COASTAL BRIDGE ADVISORS, LLC

Item 1 – Cover Page COASTAL BRIDGE ADVISORS 54 Wilton Road, 1st Floor Westport, CT 06880 (203) 683-1530 www.coastalbridgeadvisors.com 3/31/2025 This fee brochure provides information about the qualifications and business practices of Coastal Bridge Advisors, LLC (hereinafter “Coastal Bridge Advisors” or “the Firm”). If you have any questions about the contents of this Brochure, please contact P. Elizabeth Perez at (203)683-1530. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Coastal Bridge Advisors is available on the SEC’s website at www.adviserinfo.sec.gov. Coastal Bridge Advisors is an SEC Registered Investment Adviser. Registration does not imply any level of skill or training.  Item 2 – Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If an adviser is filing an annual updating amendment and there are any material changes to an adviser’s disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since the last annual update filed March 28, 2024, this Brochure was revised to reflect the following material changes: Clients of TrinityPoint Wealth, LLC (“TrinityPoint”), an SEC-registered investment advisory firm headquartered in Millford, CT, have joined Coastal Bridge Advisors. Clients of TrinityPoint were formally notified of the transaction and assigned their advisory agreements to Coastal Bridge Advisors. Items 4 and 5 of the Brochure have been revised to take into account changes resulting from the transaction. Coastal Bridge Advisors does not offer a Wrap Fee Program. Accordingly, all details and references related to the Wrap Fee Program have been removed, and our Wrap Fee Program Brochure has been retired. We no longer have a minimum account requirement, and Item 7 has been updated accordingly. We recommend to certain clients that they invest a portion of their assets in a separately managed account strategy that is managed by an affiliate of our firm. Please see Items 4, 5, and 10 for details of this arrangement. We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). UPTIQ and Flourish are compensated by sharing in the revenue earned by such third-party institutions for serving our clients. When legally permissible, UPTIQ and Flourish each shares a portion of this earned revenue with an affiliate of our firm. The affiliate distributes this revenue to us when we are licensed to receive such revenue (or when no such license is required) and the distribution is not otherwise legally prohibited. Further information on this conflict of interest is available in Items 4, 5, and 10 of this Brochure. We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”). If FRS places an insurance product for our client or refers our client to an insurance broker and there is a subsequent purchase of insurance through the broker, then FRS will receive a portion of the upfront and/or ongoing commissions associated with the sale by the insurance carrier with which the policy was placed. The amount of insurance commission revenue earned by FRS is considered for purposes of determining the amount of additional compensation that certain of our financial professionals are entitled to receive. Additionally, certain of these brokers pay FRS periodic fees to participate in the FRS platform and, thereby, to offer their services to our clients and certain of our affiliates’ clients. Further information on this conflict of interest is available in Items 4, 5 and 10 of this Brochure. We are amending our client agreements so that we will no longer accept proxy voting authority. We have updated Item 17 accordingly.  Item 3 – Table of Contents Item 1 – Cover Page ...................................................................................................................................... 1 Contents Item 2 – Material Changes ............................................................................................................................ 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 – Advisory Business ........................................................................................................................... 4 Item 5 – Fees and Compensation ................................................................................................................. 8 Item 6 – Performance-Based Fees and Side-by-Side Management ........................................................... 12 Item 7 – Types of Clients ............................................................................................................................. 12 Item 9 – Disciplinary Information ............................................................................................................... 15 Item 10 – Other Financial Industry Activities and Affiliations .................................................................... 16 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 20 Item 12 – Brokerage Practices .................................................................................................................... 21 Item 13 – Review of Accounts ..................................................................................................................... 24 Item 14 – Client Referrals and Other Compensation .................................................................................. 24 Item 15 – Custody ....................................................................................................................................... 26 Item 16 – Investment Discretion ................................................................................................................ 27 Item 17 – Voting Client Securities ............................................................................................................... 27 Item 18 – Financial Information .................................................................................................................. 28  Item 4 – Advisory Business Coastal Bridge Advisors is a limited liability company organized in Delaware, and has been registered with the United States Securities and Exchange Commission since 2009. Clients of TrinityPoint Wealth, LLC (“TrinityPoint”), previously an SEC-registered investment advisory firm headquartered in Milford, CT, have joined Coastal Bridge Advisors. Clients of TrinityPoint were formally notified of the transaction and assigned their advisory agreements to Coastal Bridge Advisors. Coastal Bridge Advisors provides financial planning, consulting, and wealth management services to its clients. Coastal Bridge Advisors provides close consultation and consideration of its clients’ goals and risk tolerance before reaching a mutual decision with the client on how best to seek to build and preserve their wealth. Coastal Bridge Advisors follows a rigorous and disciplined process and seeks to leverage high-quality investment products and providers to create a diversified portfolio aimed at meeting its clients’ objectives. Coastal Bridge Advisors is results focused. The Firm’s goal-based investment planning process is designed to deal with significant events in its clients’ lives and in the external environment. As conditions change, Coastal Bridge Advisors will implement mid-course corrections with the goal of keeping its clients on-track. Coastal Bridge Advisors has been in business since December 2009. As of December 31, 2024, Coastal Bridge Advisors had $4,595,660,113 in assets under management, of which $4,420,171,742 was managed on a discretionary basis and $175,488,371 was managed on a non-discretionary basis. Prior to engaging Coastal Bridge Advisors to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with Coastal Bridge Advisors setting forth the terms and conditions under which Coastal Bridge Advisors renders its services (collectively the “Agreement”). This disclosure brochure describes the business of Coastal Bridge Advisors. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of Coastal Bridge Advisors’ officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on Coastal Bridge Advisors’ behalf and is subject to Coastal Bridge Advisors’ supervision or control. Principal Ownership Coastal Bridge Advisors is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Coastal Bridge Advisors is a wholly-owned indirect subsidiary of Focus LLC. Focus Financial Partners Inc. is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because Coastal Bridge Advisors is an indirect,  wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Coastal Bridge Advisors. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. Coastal Bridge Advisors is managed by James Betzig, and Mark Dupont ("Coastal Bridge Advisors Principals"), pursuant to a management agreement between CBA Mgmt Co, LLC, and Coastal Bridge Advisors, LLC. The Coastal Bridge Advisors Principals serve as officers of Coastal Bridge Advisors and are responsible for the management, supervision and oversight of the Firm. Types of Advisory Services Coastal Bridge Advisors provides holistic and personalized financial planning and discretionary and non-discretionary investment advisory services to individuals, including high net worth individuals, and entities, including, but not limited to, family offices, trusts, estates, private foundations, and qualified retirement plans. Financial Planning and Consulting Services Coastal Bridge Advisors can provide its clients with a broad range of comprehensive financial planning and consulting services. These services can include, but are not limited to, cash flow analysis, investment planning, retirement planning, estate planning, personal savings, educational savings, retirement education, education, business planning, investments, insurance, and tax needs of the client and other areas of a client’s financial situation. Additionally, through Financial Institutions (as defined below), Coastal Bridge Advisors provides margin loans, collateralized loans against a client’s holdings and access to residential mortgages. The Firm’s financial planning and consulting services can be included as part of Coastal Bridge Advisors’ overall investment management services (described below). Coastal Bridge Advisors may recommend the services of itself, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Coastal Bridge Advisors recommends its own services. The client is under no obligation to act upon any of the recommendations made by Coastal Bridge Advisors under a financial planning or consulting engagement or to engage the services of any such recommended professional, including Coastal Bridge Advisors itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Coastal Bridge Advisors’ recommendations. Clients are advised that it remains their responsibility to promptly notify Coastal Bridge Advisors if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Coastal Bridge Advisors’ previous recommendations and/or services.  Investment Management Services As detailed in Item 8, Coastal Bridge Advisors provides investment management services to its clients. Coastal Bridge Advisors allocates a majority of in accordance with their stated investment objectives. In addition, Coastal Bridge Advisors also recommends that certain eligible clients invest in privately placed securities, which can include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds). In designing and implementing customized models and portfolio strategies, Coastal Bridge Advisors can manage, on a discretionary or non-discretionary basis, a broad range of investment strategies and vehicles. Coastal Bridge Advisors allocates client investment management assets among External Managers (as defined below), among various mutual funds, exchange-traded funds (“ETFs”), and individual debt and equity securities in accordance with clients’ stated investment objectives. Coastal Bridge Advisors may further recommend to clients that all or a portion of their investment portfolio be managed on a discretionary basis by one or more private investment funds and/or investment management programs, external money managers of separately managed accounts or investment platforms (“External Managers”). The client may be required to enter into a separate agreement with the External Manager(s), which will set forth the terms and conditions of the client’s engagement of the External Manager. Coastal Bridge Advisors generally renders services to the client relative to the discretionary selection of External Managers. Coastal Bridge Advisors also assists in establishing the client’s investment objectives for the assets managed by External Managers, monitors and reviews the account performance and defines any restrictions on the account. The investment management fees charged by the designated External Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, are exclusive of, and in addition to, the annual advisory fee charged by Coastal Bridge Advisors. When Adviser provides investment advice to you regarding your retirement plan account or individual retirement account, Adviser is 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. The way Adviser makes money creates some conflicts with your interests, so Adviser operates under a special rule that requires Adviser to act in your best interest and not put our interest ahead of yours. As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. We implement investment advice on behalf of certain clients in held-away accounts that are maintained at independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary custodian(s). The order management system that we use for some held-away accounts is provided by Pontera Solutions, Inc. We review, monitor, and manage those held-away accounts in an integrated way with client accounts held at our primary custodian(s). Further information  about this service is available in Item 5. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, however, clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage Coastal Bridge Advisors to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Coastal Bridge Advisors directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of these services and other important information. Coastal Bridge Advisors tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Coastal Bridge Advisors consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Coastal Bridge Advisors if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Coastal Bridge Advisors determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any unwaivable rights you possess. We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). Please see Items 5 and 10 for a fuller discussion of these services and other important information. Use of External Managers As mentioned above, Coastal Bridge Advisors recommends that most clients authorize the active discretionary management of a portion of their assets by and/or among certain External Managers, based upon the stated investment objectives of the client. The terms and conditions of the engagement are set forth in a written agreement between Coastal Bridge Advisors and  the designated External Managers or wrap sponsor (such as Envestnet Inc.). For certain External Managers, the specific terms and conditions may be set forth in a separate written agreement between the client and the External Manager. Coastal Bridge Advisors generally renders services to the client relative to the discretionary selection of External Managers. Coastal Bridge Advisors also monitors and reviews the account performance and the client’s investment objectives. Coastal Bridge Advisors receives an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated External Managers. In addition to Coastal Bridge Advisors’ written disclosure statement, the client also receives the written disclosure statement of the designated External Managers. Certain External Managers can impose more restrictive account requirements and varying billing practices than Coastal Bridge Advisors. In such instances, Coastal Bridge Advisors can alter its corresponding account requirements and/or billing practices to accommodate those of the External Managers. We invest certain of our clients’ assets in separately managed account (“SMA”) strategies managed by Alley Investment Management Company, LLC (“Alley Company”), an affiliate that is under common control with us. Our affiliate collects a management fee from assets placed in these SMA strategies, including but not limited to our clients’ assets. Please see Items 5 and 10 of this Brochure for further details. Non-Purpose Loans Where clients deem beneficial and appropriate based on their risk tolerance and investment objectives, a non-purpose loan will be utilized as part of their financial planning strategy. A non-purpose loan is a type of loan that uses an investment portfolio as loan collateral and the proceeds of which cannot be used to purchase, carry, or trade securities. This type of loan allows investors access to funds without having to sell their investments. The proceeds of non- purpose loans may be deployed for a variety of for personal uses, such as for education, real estate, taxes, or other expenses. Such loans, using a client portfolio as collateral, are high risk, and suitability will depend on other client assets and the client’s risk profile. Health Savings Account Management Coastal Bridge Advisors offers investment advisory services for client Health Savings Accounts (“HSAs”) to assist clients in investing HSA assets among mutual fund investment options, which will be reviewed every six months. Coastal Bridge Advisors utilizes the Health Savings Administrators platform to provide an investment only HSA vehicle, and Health Savings Administrators comes with a collection of educational tools. Coastal Bridge Advisors will be paid a negotiated flat-dollar advisory fee directly from the HSA account. Coastal Bridge Advisors will monitor the client’s account and make investment recommendations based on the client’s responses to a web-based interactive questionnaire that establishes a risk profile based on client goals, objectives, time horizon and circumstances Subadvisory Arrangement Coastal Bridge Advisors is a subadviser of Fergus Reinsurance Limited (“Fergus”), a Bermuda- based reinsurance company. Depending on our clients’ investment objectives and risk  tolerance and their eligibility to invest in Fergus, we will recommend Fergus to our clients as a way to diversify their portfolios. See Items 5 and 10 for additional information. ERISA Services Coastal Bridge Advisors provides discretionary and non-discretionary, fiduciary, and non- fiduciary advisory services to the sponsors of the defined contribution, defined benefits and non-qualified deferred compensation plans, who have ultimate authority to direct the investing and reinvesting of plan assets as they deem appropriate, considering each plan’s stated objective, liquidity needs, and stated policies and guidelines. Providing non-discretionary investment services to an ERISA plan means that the ERISA plan client retains and exercises the final decision-making authority for implementing or rejecting Coastal Bridge Advisors’s recommendations. Providing discretionary investment management services as an ERISA 3(38) investment manager means Coastal Bridge Advisors makes the investment decisions in its sole discretion, without the ERISA plan client’s prior approval. Certain of the foregoing services are provided by Coastal Bridge Advisors as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). To the extent a client’s plan is covered by ERISA, in accordance with ERISA Section 408(b)(2), each plan sponsor is provided with a written description of Coastal Bridge Advisors’s fiduciary status, the specific services to be rendered and all direct and indirect compensation Coastal Bridge Advisors reasonably expects under the engagement. When Coastal Bridge Advisors provides investment advice for a fee to an ERISA plan or ERISA plan participant, it is a fiduciary under ERISA. Coastal Bridge Advisors is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plans and ERISA plan participants. Coastal Bridge Advisors is also a fiduciary under section 4975 of the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, Coastal Bridge Advisors is subject to specific duties and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction exemption. Retirement Plan Consulting Services Coastal Bridge Advisors provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is individually negotiated and customized, and includes any or all of the following services: Plan Design and Strategy; Plan Review and Evaluation; Executive Planning & Benefits; Investment Selection; Plan Fee and Cost Analysis; Plan Committee Consultation; Fiduciary and Compliance; and Participant Education. Coastal Bridge Advisors’ Supervised Persons can offer insurance products under a commission arrangement. Being paid on commission gives our supervised persons an incentive to recommend the purchase of insurance products to receive commissions rather than based on  a client’s needs. Clients are free to accept or reject the recommendation of insurance products, as they wish. Item 5 – Fees and Compensation Coastal Bridge Advisors offers its services on a fee basis, which can include fixed fees as well as fees based upon assets under management. As described in greater detail below, Coastal Bridge Advisors charges an annual advisory fee that is agreed upon with each client and set forth in the client’s investment advisory agreement. If we have agreed to provide investment advisory services to held-away accounts, our investment advisory fee will be charged on those assets and not solely assets held in the account of a custodian we recommend. Coastal Bridge Advisors and the client may choose to negotiate an annual advisory fee that varies from the schedule below. Factors upon which a different annual advisory fee will be based include, but are not limited to, the size and nature of the relationship, the services rendered, the nature and complexity of the products and investments involved, time commitments, and travel requirements. Coastal Bridge Advisors will, in its sole discretion, waive its fees in their entirety for friends and family of the Firm and/or reduce its fees for certain clients, and could change the above listed fee amounts at any time. The negotiated advisory fee may include the financial planning services described above. Clients who transitioned to Coastal Bridge Advisors from TrinityPoint have fee schedules/rates that are different than the fee schedule below. Those accounts have been grandfathered in under a previously executed investment advisory agreement. These fee schedules contain rates that in some cases are higher than Coastal Bridge’s current fee rates. Financial Planning and Consulting Fees Coastal Bridge Advisors offers financial planning services. Basic financial planning services are generally included in the investment management fee for clients who engage Coast Bridge Advisors for investment management services. For clients that we agree to provide financial planning and consulting services on a standalone basis, Coastal Bridge Advisors can charge a fixed fee and/or hourly fee. These fees are negotiable, but generally range from $1,000 to $120,000, depending upon the level and scope of the services and the professional rendering of the services. If the client engages Coastal Bridge Advisors for investment management services, Coastal Bridge Advisors could potentially offset all or a portion of the financial planning and consulting fees that have been paid. Coastal Bridge Advisors reserves the right to charge a minimum fee. Prior to engaging Coastal Bridge Advisors to provide financial planning and/or consulting services, the client is required to enter into a written agreement with Coastal Bridge Advisors setting forth the terms and conditions of the engagement. For one-time projects, Coastal Bridge Advisors generally requires one-half of the consulting fee (estimated fixed) payable upon entering the written agreement while the balance is generally due upon delivery of the  completion of the agreed upon services. Ongoing services will be prorated and billed per the Agreement (typically monthly or quarterly). From time to time, CBA accepts payment for the entire project upon completion. Investment Management Fee Coastal Bridge Advisors generally provides investment management services for an annual asset-based fee. The manner in which we charge investment advisory fees is specified in the client agreement. After the initial billing period, Coastal Bridge Advisors’ asset-based fee is prorated and charged quarterly, in advance, based upon the market value of the assets on the last day of the previous quarter as valued by third-party sources selected by the Firm, such as Envestnet Inc. Cash, accrued dividends, accrued interest and the value of securities held on margin are included for billing purposes. Clients who joined Coastal Bridge Advisors from TrinityPoint continue to be billed as specified in their client agreements. If based on a percentage of the value of assets under management, the advisory fee of legacy TrinityPoint clients generally is payable quarterly in advance, based on the average daily value of the client’s accounts in, and through the last day of, the previous quarter, including cash, accrued dividends, accrued interest, and the value of securities purchased on margin. Our standard fee schedule is as follows: PORTFOLIO VALUE First $1,000,000 ANNUAL FEE* 1.25% $1,000,000 - $5,000,000 1.00% $5,000,000 - $10,000,000 0.80% $10,000,000 - $50,000,000 0.65% Above $50,000,000 0.50% *The fee rate shown applies only to client assets in that tier. Notwithstanding the foregoing, the annual fee for assets under management in accounts held at Cidel Bank & Trust, Inc. (“Cidel”) will be negotiated and will generally be higher than the fee schedule set forth herein, due to the additional administrative cost associated with the Firm’s management of such accounts. As set forth in Item 12, below, the Firm will recommend Cidel as custodian to certain non-US clients and high net worth US clients with interests in foreign entities (e.g. trusts, limited liability companies, and partnerships). As stated above, the fee the client is obligated to pay is specified in the client agreement and the fees are potentially negotiable. Retirement Plan Consulting Fees Coastal Bridge Advisors charges as fixed project-based fee to provide clients with retirement plan consulting services. Each engagement is individually negotiated and tailored to accommodate the needs of the individual plan sponsor, as memorialized in the Agreement. These fees are negotiable and vary based on the scope of the services to be rendered.  Subadvisory Arrangement Coastal Bridge Advisors serves as subadviser for Fergus Reinsurance Limited (“Fergus”) pursuant to a subadvisory agreement with the Fund’s primary adviser, Checchi Capital Advisers, LLC (“Checchi Capital”). Checchi Capital pays Coastal Bridge Advisors a sub-advisory fee that is 50% of the asset management fee earned by Checchi Capital. The Clients who are invested in Fergus are not charged a separate advisory fee by Coastal Bridge Advisors on their assets invested in Fergus, although such clients are responsible for fergus-level fees. See Item 10 for additional information. Fees and Expenses of Investment In addition to Coastal Bridge’s investment management fees, clients are responsible for the fees and expenses associated charged by third parties in connection with the investment of their assets. These fees and expenses could potentially include such as brokerage and other transaction costs, and fees and taxes, related to the purchase and sale of securities for their accounts, and any expenses and charges imposed by broker-dealers and custodians who service client accounts (including but not limited to any custodian fees and account maintenance fees). Clients are additionally responsible for the fees and expenses of externally managed investments, such as those managed by External Managers, and of private investment funds, mutual funds and exchange traded funds. Such fees, expenses, commissions and charges are exclusive of and in addition to our fee. Coastal Bridge Advisors’ Agreement and the separate agreement with any Financial Institutions can authorize Coastal Bridge Advisors or External Managers to debit the client’s account for the amount of Coastal Bridge Advisors’ fee and to directly remit that management fee to Coastal Bridge Advisors or the External Managers. Any Financial Institutions recommended by Coastal Bridge Advisors have agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to Coastal Bridge Advisors. Fees for Management During Partial Quarters of Service For the initial period of investment management services, the fees are calculated on a pro rata basis. The Agreement between Coastal Bridge Advisors and the client will continue in effect until terminated by either party pursuant to the terms of the Agreement. Coastal Bridge Advisors’ fees are prorated through the date of termination and any remaining balance is charged or refunded to the client, as appropriate. As noted above, we invest certain of our clients’ assets in SMA strategies managed by Alley Company. We do not receive any compensation from Alley Company in connection with the investment of our clients’ assets in the SMA strategies managed by Alley Company. However, Alley Company is compensated for the investment advisory services it provides in the management of the SMA strategies in addition to our advisory fee. The allocation of our client assets to Alley Company for SMA services, rather than to an unaffiliated investment manager,  increases Alley Company’s compensation and the revenue to Focus LLC relative to a situation in which our clients’ assets are managed by an unaffiliated manger. As a consequence, Focus LLC has a financial incentive to encourage us to invest a portion of our clients’ assets in Alley Company’s SMA strategies. Please see Item 10 of this Brochure for further details. We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”) and Flourish Financial LLC (“Flourish”). Focus Financial Partners, LLC (“Focus”) is a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such third-party financial institutions for serving our clients. The revenue paid to UPTIQ also benefits UPTIQ, Inc.’s investors, including Focus, our parent company. When legally permissible, UPTIQ also shares a portion of this earned revenue with our affiliate, Focus Solutions Holdings, LLC (“FSH”). For securities-backed lines of credit (“SBLOCs”) made to our clients, UPTIQ will share with FSH up to 75% of all revenue it receives from such third- party financial institutions. For other loans (except residential mortgage loans) made to our clients, UPTIQ will share with FSH up to 25% of all revenue it receives from such third-party financial institutions. For cash management products and services provided to our clients, UPTIQ will share with FSH up to 33% of all revenue it receives from the third-party financial institutions and other intermediaries that provide administrative and settlement services in connection with this program. As noted above, Flourish facilitates cash management solutions for our clients. When legally permissible, Flourish pays FSH a revenue share of up to 0.10% of the total amount of cash held in Flourish cash accounts by our clients. Although the amount of these revenue-sharing payments to FSH is not charged directly in the calculation of the interest rate paid by clients on credit solutions facilitated by UPTIQ or the yield earned by clients on cash management solutions facilitated by UPTIQ or Flourish, the compensation earned by UPTIQ and Flourish is an expense of the third-party financial institutions that informs the interest rate paid by clients on credit solutions and the yield earned by clients on cash management solutions. FSH distributes this revenue to us when we are licensed to receive such revenue (or when no such license is required) and the distribution is not otherwise legally prohibited. Further information on this conflict of interest is available in Item 10 of this Brochure. We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. FRS assists our clients with regulated insurance sales activity by advising our clients on insurance matters and placing insurance products for them and/or referring our clients to certain third-party insurance brokers (the “Brokers”), with whom FRS has agreements, which either separately or together with FRS place insurance products for them. If FRS places an insurance product or refers one of our clients to a Broker and there is a subsequent purchase of insurance through the Broker, then FRS will receive a portion of the upfront and/or ongoing commissions associated with the sale by the insurance carrier with which the policy was placed. The amount of revenue earned by FRS for the sale of these insurance products will vary over time in response to market conditions and will also differ based on the type of insurance product sold and which Broker placed the policy. The amount of insurance commission revenue earned by FRS is considered for purposes of determining the amount of additional compensation that certain of our financial professionals are entitled to  receive. Additionally, in exchange for allowing certain of the Brokers to participate in the FRS platform and, thereby, to offer their services to our clients and certain of our affiliates’ clients, FRS receives periodic fees (the “Platform Fees”) from such Brokers. The Platform Fees are expected to change over time. Such Platform Fees are revenue for FRS and, ultimately, for our common parent company, Focus, but we do not share in such revenue. FRS also indirectly benefits from our clients’ use of the services insofar as such use incentivizes the Brokers to maintain their relationship with FRS and to continue paying Platform Fees to FRS, which could also support increases in the overall amount of the Platform Fee rates in the future. Further information on this conflict of interest is available in Item 10 of this Brochure. Item 6 – Performance-Based Fees and Side-by-Side Management Coastal Bridge Advisors does not provide any services for performance-based fees. Performance-based fees are those based on a share of capital gains on or capital appreciation of the assets of a client. Item 7 – Types of Clients Coastal Bridge Advisors primarily provides its services to individuals, including high net worth individuals, and families. However, Coastal Bridge Advisors also provides services to trusts, estates, charitable organizations, insurance companies, corporations and business entities, family offices, charitable foundations, ERISA plans, and retirement/profit-sharing plans.. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis & Investment Strategies A primary step in Coastal Bridge Advisors’s investment strategy is getting to know the clients – to understand their financial condition, risk profile, investment goals, tax situation, and liquidity constraints, among other things – in order to assemble a complete picture of their financial situation. To aid in this understanding, Coastal Bridge Advisors offers clients financial planning that is highly customized and tailored. Coastal Bridge Advisors primarily employs fundamental analysis methods in developing investment strategies for its clients. Research and analysis from Coastal Bridge Advisors is based on numerous sources, including third-party research materials and publicly-available materials, such as company annual reports, prospectuses, and press releases. Coastal Bridge Advisors seeks to employ investment strategies that are consistent with clients’ financial goals. Coastal Bridge Advisors will typically hold all or a portion of a securities position for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of clients. At times, the Firm may also buy and sell positions that are more short-term in nature, depending on the goals of the client and/or the fundamentals of the security, sector, or asset class. Coastal Bridge Advisors’s investment personnel select assets and products from across many asset classes. Client assets are invested in global and domestic equities, taxable and non-  taxable fixed income, mutual funds, and exchange traded funds (“ETFs”). External Managers often manage portions of clients’ investment portfolios. In some circumstances, Coastal Bridge Advisors will conduct an in-depth planning process which takes into consideration, among other things, cash flow analysis, retirement, education, business planning, investments, insurance, and the tax needs of the client. Coastal Bridge Advisors conducts an extensive planning process which includes both qualitative and quantitative analysis of the client’s current position and future goals. In the Firm’s sole discretion and upon the completion of the planning process, Coastal Bridge Advisors will sometimes conduct a “stress test” of its recommended allocations using Monte Carlo Analysis. The Firm will then construct portfolios using what it believes to be the most appropriate for the client under the circumstances. Coastal Bridge will, when deemed appropriate, allocate client assets to Independent Managers Coastal Bridge has determined are appropriate for the portfolios and then monitor and review the client’s account performance and investment objectives. Risks of Loss Investing in securities involves a risk of loss. A client can lose all or a substantial portion of his/her investment. A client should be willing to bear such a loss. Some investments are intended only for sophisticated investors and can involve a high degree of risk. Coastal Bridge Advisors provides close consultation and consideration of its clients’ goals and risk tolerance before reaching a mutual decision with the client on how best to seek to build and preserve their wealth. Coastal Bridge Advisors follows a rigorous and disciplined process and seeks to leverage high-quality investment products and providers to create a diversified portfolio aimed at meeting its clients’ objectives. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. As such, a fund investor can incur substantial tax liabilities even when the fund underperforms. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares can differ significantly from the NAV during periods of market volatility, which can, among other factors, lead to the mutual fund’s shares trading at a premium or discount to NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the  secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed-based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies can cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Use of External Managers For clients , Coastal Bridge Advisors may recommend the use of External Managers. Coastal Bridge Advisors will conduct due diligence of such managers, but such recommendations rely, to a great extent, on the External Managers ability to successfully implement their investment strategy. In addition, Coastal Bridge Advisors generally does not have the ability to supervise the External Managers on a day-to-day basis. Use of Private Collective Investment Vehicles Coastal Bridge Advisors can recommend the investment by certain clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, in privately placed collective investment vehicles (some of which are called “hedge funds”). These privately placed collective investment vehicles include, but are not limited to, the Manifest Fund. The managers of these vehicles will have broad discretion in selecting the investments. There are few limitations on the types of securities or other financial instruments which can be traded and no requirement to diversify. The hedge funds can trade on margin or otherwise leverage positions, thereby potentially increasing the risk to the vehicle. In addition, because the vehicles are not registered as investment companies, there is an absence of regulation. There are numerous other risks in investing in these securities. The client will receive a private placement memorandum and/or other documents explaining such risks. Cybersecurity The computer systems, networks and devices used by Coastal Bridge Advisors and service providers to the Firm and its clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. Cybersecurity breaches may cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by the Firm and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well as the inadvertent release of confidential  information. Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers, and other financial institutions; and other parties. In addition, substantial costs may be incurred by these entities in order to prevent any cybersecurity breaches in the future. General Risk of Loss Investing in securities involves the risk of loss. Clients should be prepared to bear such loss. Item 9 – Disciplinary Information Coastal Bridge Advisors is required to disclose the facts of any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of management. Coastal Bridge Advisors does not have any required disclosures to this Item. Item 10 – Other Financial Industry Activities and Affiliations Coastal Bridge Advisors is required to disclose any relationship or arrangement that is material to its advisory business or to its clients with certain related persons. Coastal Bridge Advisors has described such relationships and arrangements below. Focus Financial Partners As noted above in response to Item 4, certain investment vehicles affiliated with CD&R collectively are indirect majority owners of Focus LLC, and certain investment vehicles affiliated with Stone Point are indirect owners of Focus LLC. Because Coastal Bridge Advisors is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Coastal Bridge Advisors. Receipt of Insurance Commission Certain of Coastal Bridge Advisors’ Supervised Persons, in their individual capacities, are licensed insurance agents with various insurance companies, and in such capacity, can recommend, on a fully- disclosed basis, the purchase of certain insurance products. A conflict of interest exists to the extent that Coastal Bridge Advisors or its Supervised Persons recommend the purchase of insurance products where Coastal Bridge Advisors or its Supervised Persons receive insurance commissions or other additional compensation. Focus Risk Solutions We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC (“Focus”). FRS assists our clients with regulated insurance sales activity by advising our clients on insurance matters and placing insurance products for them and/or referring our clients to  certain third-party insurance brokers (the “Brokers”), with whom FRS has agreements, which either separately or together with FRS place insurance products for them. If FRS places an insurance product or refers one of our clients to a Broker and there is a subsequent purchase of insurance through the Broker, then FRS will receive a portion of the upfront and/or ongoing commissions associated with the sale by the insurance carrier with which the policy was placed. The amount of revenue earned by FRS for the sale of these insurance products will vary over time in response to market conditions and will also differ based on the type of insurance product sold and which Broker placed the policy. The amount of insurance commission revenue earned by FRS is considered for purposes of determining the amount of additional compensation that certain of our financial professionals are entitled to receive. This revenue is also revenue for our and FRS’s common parent company, Focus. Additionally, in exchange for allowing certain of the Brokers to participate in the FRS platform and, thereby, to offer their services to our clients and certain of our affiliates’ clients, FRS receives periodic fees (the “Platform Fees”) from such Brokers. The Platform Fees are expected to change over time. Such Platform Fees are revenue for FRS and, ultimately, for our common parent company, Focus, but we do not share in such revenue. FRS also indirectly benefits from our clients’ use of the services insofar as such use incentivizes the Brokers to maintain their relationship with FRS and to continue paying Platform Fees to FRS, which could also support increases in the overall amount of the Platform Fee rates in the future. Accordingly, we have a conflict of interest when recommending FRS’s services to clients because of the compensation to certain of our financial professionals and to our affiliates, FRS and Focus. We address this conflict by: (1) fully and fairly disclosing the material facts concerning the above arrangements to our clients, including in this Brochure; (2) offering FRS solutions to clients on a strictly nondiscretionary and fully disclosed basis, and not as part of any discretionary investment services; and (3) not sharing in any portion of the Platform Fees. Additionally, we note that clients who use FRS’s services will receive product-specific disclosure from the Brokers and insurance carriers and other unaffiliated third-party intermediaries that provide services to our clients. The insurance premium is ultimately dictated by the insurance carrier, although in some circumstances the Brokers or FRS may have the ability to influence an insurance carrier to lower the premium of the policy. The final rate may be higher or lower than the prevailing market rate, and may be higher than if the policy was purchased directly through the Broker without the assistance of FRS. We can offer no assurances that the rates offered to you by the insurance carrier are the lowest possible rates available in the marketplace. Affiliation with Private Placements Certain principals of Coastal Bridge Advisors, Bill Loftus and Kevin Burns (the “Fund Principals”) are members and executive officers of limited liability companies that act as the general partner (the “Fund General Partner”) of privately placed investment vehicles (the “Funds”), and are members of the management company for the Funds. Therefore, there is a conflict of interest whereby Coastal Bridge Advisors and the Fund Principals have various incentives to recommend that clients invest in the Funds.  The members of the Fund General Partner will be entitled to receive a share of the carried interest distributed to the Fund General Partner by the Fund and borne by its investors. The Fund General Partner are compensated with a carried interest (potentially up to 20% of Fund profits) when certain conditions are met. This profit-sharing interest, coupled with an investment by one or more of the Fund Principals in the Fund General Partner and/or the Funds also creates a general incentive for the Fund Principals to ensure that the Funds raise sufficient capital. Furthermore, the Fund Principals have an added incentive to recommend that Coastal Bridge Advisors clients invest in the Funds because their profit sharing percentages in the Fund General Partner increase as they raise more capital for the Funds. Finally, one of the principals of the Fund General Partner is a client of Coastal Bridge Advisors. This results in a conflict of interest for Coastal Bridge Advisors to favor that client due to this business relationship. Coastal Bridge Advisors will not charge an advisory fee on client assets invested in the Funds. Ultimately, however, the compensation earned by the Fund Principals in connection with investments in the Funds by Coastal Bridge Advisors clients could exceed the advisory fees that clients would have otherwise paid Coastal Bridge Advisors with respect to those assets. The foregoing conflicts of interest disclosures do not represent a complete list of pertinent conflicts of interest and risk factors associated with an investment in the Funds. For additional disclosures, clients should review the Confidential Private Placement Memorandum of the Funds. The Firm has procedures in place whereby it seeks to ensure that all recommendations are made in its clients’ best interest regardless of its affiliation with the Funds. Clients of the Firm will be provided with a separate disclosure that discusses the conflicts of interest when investing in a Fund. Subadvisory Arrangement As noted above, Coastal Bridge Advisors serves as subadviser for Fergus Reinsurance Limited (“Fergus”) pursuant to a subadvisory agreement with the Fund’s primary adviser, Checchi Capital Advisers, LLC (“Checchi Capital”). Checchi Capital pays Coastal Bridge Advisors a sub- advisory fee that is 50% of the fund-level management fee earned by Checchi Capital. The Clients who are invested in Fergus are not charged a separate advisory fee by Coastal Bridge Advisors on their assets invested in Fergus, although such clients are responsible for fund-level fees. The subadviser compensation earned by Coastal Bridge Advisors in connection with investments in Fergus could exceed the advisory fees that clients otherwise would have paid to Coastal Bridge Advisors. This creates conflicts of interest for Coastal Bridge Advisors, because we are financially incentivized to recommend that clients invest in Fergus, instead of other investments. We believe this conflict is mitigated because of the following factors: (1) this arrangement is based on our reasonable belief that investing a portion of clients’ assets in Fergus is in the best interest of the clients; (2) Checchi Capital and the Fergus have met the due diligence and performance standards that we apply to outside, unaffiliated investment managers; (3) clients will invest in Fergus on a nondiscretionary basis through the completion of subscription documentation; (4) subject to redemption restrictions, we are willing and able to reallocate client assets to other unaffiliated or affiliated investment vehicles, in part or in whole, if  Checchi Capital’s services become unsatisfactory in our judgment and at our sole discretion; and (5) we have fully and fairly disclosed the material facts regarding this relationship to clients, including in this Brochure, and clients who invest in Fergus have given their informed consent to those investments. For more information, clients should refer to the applicable offering documents. Personal Lending Coastal Bridge Advisors and/or its Supervised Persons provide personal loans to clients of the Firm and are entitled to receive compensation (in the form of interest) as a result. As a result, a conflict of interest exists to the extent that the Firm has an incentive to prefer clients with debt obligations to the Firm or its Supervised Persons in order to ensure repayment. The Firm has procedures in place whereby it seeks to ensure that investment opportunities are allocated in a fair and equitable manner regardless of such loans. In addition, a conflict of interest exists to the extent that Coastal Bridge Advisors or its Supervised Persons recommend personal loans where Coastal Bridge Advisors or its Supervised Persons receive additional compensation. The Firm has procedures in place whereby it seeks to ensure that all recommendations are made in its clients’ best interest regardless of such additional compensation received. Credit and Cash Management Solutions We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”) and Flourish Financial LLC. These third-party financial institutions are banks and non-banks that offer credit and cash management solutions to our clients, as well as certain other unaffiliated third parties that provide administrative and settlement services to facilitate UPTIQ’s cash management solutions. UPTIQ acts as an intermediary to facilitate our clients’ access to these credit and cash management solutions. Flourish acts as an intermediary to facilitate our clients’ access to cash management solutions. We are a wholly owned subsidiary of Focus Financial Partners, LLC (“Focus”). Focus is a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such third- party financial institutions for serving our clients. The revenue paid to UPTIQ also benefits UPTIQ, Inc.’s investors, including Focus. When legally permissible, UPTIQ also shares a portion of this earned revenue with our affiliate, Focus Solutions Holdings, LLC (“FSH”). For securities-backed lines of credit (“SBLOCs”) made to our clients, UPTIQ will share with FSH up to 75% of all revenue it receives from such third-party financial institutions. For other loans (except residential mortgage loans) made to our clients, UPTIQ will share with FSH up to 25% of all revenue it receives from such third-party financial institutions. For cash management products and services provided to our clients, UPTIQ will share with FSH up to 33% of all revenue it receives from the third-party financial institutions and other intermediaries that provide administrative and settlement services in connection with this program. As noted above, Flourish facilitates cash management solutions for our clients. When legally permissible, Flourish pays FSH a revenue share of up to 0.10% of the total amount of cash held in Flourish cash accounts by our clients. Although the amount of these revenue-sharing payments to FSH is not charged directly in the calculation of the interest rate paid by clients on credit solutions facilitated by UPTIQ or the yield  earned by clients on cash management solutions facilitated by UPTIQ or Flourish, the compensation earned by UPTIQ and Flourish is an expense of the third-party financial institutions that informs the interest rate paid by clients on credit solutions and the yield earned by clients on cash management solutions. FSH distributes this revenue to us when we are licensed to receive such revenue (or when no such license is required) and the distribution is not otherwise legally prohibited. This revenue is also revenue for FSH’s and our common parent company, Focus. Additionally, the volume generated by our clients’ transactions allows Focus to negotiate better terms with UPTIQ and Flourish, which benefits Focus and us. Accordingly, we have a conflict of interest when recommending UPTIQ’s and Flourish’s services to clients because of the compensation to us and to our affiliates, FSH and Focus, and the transaction volume to UPTIQ and Flourish. We mitigate this conflict by: (1) fully and fairly disclosing the material facts concerning the above arrangements to our clients, including in this Brochure; and (2) offering UPTIQ’s and Flourish’s solutions to clients on a strictly nondiscretionary and fully disclosed basis, and not as part of any discretionary investment services. Additionally, we note that clients who use UPTIQ’s and Flourish’s services will receive product-specific disclosures from the third-party financial institutions and other unaffiliated third-party intermediaries that provide services to our clients. We have an additional conflict of interest when we recommend credit solutions to our clients because our interest in continuing to receive investment advisory fees from client accounts gives us a financial incentive to recommend that clients borrow money rather than liquidate some or all of the assets we manage. Credit Solutions Clients retain the right to pledge assets in accounts generally, subject to any restrictions imposed by clients’ custodians. While credit solution programs that we offer facilitate secured loans through third-party financial institutions, clients are free instead to work directly with institutions outside such programs. Because of the limited number of participating third-party financial institutions, clients may be limited in their ability to obtain as favorable loan terms as if the client were to work directly with other banks to negotiate loan terms or obtain other financial arrangements. Clients should also understand that pledging assets in an account to secure a loan involves additional risk and restrictions. A third-party financial institution has the authority to liquidate all or part of the pledged securities at any time, without prior notice to clients and without their consent, to maintain required collateral levels. The third-party financial institution also has the right to call client loans and require repayment within a short period of time; if the client cannot repay the loan within the specified time period, the third-party financial institution will have the right to force the sale of pledged assets to repay those loans. Selling assets to maintain collateral levels or calling loans may result in asset sales and realized losses in a declining market, leading to the permanent loss of capital. These sales also may have adverse tax consequences. Interest payments and any other loan-related fees are borne by clients and are in addition to the advisory fees that clients pay us for managing assets, including assets that are pledged as collateral. The  returns on pledged assets may be less than the account fees and interest paid by the account. Clients should consider carefully and skeptically any recommendation to pursue a more aggressive investment strategy in order to support the cost of borrowing, particularly the risks and costs of any such strategy. More generally, before borrowing funds, a client should carefully review the loan agreement, loan application, and other forms and determine that the loan is consistent with the client’s long-term financial goals and presents risks consistent with the client’s financial circumstances and risk tolerance. We use UPTIQ to facilitate credit solutions for our clients. Cash Management Solutions For cash management programs, certain third-party intermediaries provide administrative and settlement services to our clients. Engaging the third-party financial institutions and other intermediaries to provide cash management solutions does not alter the manner in which we treat cash for billing purposes. Clients should understand that in rare circumstances, depending on interest rates and other economic and market factors, the yields on cash management solutions could be lower than the aggregate fees and expenses charged by the third-party financial institutions, the intermediaries referenced above, and us. Consequently, in these rare circumstances, a client could experience a negative overall investment return with respect to those cash investments. Nonetheless, it might still be reasonable for a client to participate in a cash management program if the client prefers to hold cash at the third-party financial institutions rather than at other financial institutions (e.g., to take advantage of FDIC insurance). We use Flourish to facilitate cash management solutions for our clients. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Coastal Bridge Advisors and persons associated with Coastal Bridge Advisors (“Associated Persons”) are permitted to buy or sell securities that it also recommends to clients consistent with Coastal Bridge Advisors’ policies and procedures. Coastal Bridge Advisors has adopted a code of ethics that sets forth the standards of conduct expected of its Associated Persons and requires compliance with applicable securities laws (“Code of Ethics”). In accordance with Section 204A of the Investment Advisers Act of 1940 (the “Advisers Act”), its Code of Ethics contains written policies reasonably designed to prevent the unlawful use of material non-public information by Coastal Bridge Advisors or any of its Associated Persons. The Code of Ethics also requires that certain of Coastal Bridge Advisors’ personnel (called “Access Persons”) report their personal securities holdings and transactions and obtain pre-approval of certain investments such as initial public offerings and limited offerings. Unless specifically permitted in Coastal Bridge Advisors’ Code of Ethics, none of Coastal Bridge Advisors’ Access Persons may effect for themselves or for their immediate family (i.e., spouse, minor children, and adults living in the same household as the Access Person) any transactions  in a security which is being actively purchased or sold, or is being considered for purchase or sale, on behalf of any of Coastal Bridge Advisors’ clients. When Coastal Bridge Advisors is purchasing or considering for purchase any security on behalf of a client, no Access Person may effect a transaction in that security prior to the completion of the purchase or until a decision has been made not to purchase such security. Similarly, when Coastal Bridge Advisors is selling or considering the sale of any security on behalf of a client, no Access Person may effect a transaction in that security prior to the completion of the sale or until a decision has been made not to sell such security. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds. Clients and prospective clients can contact Coastal Bridge Advisors to request a copy of its Code of Ethics. Item 12 – Brokerage Practices As discussed above, in Item 5, Coastal Bridge Advisors generally recommends that clients utilize the brokerage and clearing services of Pershing, BNY, Fidelity and Charles Schwab. In addition, the Firm will recommend that certain non-US clients, as well as high net worth US clients with interests in foreign entities (e.g., trusts, limited liability companies, and partnerships), utilize Cidel as custodian. Factors which Coastal Bridge Advisors considers in recommending Pershing, BNY, Fidelity, Charles Schwab and Cidel or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. Pershing, Fidelity, and Charles Schwab enable Coastal Bridge Advisors to obtain many mutual funds without transaction charges and other securities at nominal transaction charges. The commissions and/or transaction fees charged by Pershing and Fidelity may be higher or lower than those charged by other Financial Institutions. The commissions paid by Coastal Bridge Advisors’ clients comply with Coastal Bridge Advisors’ duty to obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the same transaction where Coastal Bridge Advisors determines that the commissions are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s services, including among others, the value of research provided, execution capability, commission rates, and responsiveness. Coastal Bridge Advisors seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. Transactions can be cleared through other Financial Institutions with whom Coastal Bridge  Advisors and the Financial Institutions have entered into agreements for prime brokerage clearing services. Coastal Bridge Advisors periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. The client can direct Coastal Bridge Advisors in writing to use a particular Financial Institution to execute some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the account with that Financial Institution, and Coastal Bridge Advisors will not seek better execution services or prices from other Financial Institutions or be able to “batch” client transactions for execution through other Financial Institutions with orders for other accounts managed by Coastal Bridge Advisors (as described below). As a result, the client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, Coastal Bridge Advisors can decline a client’s request to direct brokerage if, in Coastal Bridge Advisors’ sole discretion, such directed brokerage arrangements would result in additional operational difficulties or violate restrictions imposed by other broker-dealers (as further discussed below). Transactions for each client generally will be effected independently, unless Coastal Bridge Advisors decides to purchase or sell the same securities for several clients at approximately the same time. Coastal Bridge Advisors 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 Coastal Bridge Advisors’ 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 generally be averaged as to price and allocated among Coastal Bridge Advisors’ clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that Coastal Bridge Advisors determines to aggregate client orders for the purchase or sale of securities, including securities in which Coastal Bridge Advisors’ Supervised Persons may invest, Coastal Bridge Advisors generally does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. Coastal Bridge Advisors does not receive any additional compensation or remuneration as a result of the aggregation. In the event that Coastal Bridge Advisors determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which may include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, Coastal Bridge Advisors may exclude the account(s) from the allocation; the  transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Consistent with obtaining best execution, brokerage transactions can be directed to certain broker-dealers in return for investment research products and/or services which assist Coastal Bridge Advisors in its investment decision-making process. Such research generally will be used to service all of Coastal Bridge Advisors’ clients, but brokerage commissions paid by one client may be used to pay for research that is not used in managing that client’s portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because Coastal Bridge Advisors does not have to produce or pay for the products or services. Software and Support Provided by Financial Institutions Coastal Bridge Advisors receives from Pershing, Fidelity and Charles Schwab, without cost to Coastal Bridge Advisors, computer software and related systems support, which allow Coastal Bridge Advisors to better monitor client accounts maintained at Pershing, Fidelity, and Charles Schwab. Coastal Bridge Advisors receives the software and related support without cost because Coastal Bridge Advisors renders investment management services to clients that maintain assets at Pershing, Fidelity and Charles Schwab. The software and related systems support may benefit Coastal Bridge Advisors, but not its clients directly. In fulfilling its duties to its clients, Coastal Bridge Advisors endeavors at all times to put the interests of its clients first. Clients should be aware, however, that Coastal Bridge Advisors’ receipt of economic benefits from a broker-dealer creates a conflict of interest since these benefits can influence Coastal Bridge Advisors’ choice of broker-dealer over another broker- dealer that does not furnish similar software, systems support, or services. Additionally, Coastal Bridge Advisors receives the following benefits from Pershing, Fidelity and Charles Schwab: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk that exclusively services their institutional platform 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. Coastal Bridge Advisors also receives other economic benefits in the form of educational conferences and meetings and related materials sponsored by various mutual funds, insurance and annuity companies and other vendors. Coastal Bridge Advisors may also receive monetary support for technological, marketing and advertising needs from these entities which may be used towards Coastal Bridge Advisors’ own client events. Clients are advised that a conflict of interest exists to the extent Coastal Bridge Advisors recommends products of these mutual fund families, insurance annuity companies or other vendors. However, the client is under no obligation to purchase these products, and Coastal Bridge Advisors shall not receive any other form of compensation from the mutual fund families, annuity companies or vendors for these events other than as set forth herein.  Item 13 – Review of Accounts For those clients to whom Coastal Bridge Advisors provides investment management services, Coastal Bridge Advisors monitors those portfolios as part of an ongoing process while regular account reviews are conducted on at least an annual basis. For those clients to whom Coastal Bridge Advisors provides financial planning and/or consulting services, reviews are conducted on an “as needed” basis. Such reviews are conducted by one of Coastal Bridge Advisors’ investment adviser representatives. All investment advisory clients are encouraged to discuss their needs, goals, and objectives with Coastal Bridge Advisors and to keep Coastal Bridge Advisors informed of any changes thereto. Coastal Bridge Advisors contacts ongoing investment advisory clients at least annually to review its previous services and/or recommendations and to discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives. Unless otherwise agreed upon, clients are provided with transaction confirmation notices and regular summary account statements directly from the broker-dealer or custodian for the client accounts. Those clients to whom Coastal Bridge Advisors provides investment advisory services may also receive a report from Coastal Bridge Advisors that may include such relevant account and/or market-related information such as an inventory of account holdings and account performance on a periodic basis. Clients should compare the account statements they receive from their custodian with those they receive from Coastal Bridge Advisors. Those clients to whom Coastal Bridge Advisors provides financial planning and/or consulting services will receive reports from Coastal Bridge Advisors summarizing its analysis and conclusions as requested by the client or otherwise agreed to in writing by Coastal Bridge Advisors. Item 14 – Client Referrals and Other Compensation Coastal Bridge Advisors receives economic benefits from non-clients for providing advice or other advisory services to clients. Coastal Bridge Advisors has described such relationships and arrangements below. Client Referrals to Coastal Bridge The firm has arrangements in place with certain third parties, called promoters, under which such promoters refer clients to us in exchange for a percentage of the advisory fees we collect from such referred clients. Such compensation creates an incentive for the promoters to refer clients to us, which is a conflict of interest for the promoters. Rule 206(4)-1 of the Advisers Act addresses this conflict of interest by, among other things, requiring disclosure of whether the promoter is a client or a non-client and a description of the material conflicts of interest and material terms of the compensation arrangement with the promoter. Accordingly, we require promoters to disclose to referred clients, in writing: whether the promoter is a client or a non-client; that the promoter will be compensated for the referral; the material conflicts of interest arising from the relationship and/or compensation arrangement; and the material terms of the compensation arrangement, including a description of the compensation to be provided for the referral.  Other Compensation The Firm receives economic benefits from Pershing and Fidelity. The benefits, conflicts of interest and how they are addressed are discussed above in response to Item 12 Sponsorship Disclosure The Firm’s parent company is Focus Financial Partners, LLC (“Focus”). From time to time, Focus holds partnership meetings and other industry and best-practices conferences, which typically include Coastal Bridge Advisors, other Focus firms and external attendees. These meetings are first and foremost intended to provide training or education to personnel of Focus firms, including Coastal Bridge Advisors. However, the meetings do provide sponsorship opportunities for asset managers, asset custodians, vendors and other third-party service providers. Sponsorship fees allow these companies to advertise their products and services to Focus firms, including Coastal Bridge Advisors. Although the participation of Focus firm personnel in these meetings is not preconditioned on the achievement of a sales target for any conference sponsor, this practice could nonetheless be deemed a conflict as the marketing and education activities conducted, and the access granted, at such meetings and conferences could cause Coastal Bridge Advisors to focus on those conference sponsors in the course of its duties. Focus attempts to mitigate any such conflict by allocating the sponsorship fees only to defraying the cost of the meeting or future meetings and not as revenue for itself or any affiliate, including Coastal Bridge Advisors. Conference sponsorship fees are not dependent on assets placed with any specific provider or revenue generated by such asset placement. The following entities have provided conference sponsorship to Focus from January 1, 2024 to February 1, 2025: • Advent Software, Inc. (includes SS&C) • BlackRock, Inc. • Blackstone Administrative Services Partnership L.P. • Capital Integration Systems LLC (CAIS) • Charles Schwab & Co., Inc. • Confluence Technologies Inc. • Eaton Vance Distributors, Inc. (includes Parametric Portfolio Associates) • Fidelity Brokerage Services LLC and Fidelity Distributors Company LLC (includes Fidelity Institutional Asset Management and FIAM) • Flourish Financial LLC • Franklin Distributors, LLC (includes O’Shaughnessy Asset Management, L.L.C. (OSAM) and CANVAS) • K&L Gates LLP • Nuveen Securities, LLC • Orion Advisor Technology, LLC • Pinegrove Capital Partners LLC (includes Brookfield Oaktree Wealth Solutions) • Practifi, Inc. • Salus GRC, LLC • Stone Ridge Asset Management LLC  • The Vanguard Group, Inc. • TriState Capital Bank • UPTIQ, Inc. You can access updates to the list of conference sponsors on Focus’ website through the following link: https://www.focusfinancialpartners.com/conference-sponsors Expense Reimbursement from Sponsors and Distributors of Investment Products Coastal Bridge Advisors may receive expense reimbursement for travel from sponsors and distributors of investment products. Travel expense reimbursements typically result from Coastal Bridge Advisors’ Supervised Persons travel to conduct due diligence of investments or to attend training events hosted by sponsors and distributors of investment products. Receipt of such expense reimbursement for travel poses a conflict of interest, as it creates an incentive for the Firm to recommend the investments of those sponsors and distributors that offer this benefit. Travel reimbursements are not dependent on assets placed with any specific provider or the revenue generated by asset placement. Further, Coastal Bridge Advisors will only recommend such investments if they are in the best interests of the relevant client. Item 15 – Custody Coastal Bridge Advisors’ Agreement and/or the separate agreement with any Financial Institution may authorize Coastal Bridge Advisors through such Financial Institution to debit the client’s account for the amount of Coastal Bridge Advisors’ fee and to directly remit that management fee to Coastal Bridge Advisors in accordance with applicable custody rules. The Financial Institutions recommended by Coastal Bridge Advisors have agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to Coastal Bridge Advisors. In addition, as discussed in Item 13, Coastal Bridge Advisors also sends periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and compare them to those received from Coastal Bridge Advisors. Surprise Independent Examination As Coastal Bridge Advisors is deemed to have custody over clients’ cash, bank accounts or securities (for reasons other than those discussed above), the Firm is required to engage an independent accounting Firm to perform a surprise annual examination of those assets and accounts over which it maintains custody. Any related opinions issued by an independent accounting Firm are filed with the SEC and are publicly available on the SEC’s Investment Adviser Public Disclosure website. Coastal Bridge Advisors does not have direct access to client funds as they are maintained with an independent qualified custodian. Standing Letters of Authorization Coastal Bridge Advisors also has custody due to clients giving the Firm limited power of attorney in a standing letter of authorization (“SLOA”) to disburse funds to one or more third parties as specifically designated by the client. In such circumstances, the Firm will implement the steps in the SEC’s no-action letter on February 21, 2017 which includes (in summary): i) client will provide instruction for the SLOA to the custodian; ii) client will authorize the Firm  to direct transfers to the specific third party; iii) the custodian will perform appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after each transfer; iv) the client will have the ability to terminate or change the instruction; v) the Firm will have no authority or ability to designate or change the identity or any information about the third party; vi) the Firm will keep records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and vii) the custodian will send the client an initial and annual notice confirming the SLOA instructions. Item 16 – Investment Discretion Coastal Bridge Advisors is generally given the authority to exercise discretion on behalf of clients. Coastal Bridge Advisors is considered to exercise investment discretion over a client’s account if it can effect transactions for the client without first having to seek the client’s consent. Coastal Bridge Advisors is given this authority through a power-of-attorney included in the Agreement between Coastal Bridge Advisors and the client. Clients can request a limitation on this authority (such as requesting that certain securities not to be bought or sold). Coastal Bridge Advisors takes discretion over the following activities: • The securities to be purchased or sold; • The amount of securities to be purchased or sold; • When transactions are made; • The Financial Institutions to be utilized; and • The External Managers to be hired or fired. Item 17 – Voting Client Securities Coastal Bridge Advisors has in the past accepted the authority to vote securities (i.e., proxies) on the behalf of certain clients, but does not intend to do so with new clients and is amending current agreements so that proxy voting authority is retained by clients. When Coastal Bridge Advisors does vote client proxies pursuant to accepted proxy voting authority, it will cast proxy votes only in a manner it believes consistent with the best interest of its clients. At any time clients can contact the Firm to request information about how Coastal Bridge Advisors voted proxies for that client’s securities. A brief summary of Coastal Bridge Advisors’ proxy voting policies and procedures is as follows: • The Firm has engaged Broadridge Financial Services, Inc. (“Broadridge”), a third- party, independent proxy advisory firm, to provide it with research, analysis, and recommendations on the various proxy proposals for the client securities that Coastal Bridge Advisors manages with the aim of maximizing shareholder value. • In engaging Broadridge for that purpose, Coastal Bridge Advisors has reviewed Broadridge’s guidelines proxy voting. Coastal Bridge Advisors will  continue to review Broadridge’s proxy voting services to ensure that proxies are being voted in the best interest of clients. Where Coastal Bridge Advisors is responsible for voting proxies on behalf of a client, the client cannot direct the Firm’s vote on a particular solicitation. The client, however, can revoke Coastal Bridge Advisors’ authority to vote proxies. In situations where there is a conflict of interest in the voting of proxies due to business or personal relationships that Coastal Bridge Advisors maintains with persons having an interest in the outcome of certain votes, the Firm will take appropriate steps, whether by following Broadridge’s third-party recommendation or otherwise, to ensure that proxy voting decisions are made in what it believes is the best interest of its clients and are not the product of any such conflict. Item 18 – Financial Information Coastal Bridge Advisors does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance. In addition, Coastal Bridge Advisors is required to disclose any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. Coastal Bridge Advisors has no disclosures pursuant to this Item.