pricing information and market data, software and other technology that provide access to Client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by Advisor in furtherance of its investment advisory business operations. As indicated above, certain of the support services and/or products received may assist Advisor in managing and administering Client accounts. Others do not directly provide such assistance, but rather assist Advisor to manage and further develop its business enterprise. Additional Benefits Advisor has received, from Pershing, Fidelity, and Schwab, certain additional economic benefits, related to business development needs, (“Additional Benefits”) that may or may not be offered to Advisor again in the future. The Advisor has no expectation that these Additional Benefits will be offered again; however, Advisor reserves the right to negotiate for these Additional Benefits in the future. The Additional Benefits are described below in Item 14.A. Summit Trail’s Chief Compliance Officer, Joseph Erigo, remains available to address any questions that a Client or prospective Client may have regarding the above arrangements and the corresponding conflicts of interest presented by such arrangements. 2. Brokerage Referrals The Advisor does not receive referrals from broker-dealers. 3. Directed Brokerage The Advisor does not typically accept directed brokerage arrangements (i.e., arrangements when a Client requires that account transactions be effected through a specific broker- dealer). If a directed brokerage arrangement is accepted, the Client will negotiate terms and arrangements for their account(s) with that broker-dealer, and Advisor will not seek best execution services or prices from other broker-dealers or be able to "batch" the Client's transactions for execution through other broker-dealers with orders for other accounts managed by Advisor. As a result, Client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account(s) than would otherwise be the case. In the event that the Client directs the Advisor to implement securities transactions for the Client’s account(s) through a specific broker-dealer/custodian, the Client is required to acknowledge that such direction may cause their account(s) to incur higher commissions or transaction costs than the account(s) would otherwise incur had the Client determined to effect account transactions through alternative clearing arrangements that may be available through the Advisor. Higher transaction costs adversely impact account performance. Transactions for directed accounts will generally be executed following the execution of portfolio transactions for non-directed accounts. B. To the extent that the Advisor provides investment advisory services to its Clients, the transactions for each Client account generally will be effected independently, unless the Advisor decides to purchase or sell the same securities for several Clients at approximately the same time. The 26 | Summit Trail Advisors, LLC March 31, 2026  Advisor may (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among the Advisor’s Clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among Clients in proportion to the purchase and sale orders placed for each Client account on any given day. The Advisor shall not receive any additional compensation or remuneration as a result of such aggregation. ITEM 13: REVIEW OF ACCOUNTS A. For those Clients to whom the Advisor provides investment supervisory services, account reviews are conducted on an ongoing basis by the Advisor's Principals and its Advisory Persons. All investment supervisory Clients are advised that it remains their responsibility to advise the Advisor of any changes in their investment objectives and/or financial situation. All Clients (in person or via telephone) are encouraged to review financial planning issues (to the extent applicable), investment objectives and account performance with the Advisor on an annual basis. B. The Advisor reserves the right to conduct account reviews on an other-than-periodic basis upon the occurrence of a triggering event, such as a change in Client investment objectives and/or financial situation, market corrections and Client request. The Client is encouraged to notify the Advisor if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews will likely be triggered by material market, economic or political events. C. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the broker-dealer/custodian and/or program sponsor for the Client accounts. The Advisor may also provide a written periodic report summarizing account activity and performance. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION A. As referenced in Item 12.A.1 above, the Advisor can receive economic benefits from Pershing, Fidelity, Schwab and/or IB. The Advisor, without cost (and/or at a discount), can receive support services and/or products from these custodians. Participation in Institutional Advisor Platform - Schwab The Advisor has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Schwab. As a registered investment advisor participating on the Schwab Advisor Services platform, Schwab receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over one that does not furnish similar software, systems support, or services. Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client’s 27 | Summit Trail Advisors, LLC March 31, 2026  funds and securities. Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able to obtain directly or through other sources. Further, the Advisor will likely be able to invest in certain mutual funds and other investments without having to adhere to investment minimums that might be required if the Client were to directly access the investments. Services that Will Indirectly Benefit the Client – Schwab provides participating advisors with access to technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts, the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but there can be no guarantee they will benefit all Clients. Services that Will Only Benefit the Advisor – Schwab also offers other services to the Advisor that will not always benefit the Client, including: educational conferences and events, financial start-up support, consulting services and discounts for various service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest. The Advisor believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients. Participation in Institutional Advisor Platform – Pershing, Fidelity and IB The Advisor has established institutional relationships with Fidelity, Pershing and IB to assist the Advisor in managing Client account[s]. Access to the Fidelity, Pershing and IB Institutional platforms is provided at no charge to the Advisor. The Advisor receives access to software and related support without cost because the Advisor renders investment management services to Clients that maintain assets at Fidelity, Pershing and IB. The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor’s recommendation of this custodian over one that does not furnish similar software, systems support, or services. Additionally, the Advisor may receive the following benefits from Fidelity, Pershing and IB: receipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts; and access to an electronic communication network for Client order entry and account information. There is no corresponding commitment made by the Advisor to any such custodian, or any other entity, to invest any specific amount or percentage of Client assets in any specific mutual funds, securities or other investment products as a result of the above arrangement. Transition Assistance The Advisor can receive Transition Assistance from Fidelity, Pershing and Schwab, relating to expenses incurred while transitioning new accounts to these respective custodians. Proceeds of the Transition Assistance are intended to be used to offset account transfer fees incurred by Clients moving to a respective custodian while other funds can be used for a variety of purposes, subject to review by the respective custodian. Clients should be aware that the receipt 28 | Summit Trail Advisors, LLC March 31, 2026  of economic benefits from a respective custodian creates a conflict of interest since these benefits may influence the Advisor’s recommendation of these custodians over one that does not furnish similar support. Summit Trail’s Chief Compliance Officer, Joseph Erigo, remains available to address any questions that a Client or prospective Client may have regarding the above arrangements and the corresponding conflicts of interest presented by such arrangements. Insurance Company As noted in Item 10, Summit Trail also serves as an insurance company, where the Advisor may recommend to Clients the purchase of certain insurance products. Summit Trail will benefit from any revenue generated from the sale of a recommended insurance product. B. Referral Fees. Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the Promoter with a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the Advisor, and shall not result in any additional charge to the Client. ITEM 15: CUSTODY The Advisor shall have the ability to have its investment advisory fee for each Client debited by the custodian on a quarterly basis. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the broker- dealer/custodian and/or program sponsor for the Client accounts. The Advisor may also provide a written periodic report summarizing account activity and performance. To the extent that the Advisor provides Clients with periodic account statements or reports, the Client is urged to compare any statement or report provided by the Advisor with the account statements received from the account custodian. The custodian does not verify the accuracy of the Advisor’s advisory fee calculation. Additionally, if the Client gives the Advisor authority to move money from one account to another account, the Advisor may have custody of those assets. In order to avoid additional regulatory requirements in these cases, the Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions. Custody Situations: The Advisor and certain of the Advisor’s representatives do engage in other practices and/or services on behalf of its Clients that require disclosure at ADV Part 1, Item 9, which practices and/or services are subject to an annual surprise CPA examination in accordance with the requirements of Rule 206(4)-2 under the Investment Advisers Act of 1940. ITEM 16: INVESTMENT DISCRETION The Client can determine to engage the Advisor to provide investment advisory services on a discretionary basis. Prior to the Advisor assuming discretionary authority over a Client’s account(s), the Client shall be required to execute an investment advisory agreement, naming the Advisor as the Client’s attorney and agent in fact, granting the Advisor full authority to buy, sell, or otherwise effect investment transactions involving the assets in the Client’s name found in the discretionary account(s). 29 | Summit Trail Advisors, LLC March 31, 2026  Clients who engage the Advisor on a discretionary basis may, at any time, impose restrictions, in writing, on the Advisor’s discretionary authority (i.e., limit the types/amounts of particular securities purchased for their account(s), exclude the ability to purchase securities with an inverse relationship to the market, limit or proscribe the Advisor’s use of margin, etc.). ITEM 17: VOTING CLIENT SECURITIES Except for Assets allocated to independent investment managers (for which the manager shall retain proxy voting authority), the Advisor (unless provided otherwise in writing), utilizing services provided by Broadridge, an unaffiliated proxy voting vendor, shall be responsible for directing the manner in which Account proxies shall be voted. The Advisor, at its expense, has also engaged Broadridge to assist the Client with class-action matters. The Advisor shall not receive any compensation from the service provider. The Client is under no obligation to engage the service provider. Unless the Client notifies the Advisor to the contrary, in writing, the Advisor shall engage the service provider on the Client’s behalf for its class-action service. If the Client notifies the Advisor, in writing, that it does not want to participate in the class-action service, the Client shall be exclusively responsible for reviewing/voting/filing class actions claims. The Advisor understands its duty to vote Client proxies in the best interest of its Clients. Furthermore, any material conflicts between the Advisor’s interests and those of our Clients with regard to a proxy vote must be resolved before proxies are voted. Clients may request a copy of our written policies and procedures regarding proxy voting and/or information on how particular proxies were voted by contacting our CCO. In addition, the Advisor has also contracted with Broadridge as provider to file Class Actions "Proof of Claim" forms. Occasionally, securities held in the accounts of Clients will be the subject of class action lawsuits. Broadridge provides a comprehensive review of our Clients’ possible claims to a settlement throughout the class action lawsuit process. Broadridge actively seeks out any open and eligible class action lawsuits. Additionally, Broadridge files, monitors and expedites the distribution of settlement proceeds in compliance with SEC guidelines on behalf of Clients. Broadridge retains 20% of the proceeds from any class action awards obtained by our Clients through the use of its services. Clients may choose to optout of this service. ITEM 18: FINANCIAL INFORMATION A. The Advisor does not solicit fees of more than $1,200, per Client, six months or more in advance. B. The Advisor is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain Client accounts. C. The Advisor has not been the subject of a bankruptcy petition. Summit Trail’s Chief Compliance Officer, Joseph Erigo, remains available to address any questions pertaining to this Brochure. 30 | Summit Trail Advisors, LLC March 31, 2026 

SUMMIT TRAIL ADVISORS, LLC SEC FILE NUMBER: 801 – 99352 WRAP FEE PROGRAM BROCHURE DATED: March 31, 2026 This Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and business practices of Summit Trail Advisors, LLC (“Summit Trail” or the “Advisor”). If you have any questions about the contents of this Wrap Fee Program Brochure, please contact us at (212) 812-7010. The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Summit Trail Advisors, LLC and its Advisory Persons is also available on the SEC’s website at www.adviserinfo.sec.gov by searching with our firm name or our firm CRD# 220519. Registration with the SEC or with any state securities authority does not imply a certain level of skill or training. Contact: Joseph Erigo Chief Compliance Officer 2 Grand Central Tower, 140 E 45th Street, 28th Floor New York, NY 10017 Phone: (212) 812-7010 www.SummitTrail.com 1  ITEM 2 – MATERIAL CHANGES This Appendix 1 (“Wrap Fee Program Brochure”) provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. In particular, this Wrap Fee Brochure discusses wrap fee programs offering by the Advisor. Material Changes There have been no material changes made to our Wrap Fee Program Brochure since our last Annual Amendment filing. Future Changes From time to time, we may amend this Wrap Fee Program Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Wrap Fee Program Brochure or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of Summit Trail. At any time, you may view the current Wrap Fee Program Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 220519. You may also request a copy of this Wrap Fee Program Brochure at any time, by contacting us at (212) 812-7010. 2  ITEM 3 – TABLE OF CONTENTS ITEM 2 – MATERIAL CHANGES ............................................................................................... 2 ITEM 3 – TABLE OF CONTENTS ............................................................................................... 3 ITEM 4 – SERVICES FEES AND COMPENSATION .................................................................... 4 ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS .............................................. 6 ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION .......................................... 7 ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS .......................... 18 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS ................................................ 18 ITEM 9 – ADDITIONAL INFORMATION ................................................................................. 18 3  ITEM 4 – SERVICES FEES AND COMPENSATION A. Services For certain legacy relationships, the Advisor provides discretionary and/or non-discretionary investment advisory services on a wrap fee basis (See discussion below). Under a wrap fee, basis the Client will pay a single fee for bundled services (i.e., investment advisory, brokerage, custody). The services included in a wrap fee agreement will depend upon each Client’s particular need. The Advisor’s investment management services on a wrap fee basis are in accordance with the Summit Trail Wrap Program (the “Program”). Under the Program, the Advisor is able to offer participants discretionary and/or non-discretionary investment management services, for a single specified annual Program fee, inclusive of trade execution, custody, reporting, account maintenance, investment management fees, and fees charged by independent managers. However, Clients may be responsible for, but not limited to, trustee fees, mutual fund expenses, ETF expenses, mark-ups, mark-downs, transfer taxes, odd lot differentials, exchange fees, interest charges, American Depository Receipt agency processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law or otherwise agreed to with regard to Client accounts. These fees and expenses are described in each fund’s prospectus. Summit Trail can provide or direct you to a copy of the prospectus for any fund that we recommend to you. Such fees are in addition to any fees paid by the Client to the Advisor and are between the Client and the account custodian. The current annual Program fee ranges up to 2.00%, as follows: Assets Under Management Less than $5,000,000 $5,000,000 to $10,000,000 $10,000,000 to $25,000,000 $25,000,000 to $50,000,000 $50,000,000 to $100,000,000 More than $100,000,000 Annualized Fee 2.00% 1.75% 1.50% 1.30% 1.10% 1.00% Under the Program, if engaged on a discretionary basis, the Advisor shall have written authority to determine the type and amount of securities that are bought or sold. Clients who engage the Advisor on a discretionary basis may, at any time, impose restrictions, in writing, on the Advisor’s discretionary authority (i.e., limit the types/amounts of particular securities purchased for their account(s), exclude the ability to purchase securities with an inverse relationship to the market, limit or proscribe the Advisor’s use of margin, etc.). Pershing, LLC (“Pershing”) and/or Fidelity Institutional Wealth Services, (“Fidelity”) shall serve as the custodian for Program accounts. Use of Independent Managers: For Client account[s] implemented through an Independent Manager (“Independent Managers”), the Client’s overall fees may include Summit Trail’s investment advisory fee (as noted above) plus advisory fees and/or platform fees charged by the Independent Manager[s], as applicable. The Independent Manager may assume responsibility for calculating the Client’s fees and deducting all fees from the Client’s account[s]. In such instances, Summit Trail will not charge its fee separately on those assets. Turnkey asset management programs (“TAMP”) related charges are not included in the investment management fee you pay to Summit Trail. You will be charged, separate from and in addition to your investment management fee, any applicable TAMP fees as well as applicable Independent Manager fees. 4  The Advisor is affiliated with Dynasty Financial Partners, LLC (“Dynasty”), Dynasty is also a TAMP provider (See Item 6 below). The Advisor does not receive any portion of the fees paid directly to Dynasty or the service providers made available through Dynasty’s TAMP, including the Independent Managers. TAMP and Independent Manager fees are determined by the particular TAMP and Independent Manager[s] with which Client assets are invested, and are calculated based upon a percentage of assets under management, as applicable. The program fee generally ranges up to 0.45% annually. Clients should note the total fees reflected on custodial statements represent the aggregate of Summit Trail’s investment management fee, TAMP fee and Independent Manager fee, accordingly. Clients are urged to review such statements to determine the total amount of fees associated with assets placed with Independent Managers. Client should also review the investment management agreement with Summit Trail to determine the investment management fee paid to the Advisor. Fee Calculation: The fee charged is calculated as described above and is not charged on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of the funds of a Client. Client’s may make additions to and withdrawals from their account(s) at any time. However, reconciliations are performed on a quarterly basis to capture the difference in the market value of the assets on the last day of the previous quarter and the average daily balance of the assets for the quarter. An adjustment will be made in the form of a credit or debit to reflect the difference. For the initial period of an engagement, the fee is calculated on a pro rata basis through the end of the quarter. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the unearned portion is refunded to the Client, as appropriate. investment advisory services with respect to non-custodial The Advisor may also provide partnership/private fund investments, which are not held at the Primary Custodian. In such instances, the Client shall be required to complete the applicable private placement and/or account opening documents to establish these investments. The Advisor will debit its fee for providing investment advisory services with respect to these relationships directly from a brokerage account designated by the Client held at the Primary Custodian. For certain non-custodial partnership/private fund investments, the Advisor may not receive quarter-end investment valuations prior to its fee billing calculation. In such instances, the Advisor will use the most recent month-end or quarter-end valuation available for the calculation of investment advisory fees. The Advisor will recalculate its fee upon receipt of final valuations. Adjustments are reflected in the fee calculations for the next quarterly period. Fee Payment: Clients will be charged in advance, at the beginning of each calendar quarter based upon the market value of the assets on the last business day of the previous quarter. Clients may elect to have the Advisor’s advisory fees deducted from their custodial account(s). Investment Performance: As a condition to participating in the Program, the participant must accept that past performance may not be indicative of future results, and understand that the future performance of any specific investment or investment strategy (including the investments and/or investment strategies purchased and/or undertaken by the Advisor) may not: (1) achieve their intended objective; (2) be profitable; or, (3) equal historical performance level(s) or any other performance level(s). The Advisor’s Chief Compliance Officer (“CCO”), Joseph Erigo, remains available to address any questions that a Client or prospective Client may have regarding this Wrap Fee Program Brochure. 5  B. Program Costs Participation in the Program may cost more or less than purchasing such services separately. Also, the Program fee charged by Advisor for participation in the Program may be higher or lower than those charged by other sponsors of comparable wrap fee programs. Depending upon the percentage wrap-fee charged by the Advisor, the amount of portfolio activity in the Client's account(s), and the value of custodial and other services provided, the wrap fee may or may not exceed the aggregate cost of such services if they were to be provided separately and/or if the Advisor were to negotiate transaction fees and seek best price and execution of transactions for the Client's account(s). Conflict of Interest: Because Program transaction fees and/or commissions are being paid by the Advisor to the account custodian/broker-dealer, the Advisor has an economic incentive to minimize the number of trades in the Client's account(s). The Advisor’s Chief Compliance Officer, Joseph Erigo, remains available to address any questions that a Client or prospective Client may have regarding the corresponding conflict of interest a wrap fee arrangement may create. C. Fees The Program’s wrap fee does not include certain charges and administrative fees, including, but not limited to, trustee fees, mutual fund expenses, ETF expenses, markups, mark-downs, transfer taxes, odd lot differentials, exchange fees, interest charges American Depository Receipt agency processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law or otherwise agreed to with regard to Client accounts. Such fees and expenses are in addition to the Program’s wrap fee. Tradeaway/Prime Broker Fees. Relative to its discretionary investment management services, when beneficial to the Client, individual fixed income transactions may be effected through broker-dealers other than the account custodian, in which event, the Client generally will incur both the fee (commission, mark- up/mark-down) charged by the executing broker-dealer and a separate “tradeaway” and/or prime broker fee charged by the account custodian (Pershing and/or Fidelity). Please Note: Clients who engage the Advisor on a wrap fee basis may incur tradeaway and/or prime broker fees. D. Compensation Advisor’s related persons who recommend the Program to Clients do not receive additional compensation as a result of a Client’s participation in the wrap fee program. ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS The Advisor’s Clients shall generally include individuals, high net worth individuals, business entities, trusts, estates, charitable organizations, and pension and profit sharing plans. The amount of each type of Client is available on the Advisor's Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. The Advisor, in its sole discretion, may charge a lesser investment advisory fee, or a flat fee, based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, 6  competition, negotiations with Client, etc.). The Advisor generally does not impose a minimum relationship size for establishing a relationship. However, certain strategies of STA may require a minimum asset amount in order to achieve optimal returns based on the needs of the Client, which may be waived at the sole discretion of the Advisor. As result, similarly situated Clients could pay different fees. In addition, similar advisory services may be available from other investment advisers for similar or lower fees. ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION A. Portfolio Manager Selection The Advisor may allocate a portion of a Client’s Program assets among unaffiliated independent investment managers and/or separately managed accounts in accordance with the Client’s designated investment objective(s). In such situations, the independent manager(s) or separately managed account managers shall have day-to-day responsibility for the active discretionary management of the allocated Program assets. The Advisor shall continue to render investment supervisory services to the Client relative to the ongoing monitoring and review of account performance, asset allocation and Client investment objectives. Factors which the Advisor shall consider in recommending independent manager(s) or separately managed accounts include the Client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. B. Related Persons The Advisor acts as the portfolio manager for the Program. Inasmuch as the execution costs for transactions effected in the Client account(s) will be paid by the Advisor, a conflict of interest arises in that the Advisor may have a disincentive to trade securities in the Client’s account(s). In addition, the amount of compensation received by the Advisor as a result of the Client’s participation in the Program may be more than what the Advisor would receive if the Client paid separately for investment advice, brokerage and other services. When managing a Client’s account(s) on a wrap fee basis, the Advisor shall receive as payment for its investment advisory services, the balance of the wrap fee after all other costs (including account transaction fees) incorporated into the wrap fee have been deducted. Accordingly, the Advisor has a conflict of interest because it could have an economic incentive to maximize its compensation by seeking to minimize the number of transactions/total costs or selecting mutual funds with no transaction fee in the Client's account(s). C. Supervised persons As discussed below, the Advisor also offers to its Clients, discretionary and/or nondiscretionary investment advisory services, on a non-wrap fee basis, as well as, Financial Planning and Consulting on a stand-alone basis. OTHER ADVISORY BUSINESS SERVICES INVESTMENT MANAGEMENT ON A NON-WRAP FEE BASIS With regard to new clients, the Advisor solely offers discretionary and/or non-discretionary investment advisory services on a non-wrap fee basis. The Advisor’s annual investment advisory fee (up to 1.50%), shall be charged quarterly in advance, depending upon the level of Client assets managed by the Advisor; 7  and or the overall relationship. The Advisor, at its sole discretion, may offer a schedule that differs from the schedule herein. Please see Item 5 of the Disclosure Brochure for additional details. Alternatively, the Advisor may offer its non-wrap investment management services on a flat fee basis. To the extent offered, the Advisor’s flat fee for non-wrap investment management services will be based upon various subjective and objective factors Advisor's annual investment advisory fee shall include investment advisory services, and, to the extent specifically requested by the Client, financial planning and consulting services. In the event that the Client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of the Advisor), the Advisor may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the Client. FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE BASIS) The Advisor may be engaged to provide a Client with a one-time financial plan without ongoing investment management services on a stand-alone separate fee basis. Prior to engaging the Advisor to provide planning or consulting services, Clients are generally required to enter into a Financial Planning and Consulting Agreement with the Advisor setting forth the terms and conditions of the engagement describing the scope of the services to be provided, and the portion of the fee that is due from the Client prior to the Advisor commencing services. If requested by the Client, the Advisor may recommend the services of other professionals, including certain of the Advisor’s representatives in their individual capacities as registered representatives of a broker- dealer, (See disclosure at Item 9) for implementation purposes. The Client is under no obligation to engage the services of any such recommended professional. The Client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Advisor. If the Client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the Client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not the Advisor, shall be responsible for the quality and competency of the services provided. It remains the Client’s responsibility to promptly notify the Advisor if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising the Advisor’s previous recommendations and/or services. MISCELLANEOUS ADVISORY SERVICES DISCLOSURE Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a Client, Advisor may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. Advisor does not serve as an attorney or accountant, and no portion of its services should be construed as legal or accounting services. Accordingly, Advisor does not prepare estate planning documents or tax returns. To the extent requested by a Client, Advisor may recommend the services of other professionals for certain non-investment implementation purpose (i.e., attorneys, accountants, insurance agents, etc.), including representatives of Advisor in their separate individual capacities as representatives Summit Trail Securities, LLC, an affiliated SEC registered and FINRA Member broker-dealer (“STS”). The Client is under no obligation to engage the services of any such recommended professional. The Client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Advisor or its representatives. 8  If the Client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the Client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not the Advisor, shall be responsible for the quality and competency of the services provided. The recommendation by Advisors’ representatives that a Client purchase a securities commission product through Advisors’ representative in their separate and individual capacities as a registered representative of STS, presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend investment products based on commissions to be received, rather than on the Client’s needs. No Client is under any obligation to purchase any securities commission products from an Advisor’s representative or to utilize the broker-dealer services of STS. Clients are reminded that they may purchase securities products recommended by Advisor through other, non-affiliated registered representatives and/or broker-dealers. Private Fund Investments - The Advisor may provide investment advice regarding affiliated and unaffiliated private investment funds. Unaffiliated Funds - The Advisor’s role relative to any unaffiliated private investment fund shall be limited to its initial and ongoing due diligence and investment monitoring services. If a Client determines to become an investor in an unaffiliated private fund, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of the Advisor calculating its investment advisory fee (unless the Client purchases the fund from the Advisor’s affiliated broker-dealer). The Advisor’s Clients are under no obligation to consider or make an investment in an unaffiliated private investment fund(s). Affiliated Funds - The Adviser is the General Partner and/or Investment Advisor to various private funds issued by Ascent Private Capital Management (the Affiliated Fund[s]). If a Client determines to invest in an Affiliated Fund, the amount of assets invested in the Affiliated Fund shall be included as part of “assets under management” for purposes of the Advisor calculating its investment advisory fee. The Advisor’s Clients are under no obligation to consider or make an investment in an Affiliated Fund. The Advisor does not receive a separate advisory fee or other forms of compensation for its investment advisory services to any Affiliated Funds. Rather, the Advisor’s only compensation is the advisory fee that it receives from any value included as a part of assets under management. Advisory Arrangements. Advisor may introduce Clients to private investment funds for which its serves as a sub-adviser. Advisor does not receive a separate sub-advisory fee for its sub-advisory services to the fund, nor any other type compensation from the fund. Rather, Advisor’s only compensation is the advisory fee that it receives from the Client as discussed above at Fees and Compensation. However, in the event that STS serves in a broker-dealer capacity for such funds, STS shall receive commission compensation. STS/Commission Purchases-The Advisor generally recommends private investment funds on a fee basis rather than on a commission basis through STS. STS will be recommended only when the Client prefers to pay a one-time commission to STS rather than an ongoing advisory fee to Advisor to monitor and review the fund on an ongoing basis. 9  Independent Managers. For those Clients that require an enhanced and/or specialized level of asset management services, Advisor may also recommend that certain Clients authorize the active discretionary management of a portion of their assets by and/or among certain independent investment manager(s). To the extent applicable, the Advisor shall recommend Independent Managers consistent with the Client’s investment objectives. Factors which the Advisor shall consider in recommending Independent Managers include the Client’s stated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The Advisor shall continue to render advisory services to the Client relative to the ongoing monitoring and reviewing of account performance, for which Advisor shall receive an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Managers. Clients who choose to engage the Advisor on a non-wrap fee basis and elect to utilize Independent Managers or separately managed accounts will incur costs in addition to the Advisor’s advisory fee. Management fees charged by Independent Managers, together with the fees charged by the broker- dealer/custodian of the Client’s assets, and any independent manager platform provider fee are exclusive of, and in addition to, Advisor’s non-wrap investment advisory fee set forth above. Clients who engage the Advisor on a wrap fee basis will not incur additional management fees should their investment portfolio utilized Independent Managers. The Advisor may provide investment advisory services to executives and/or principals of certain unaffiliated Independent Managers, thereby creating a conflict of interest. To the extent that the Advisor believes that the utilization of these investment managers is appropriate for a Client, the Advisor shall disclose the conflict to the Client and give the Client the right to restrict, in writing, the Advisor’s use of any such independent manager. Retirement Plan Rollovers – No Obligation / Conflict of Interest. A Client or prospective Client leaving an employer typically has four options regarding an existing retirement plan (and has the ability to engage in a combination of these options): (i) leave the assets in the former employer’s retirement plan, if permitted, (ii) rollover the assets to the new employer’s retirement plan, if one is available and rollovers are permitted, (iii) rollover to an individual retirement account (“IRA”), or (iv) cash out the account value (which could, depending upon the Client’s age, result in adverse tax consequences). If the Advisor recommends that a Client roll over their retirement plan assets into an account to be managed by the Advisor, such a recommendation presents a conflict of interest if the Advisor will earn new (or increase its current) compensation as a result of the rollover. The Advisor does not generally provide recommendations to Clients on rollovers. However, If Advisor provides a recommendation as to whether a Client should engage in a rollover or not, Advisor is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No Client is under any obligation to rollover retirement plan assets to an account managed by the Advisor. Non-Discretionary Service Limitations. Clients that determine to engage the Registrant on a non- discretionary investment advisory basis must be willing to accept that the Registrant cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the Client. Thus, in the event that Registrant would like to make a transaction for a Client’s account, and Client is unavailable, the Registrant will be unable to effect the account transaction (as it would for its discretionary Clients) without first obtaining the Client’s consent. 10  Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded funds are available directly to the public. Thus, a prospective Client can obtain many of the funds that may be utilized by Summit Trail independent of engaging Summit Trail as an investment advisor. However, if a prospective Client determines to do so, he/she will not receive the Summit Trail’s initial and ongoing investment advisory services. In addition to Summit Trail’s investment advisory fee described below, and transaction and/or custodial fees discussed below, Clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund expenses) Cash Positions. Advisor continues to treat cash as an asset class. As such, unless determined to the contrary by Summit Trail, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Advisor’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Advisor may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Advisor’s advisory fee could exceed the interest paid by the Client’s money market fund. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion, Advisor shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless the Advisor reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the Client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the Client of an imminent need for such cash, or the Client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within an actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the Client of a need for access to such cash, assets allocated to an unaffiliated investment manager and cash balances maintained for fee billing purposes. The Client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any unmanaged accounts. Portfolio Activity. Summit Trail has a fiduciary duty to provide services consistent with the Client’s best interest. As part of its investment advisory services, Summit Trail will review Client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the Client’s investment objective. Based upon these factors, there may be extended periods of time when Summit Trail determines that changes to a Client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no assurance that investment decisions made by Summit Trail will be profitable or equal any specific performance level(s). 11  Reporting of External Accounts. Advisor, in conjunction with the services provided by third-party services, may also provide periodic reporting services which can incorporate all of the Client’s investment assets, including those investment assets that are not part of the assets managed by the Advisor (the “Excluded Assets”). The Client and/or their other advisors that maintain trading authority, and not the Advisor, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless otherwise specifically agreed to, in writing, Advisor’s service relative to the Excluded Assets is limited to reporting only. The sole exception to the above shall be if the Advisor is specifically engaged to monitor and/or allocate the assets within the Client’s 401(k) account maintained away at the custodian directed by the Client’s employer. As such, except with respect to the Client’s 401(k) account (if applicable), Advisor does not maintain any trading authority for the Excluded Assets. Rather, the Client and/or the Client’s designated other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. In the event the Client desires that Advisor provide investment management services for the Excluded Assets, the Client must engage the Advisor to do so pursuant to the terms and conditions of the Investment Advisory Agreement between Advisor and the Client. Bitcoin, Cryptocurrency, and Digital Assets. The Advisor does not recommend or advocate for the purchase of, or investment in, Bitcoin, cryptocurrencies, or digital assets. Such investments are considered speculative and carry significant risk. For clients who want exposure to Bitcoin, cryptocurrencies, or digital assets, the Advisor, may advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Bitcoin and cryptocurrencies are digital assets that can be used for various purposes, including transactions, decentralized applications, and speculative investments. Most digital assets use blockchain technology, an advanced cryptographic digital ledger to secure transactions and validate asset ownership. Unlike conventional currencies issued and regulated by monetary authorities, cryptocurrencies generally operate without centralized control, and their value is determined by market supply and demand. While regulatory oversight of digital assets has evolved significantly since their inception, they remain subject to variable regulatory treatment globally, which may impact their risk profile and liquidity. Given that cryptocurrency investments are speculative and subject to extreme price volatility, liquidity constraints, and the potential for total loss of principal, the Advisor does not exercise discretionary authority to purchase cryptocurrency investments for client accounts. Any investment in cryptocurrencies must be expressly authorized by the client. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility, regulatory risk, technological risk, security and custody risk, and complete loss of principal. Client Obligations. In performing its services, Advisor shall not be required to verify any information received from the Client or from the Client’s other professionals, and is expressly authorized to rely thereon. Moreover, each Client is advised that it remains their responsibility to promptly notify the Advisor if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Advisor’s previous recommendations and/or services. Disclosure Statement. This Disclosure Brochure shall be provided to each Client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement. There is no material difference between how the Advisor manages wrap fee accounts and non-wrap fee accounts. However, as stated above, if a Client determines to engage the Advisor on a wrap fee basis the Client will pay a single fee for bundled services (i.e., investment advisory, brokerage, custody). The services 12  included in a wrap fee agreement will depend upon each Client’s particular need. If the Client determines to engage the Advisor on a non-wrap fee basis the Client will select individual services on an unbundled basis, paying for each service separately (i.e., investment advisory, brokerage, custody). Performance-Based Fees The Advisor does not directly accept performance-based fees. However, the Advisor may recommend Investment Managers and investment funds, including affiliated private funds, that will assess a performance-based fee. To the extent an affiliated fund pays a performance-based fee, it shall be paid to the fund’s general partner, and not the Advisor. In certain instances, the general partner of an affiliated fund will be an affiliate of the Advisor. To the extent there is an affiliation between the Advisor and the general partner, such relationship shall be disclosed in the private fund’s disclosure documentation, along with the payment of any performance-based fee to the Advisor’s affiliate. A recommendation to invest with an Investment Manager or investment fund with a performance-based fee arrangement would be preceded by an assessment as to the suitability and appropriateness of such an investment, relative to other similar investments, if any, that do not have a performance-based fee arrangement. Methods of Analysis, Investment Strategies and Risk of Loss The Advisor’s investment process encompasses three major areas: 1.) Asset Allocation, 2.) Investment Selection, and 3.) Portfolio Construction. The investment process is designed to be customized to each Client and their particular attributes. 1. Asset Allocation is the process for determining a long-term asset allocation that is appropriate for an investor, as well as considering how each asset class will fare in the intermediate-term in relation to its long-term expectations. The first step is to define which asset classes exist and how to categorize the world of investments. Asset classes must be unique, and investable for consideration. We believe there are roughly 15 asset classes that exist today for sophisticated investors. It is also important to classify these asset classes more broadly into groups that investors can understand. We believe all asset classes serve one of three purposes: Growth, Preservation, or Inflation Protection. Any asset class can be classified in one of these categories. By using broad categories that establish a clear goal and objective, we believe investors can better determine their proper allocation among the three groups, and therefore have portfolios that better fit their risk profile. 2. Investment selection is the process of determining how to invest in each asset class. We primarily utilize in open architecture, in that we do not generally select individual securities within our firm. Whenever possible, we build portfolios by selecting specialists in each asset class who focus their research process on a specific area of the investment marketplace. We typically utilize a combination of ETFs, Separate Accounts, Mutual Funds, and Limited Partnerships to invest our Client’s portfolios. In researching an active management organization, we utilize a research process built by the investment team at prior firms. We look at investment firms in four parts: Organization, Investment Process, Performance, and Operations. Our review of the organization is focused on determining whether the organization is likely to impede the investment process over the life of our investment. We seek to invest in firms that have positive attributes we prefer around 13  ownership structure, compensation, product distribution, capacity management and numerous other items. In reviewing an investment process we seek to understand the quality of the information the manager possesses, how they have utilized that information, and how they make portfolio decisions. This is a process that can review many individual investments over multiple years. We then will review performance, which is essentially the results of the investment process. Not all strong performance track records are the same, and we seek to understand in depth how manager has added value, and whether the nature of that added value is likely to continue. Finally, we review the firm’s operational capabilities, in terms of their operational policies and documents. In the case of Limited Partnerships, we conduct a review of the operations to ensure we are comfortable with the custodian, administrator, auditor, as well as other items. Ongoing due diligence is a critical component of our recommended manager selection, and it is necessary to continue to review all four aspects of our active managers on a forward-looking basis. While our ongoing due diligence includes Client’s legacy managers, we may undergo a more thorough level of due diligence of our recommended managers. We continue to monitor the organization for any changes or signs of maturity or decline. We analyze data regarding the portfolios, and how the portfolios change over time. For marketable investments, we review performance monthly, and based on the type of investment will analyze performance drivers like attribution analysis on a quarterly basis. If there are changes to any of the key attributes of our managers, we will make decisions about continuing to use a manager in Client portfolios, and could lead us to termination or redemption from an existing manager. 3. Portfolio construction is a process that marries the asset allocation and investment selection with the key attributes of the Client. Doing our review process with a Client, we will seek to understand their investment risk tolerance, engagement, belief in skill, tax status, income and spending needs, as well as numerous other factors. We will then create an investment policy on allocation to our three major asset class buckets: 1) Growth, 2) Preservation, or 3) Inflation Protection. Portfolio construction for a Client will continue to be an ongoing process as well. Making sure that as their needs and goals change over time, our portfolios change as well. The Advisor may utilize the following methods of security analysis: • Fundamental - (analysis performed on historical and present data, with the goal of making financial forecasts) • Technical – (analysis performed on historical and present data, focusing on price and trade volume, to forecast the direction of prices) The Advisor may utilize the following investment strategies when implementing investment advice given to Clients: • Long Term Purchases (securities held at least a year) • Short Term Purchases (securities sold within a year) • Margin Transactions (use of borrowed assets to purchase financial instruments) • Options (contract for the purchase or sale of a security at a predetermined price during a specific period of time) Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the 14  investments and/or investment strategies recommended or undertaken by the Advisor) will be profitable or equal any specific performance level(s). The Advisor’s methods of analysis and investment strategies do not present any significant or unusual risks. However, every method of analysis has its own inherent risks. To perform an accurate market analysis the Advisor must have access to current/new market information. The Advisor has no control over the dissemination rate of market information; therefore, unbeknownst to the Advisor, certain analyses may be compiled with stale information, severely limiting the value of the Advisor’s analysis. Furthermore, an accurate market analysis can only produce a forecast of the direction of market values. There can be no assurances that a forecasted change in market value will materialize into actionable and/or profitable investment opportunities. The Advisor’s primary investment strategies - Long Term Purchase and Short Term Purchases - are fundamental investment strategies. However, every investment strategy has its own inherent risks and limitations. For example, longer term investment strategies require a longer investment time period to allow for the strategy to potentially develop. Shorter term investment strategies require a shorter investment time period to potentially develop but, as a result of more frequent trading, may incur higher transactional costs when compared to a longer term investment strategy. In addition to the fundamental investment strategies discussed above, the Advisor may also implement and/or recommend the use of margin and options transactions. These strategies have a high level of inherent risk. Margin is an investment strategy with a high level of inherent risk. A margin transaction occurs when an investor uses borrowed assets to purchase financial instruments. The investor generally obtains the borrowed assets by using other securities as collateral for the borrowed sum. The effect of purchasing a security using margin is to magnify any gains or losses sustained by the purchase of the financial instruments on margin. To the extent that a Client authorizes the use of margin, and margin is thereafter employed by the Advisor in the management of the Client’s investment portfolio, the market value of the Client’s account(s) and corresponding fee payable by the Client to the Advisor may be increased. As a result, in addition to understanding and assuming the additional principal risks associated with the use of margin, Clients authorizing margin are advised of the conflict of interest whereby the Client’s decision to employ margin may correspondingly increase the management fee payable to the Advisor. Accordingly, the decision as to whether to employ margin is left totally to the discretion of Client. The use of options transactions as an investment strategy involves a high level of inherent risk. Option transactions establish a contract between two parties concerning the buying or selling of an asset at a predetermined price during a specific period of time. During the term of the option contract, the buyer of the option gains the right to demand fulfillment by the seller. Fulfillment may take the form of either selling or purchasing a security depending upon the nature of the option contract. Generally, the purchase or the recommendation to purchase an option contract by the Advisor shall be with the intent of offsetting/”hedging” a potential market risk in a Client’s portfolio. Although the intent of the options-related transactions that may be implemented by the Advisor is to hedge against principal risk, certain of the options-related strategies (i.e., straddles, short positions, etc.), may, in and of themselves, produce principal volatility and/or risk. Thus, a Client must be willing to accept these 15  enhanced volatility and principal risks associated with such strategies. In light of these enhanced risks, Client may direct the Advisor, in writing, not to employ any or all such strategies for their accounts. Sustainable Investing Limitations. Sustainable Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the active investment manager investment process assessment. This assessment process is a capability the Advisor continues to develop. Investment managers have varying views about how to incorporate ESG data in their investment process. Some managers do not use ESG at all in their process. Others may choose to use it extensively. In our assessment of investment managers, we seek over time to understand how they may use ESG data or processes, if at all. There are a variety of ways an investment manager may use ESG data. While there are a wide variety of approaches, we may seek to develop an understanding of how they use Environmental data (i.e., considers how a company considers the environment in its business operations); Social data (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance data (i.e., company management considerations. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by STA), there can be no assurance that investment in strategies that use ESG data will be profitable, prove successful, or outperform strategies that do not use ESG data. Currently, the Advisor primarily allocates Client investment assets among various individual equity and fixed income securities, mutual funds and/or exchange traded funds, Independent Managers, and separately managed accounts on a discretionary and non-discretionary basis in accordance with the Client’s designated investment objective(s). From time to time, and only in those cases where the Client is eligible to do so, the Advisor may recommend participating in initial and secondary public offerings (“IPOs”). In addition to the risks set forth above, given the nature of such offerings they may have more volatility in price than existing equities that are currently traded and have a trading history. Accordingly, the decision as to whether to participate in initial or secondary offerings is left totally to the discretion of Client. In addition, the following are some of the risks associated with the Advisor’s strategies: ETFs are subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Mutual funds are subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each Client for review and consideration. Unlike liquid investments that a Client may own, private investment funds do not provide 16  daily liquidity or pricing. Each prospective Client investor will be required to complete a Subscription Agreement, pursuant to which the Client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Cybersecurity Risk The information technology systems and networks that Advisor and its third-party service providers use to provide services to Advisor’s clients employ various controls that are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Advisor’s operations and/or result in the unauthorized acquisition or use of clients’ confidential or non- public personal information. In accordance with Regulation S-P, the Advisor is committed to protecting the privacy and security of its clients' non-public personal information by implementing appropriate administrative, technical, and physical safeguards. Advisor has established processes to mitigate the risks of cybersecurity incidents, including the requirement to restrict access to such sensitive data and to monitor its systems for potential breaches. Clients and Advisor are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur financial losses and/or other adverse consequences. Although the Advisor has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that the Advisor does not control the cybersecurity measures and policies employed by third-party service providers, issuers of securities, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchanges, and other financial market operators and providers. In compliance with Regulation S-P, the Advisor will notify clients in the event of a data breach involving their non-public personal information as required by applicable state and federal laws. Voting Client Securities Except for Assets allocated to independent investment managers (for which the manager shall retain proxy voting authority), the Advisor (unless provided otherwise in writing), in conjunction with the services provided by Broadridge, an unaffiliated proxy voting vendor, shall be responsible for directing the manner in which Account proxies shall be voted. The Advisor, at its expense, has also engaged Broadridge to assist the Client with class-action matters. The Advisor shall not receive any compensation from the service provider. The Client is under no obligation to engage the service provider. Unless the Client notifies the Adviser to the contrary, in writing, the Advisor shall engage the service provider on the Client’s behalf for its class-action service. If the Client notifies the Adviser, in writing, that it does not want to participate in the class-action service, the Client shall be exclusively responsible for reviewing/voting/filing class actions claims. The Advisor, in conjunction with Broadridge, understands its duty to vote Client proxies in the best interest of its Clients. Furthermore, any material conflicts between the Advisor’s interests and those of our Clients with regard to a proxy vote must be resolved before proxies are voted. Clients may request a copy of our written policies and procedures regarding proxy voting and/or information on how particular proxies were voted by contacting our CCO. In addition, the Advisor has also contracted with Broadridge as provider to file Class Actions "Proof of Claim" forms. 17  Occasionally, securities held in the accounts of Clients will be the subject of class action lawsuits. Broadridge provides a comprehensive review of our Clients’ possible claims to a settlement throughout the class action lawsuit process. Broadridge actively seeks out any open and eligible class action lawsuits. Additionally, Broadridge files, monitors and expedites the distribution of settlement proceeds in compliance with SEC guidelines on behalf of Clients. Broadridge retains 20% of the proceeds from any class action awards obtained by our Clients through the use of its services. Clients may choose to optout of this service. ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS The Advisor shall be the Program’s portfolio manager. The Advisor shall provide investment advisory services specific to needs of each Client. Prior to providing investment advisory services, an investment adviser representative will discuss with each Client, their particular investment objective(s). The Advisor shall allocate each Client’s investment assets consistent with their designated investment objective(s). Clients may, at any time, impose restrictions, in writing, on the Advisor’s services. As indicated above, each Client is advised that it remains their responsibility to promptly notify the Advisor if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Advisor’s previous recommendations and/or services. To the extent the Program utilizes independent manager(s), the Advisor shall provide the independent manager(s) with each Client’s particular investment objective(s). Any changes in the Client’s financial situation or investment objectives reported by the Client to the Advisor shall be communicated to the independent manager(s) within a reasonable period of time. ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS The Client shall have, without restriction, reasonable access to the Program’s portfolio manager. ITEM 9 – ADDITIONAL INFORMATION A. The Advisor has not been the subject of any disciplinary actions. Other Financial Activities and Affiliations Registered Representative of Summit Trail Securities, LLC. Certain Advisory Persons of the Advisor are also registered representatives of Summit Trail Securities, LLC (“STS”), an SEC registered and FINRA member broker-dealer. Neither the Advisor, nor its Advisory Persons, are registered or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or a representative of the foregoing. Registered Representatives of an Affiliated Broker Dealer. As disclosed above, certain Advisory Persons of the Adviser are also registered representatives of STS, an affiliated SEC registered and FINRA member broker-dealer. Clients can choose to engage an Advisory Person, and/or other related persons of STS in their individual capacities as registered representatives of STS, to effect securities brokerage transactions on a commission basis. Conflict of Interest: The recommendation by an Advisory Person or a related person of STS, that a Client purchase a securities commission product presents a conflict of interest, as the receipt of commissions may 18  provide an incentive to recommend investment products based on commissions received, rather than on a particular Client’s need. No Client is under any obligation to purchase any commission products from an Advisory Person or through the Advisors’ affiliated broker-dealer, STS. Clients are reminded that they may purchase securities products recommended by the Advisor through other, non-affiliated registered representatives of a broker-dealer and through other non-affiliated broker-dealers. The Advisor’s Chief Compliance Officer, Joseph Erigo, remains available to address any questions that a Client or prospective Client may have regarding the above conflicts of interest. Dynasty Financial Partners, LLC Affiliation The Advisor maintains a business relationship with Dynasty, which provides the Advisor with operational and back office support including access to a network of service providers. Through the Dynasty network of service providers, the Advisor has access to discounts on trading technology, reporting, custody, brokerage, compliance and other related services. While the Advisor believes this open architecture structure for operational services best serves the interests of its advisory Clients, this relationship may present certain conflicts of interest due to the fact that Dynasty retains a portion of the platform or other third party fees paid by the Advisor or Clients for the services referenced above. In light of the foregoing, the Advisor seeks at all times to ensure that any material conflicts are disclosed and handled in a manner that is aligned with its Clients’ best interests. The Advisor does not receive any portion of the fees paid directly to Dynasty, its affiliates or the service providers made available through Dynasty’s platform. In addition, the Advisor reviews all such relationships, including the service providers engaged through Dynasty, on an ongoing basis in an effort to ensure Clients are receiving competitive rates in relation to the quality and scope of the services provided. Dynasty’s subsidiary, Dynasty Wealth Management, LLC (“DWM”), a registered investment advisor, also provides access to a range of investment services, including separately managed accounts (“SMAs”), mutual fund and exchange-traded fund (“ETF”) asset allocation strategies and unified managed accounts (“UMAs”) managed by external third party managers (collectively the “Investment Programs”). The Advisor may receive more advantageous pricing as assets increase, which poses a conflict of interest with the Client. In light of the foregoing, the Advisor seeks at all times to determine that any such conflicts are addressed on a fully-disclosed basis and investment decisions are handled in a manner that is aligned with its Clients’ best interests. Summit Trail does not receive any portion of the fees paid directly to Dynasty or the service providers made available through its platform, and the Summit Trail reviews all such relationships on an ongoing basis in an effort to ensure Clients are receiving competitive rates in light of the services they receive. The Advisor has obtained financing for its business through Dynasty Advisors Financing Services, LLC (“DAFS”), a wholly-owned subsidiary of Dynasty Financial Partners, LLC (and affiliate of Dynasty Wealth Management, LLC). DAFS, in partnership with various independent banks, has provided the Advisor with a lending facility to assist with business transition expenses and other costs associated with launching the Advisor. The Advisor is not obligated to utilize the DAFS lending facility in order to obtain other services from Dynasty. All lending is subject to standard underwriting requirements. A portion of this loan may be furnished directly from Dynasty as a co- lender. In such situations, the Advisor will be subject to the same lending facility criteria and requirements as applied by the independent bank. Insurance Company. The Advisor is a licensed insurance agency, and as such, may offer insurance products on a commission basis. The Advisor shall generally introduce the Client to an unaffiliated insurance agency to manage the insurance process. The Advisor shall receive a portion of the insurance commission earned 19  by the unaffiliated insurance agency. No Client shall be under any obligation to purchase any insurance products from the Advisor or such introduced insurance agency. The recommendation by an Advisory Person that a Client purchase an insurance product presents a conflict of interest, as the receipt of commissions may provide an incentive to recommend insurance products based on commissions to be received, rather than based on a particular Client’s need. Clients are reminded that they remain free to purchase insurance products through other insurance agencies. Non-Soft Dollar Research and Additional Benefits Although not a material consideration when determining whether to recommend that a Client utilize the services of a particular broker-dealer/custodian, the Advisor receives from IB, Pershing, Fidelity, and/or Schwab without cost (and/or at a discount) support services and/or products, certain of which assist the Advisor to better monitor and service Client accounts maintained at such institutions. Included within the support services that may be obtained by the Advisor may be investment-related research, pricing information and market data, software and other technology that provide access to Client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by Advisor in furtherance of its investment advisory business operations. As indicated above, certain of the support services and/or products received may assist the Advisor in managing and administering Client accounts. Others do not directly provide such assistance, but rather assist the Advisor to manage and further develop its business enterprise. There is no corresponding commitment made by the Advisor to IB, Pershing, Fidelity or Schwab, or any other entity, to invest any specific amount or percentage of Client assets in any specific mutual funds, securities or other investment products as a result of the above arrangement. Additional Benefits Advisor has received from Pershing and Fidelity, certain additional economic benefits, related to business development needs, (“Additional Benefits”) that may or may not be offered to Advisor again in the future. Specifically, the Additional Benefits include partial payment for certain research and technology expenses for the benefit of the Advisor. Over the past two years, Pershing has made payments to third party vendors for technology and research related expenses. Pershing and Fidelity has made one off payments between $1,000 and $25,000 infrequently and irregularly to these third party service providers over the course of the last two years. Each payment is non-recurring and individually negotiated. The Advisor has no expectation that these Additional Benefits will be offered again; however, Advisor reserves the right to negotiate for these Additional Benefits in the future. Pershing and Fidelity provides the Additional Benefits to Advisor in its sole discretion and at its own expense, and neither the Advisor nor its Clients pay any fees to Pershing for the Additional Benefits. The Advisor and Pershing and/or Fidelity has entered into any written agreement to govern the Additional Benefits. B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information The Advisor maintains a Code of Ethics that is applicable to all individuals associated with Summit Trail (our “Supervised Persons”). In addition, the Advisor maintains an investment policy relative to personal securities transactions for Supervised Persons with access to Client investment information (our “Access Persons”). This investment policy is part of the Advisor’s overall Code of Ethics, which serves to establish a standard of business conduct that is based upon fundamental principles of openness, integrity, honesty and trust, a copy of which is available upon request. 20  In accordance with Section 204A of the Advisers Act, the Advisor also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by the Advisor or any Supervised Person. As disclosed above, the Advisor may recommend participation in initial and secondary offerings to eligible Clients. In such cases, offerings may be available in limited quantities wherein the Advisor may need to allocate shares to Clients in a lesser proportion than as requested by the Client. These situations create a conflict of interest and in such cases the Advisor will manage such conflicts through applicable policies and procedures. As disclosed above, related persons have a financial interest in the affiliated private funds. The terms and conditions for participation in each affiliated private fund, including management fees, conflicts of interest, and risk factors, are set forth in the fund’s offering documents. The Advisor and/or its Access Persons may buy or sell securities that are also recommended to Clients. This practice may create a situation where the Advisor and/or its Access Persons are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a conflict of interest. Practices such as “scalping” (i.e., a practice whereby the owner of shares of a security recommends that security for investment and then immediately sells it at a profit upon the rise in the market price which follows the recommendation) could take place if the Advisor did not have adequate policies in place to detect such activities. In addition, this requirement can help detect insider trading, “front-running” (i.e., personal trades executed prior to those of the Advisor’s Clients) and other potentially abusive practices. The Advisor has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of each of the Advisor’s “Access Persons”. The Advisor’s securities transaction policy requires that an Access Person of the Advisor must provide the Chief Compliance Officer or his/her designee with a written report of their current securities holdings within ten (10) days after becoming an Access Person. Additionally, each Access Person must provide or make available to the Chief Compliance Officer or his/her designee a list of reportable transactions each calendar quarter as well as a written annual report of the Access Person’s securities holdings; provided, however that at any time that the Advisor has only one Access Person, he or she shall not be required to submit any securities report described above. The Advisor and/or its Access Persons may buy or sell securities, at or around the same time as those securities are recommended to Clients. This practice creates a situation where the Advisor and/or its Access Persons are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a conflict of interest. The Advisor has a personal securities transaction policy in place to monitor the personal securities transaction and securities holdings of each of Advisor’s Access Persons. Review of Accounts For those Clients to whom Advisor provides investment supervisory services, account reviews are conducted on an ongoing basis by the Advisor's Principals. All investment supervisory Clients are advised that it remains their responsibility to advise the Advisor of any changes in their investment objectives and/or financial situation. All Clients (in person or via telephone) are encouraged to review financial planning issues (to the extent applicable), investment objectives and account performance with the Advisor on an annual basis. 21  The Advisor may conduct account reviews on an other than periodic basis upon the occurrence of a triggering event, such as a change in Client investment objectives and/or financial situation, market corrections and Client request. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the broker-dealer/custodian and/or program sponsor for the Client accounts. The Advisor may also provide a written periodic report summarizing account activity and performance. Client Referrals and Other Compensation The Advisor receives an indirect economic benefit from Pershing and/or Fidelity. The Advisor, without cost (and/or at a discount), receives support services and/or products from Pershing and/or Fidelity. The Advisor’s Clients do not pay more for investment transactions effected and/or assets maintained at Pershing and/or Fidelity as result of this arrangement. There is no corresponding commitment made by the Advisor to Pershing and/or Fidelity or any other entity to invest any specific amount or percentage of Client assets in any specific mutual funds, securities or other investment products as a result of the above arrangement. The Advisor’s Chief Compliance Officer, Joseph Erigo, remains available to address any questions that a Client or prospective Client may have regarding the above arrangement and any corresponding conflict of interest any such arrangement may create Financial Information The Advisor does not solicit fees of more than $1,200, per Client, six months or more in advance. The Advisor is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain Client accounts. The Advisor has not been the subject of a bankruptcy petition. 22