CAPFINANCIAL PARTNERS, LLC

Item 1: Cover Page March 18, 2025 CAPTRUST Financial Advisors 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 Firm CRD #175112 Phone: 919.870.6822 Toll Free: 800.216.0645 www.captrust.com This Form ADV Part 2A is the CAPTRUST Wealth Client Brochure (“Brochure” or “Wealth Brochure”), the disclosure brochure for wealth clients and other non-institutional clients utilizing CAPTRUST investment advisory and portfolio management services. If you have any questions about the contents of this Brochure, please contact us by phone at 919.870.6822 or toll-free at 800.216.0645 or by email at compliance@captrust.com. 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. CAPTRUST Financial Advisors is an investment adviser registered under the Investment Advisers Act of 1940. Registration does not imply any level of skill or training. Additional information about CAPTRUST Financial Advisors also is available on the SEC’s website at www.adviserinfo.sec.gov. 1 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 2: Summary of Material Changes This Summary of Material Changes reflects only material changes to this Brochure since our last annual update of this Brochure which was dated March 28, 2024. A full copy of our Brochure may be requested by email at compliance@captrust.com or by contacting us toll- free at 800.216.0645. Item 10 - Other Financial Industry Activities and Affiliations Item 10 has been amended to disclose the following acquisition activity: In the fourth quarter of 2024, CFG acquired the assets of four different firms: Campbell Wealth Management (CRD #152956) in Alexandria, VA, TruNorth Wealth Partners (CRD #284807) in St. Paul, MN, Wealth Covenant Group (CRD #291453) in Houston, TX., and Boston Financial Management (CRD #112360) (“BFM”) with offices in Boston, MA, Centerville, MA, and Portland, ME. CFG also acquired BFM’s wholly-owned subsidiary, Boston Fiduciary Services, LLC, which provides professional trustee and fiduciary services to individuals, businesses, and non-profit organizations. 2 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 3: Table of Contents Item 1: Cover Page .......................................................................................................................................................... 1 Item 2: Summary of 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 ......................................................... 10 Item 7: Types of Clients .............................................................................................................................................. 11 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 11 Item 9: Disciplinary Information ............................................................................................................................. 13 Item 10: Other Financial Industry Activities and Affiliations ..................................................................... 13 Item 11: Code of Ethics ............................................................................................................................................... 15 Item 12: Brokerage Practices ................................................................................................................................... 16 Item 13: Review of Accounts ................................................................................................................................... 19 Item 14: Client Referrals and Other Compensation ...................................................................................... 20 Item 15: Custody .......................................................................................................................................................... 22 Item 16: Investment Discretion .............................................................................................................................. 22 Item 17: Voting Client Securities ........................................................................................................................... 23 Item 18: Financial Information ................................................................................................................................ 24 3 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 4: Advisory Business Introduction CAPTRUST Financial Advisors, also known as CapFinancial Partners, LLC, (“CAPTRUST” or “Adviser”) was established in April 2003 and approved as a registered investment adviser in September 2003. The CapFinancial Group, LLC (“CFG”, a North Carolina limited liability company) owns just under 100% of CAPTRUST. Each of CapFinancial Holdings, Inc. and Halftime Holdings, LLC owns more than 25% of The CapFinancial Group, LLC. GTCR Fund XII B indirectly owns more than 25% of CAPTRUST through its ownership of Halftime Holdings, LLC. CAPTRUST provides investment advisory services to wealth management clients including, but not limited to, individuals, trusts, estates, charitable organizations, foundations, endowments, and corporations (each, a “Client” or “Wealth Client”). CAPTRUST renders continuous and regular investment supervisory services to Clients. CAPTRUST also provides investment advisory services to institutional clients including, but not limited to, retirement plan sponsors, 401(k) plans, 403(b) plans, pensions, profit-sharing plans, non-qualified plans; endowments and foundations; religious organization; and other asset pools (each, an “Institutional Client”). These services are disclosed separately (please see CAPTRUST Institutional Brochure which can be found here: https://www.captrust.com/important-disclosures/). As of December 31, 2024, CAPTRUST managed a total of just under $1.1 trillion in total assets under management, comprised of just over $845 billion in nondiscretionary assets under advisement (primarily Institutional Client assets) and just over $237 billion in discretionary assets under advisement (Institutional and Wealth Client assets). CAPTRUST offers the following services to Clients: Investment Advisory Services  Establishment of Investment Goals and Objectives  Asset Allocation Analysis  Investment Manager Selection / Mutual Fund Evaluation  Ongoing Investment Manager / Mutual Fund Due Diligence  Ongoing Portfolio Performance Measurement  Periodic Review of Client Investment Accounts Compared to Client’s Investment Goals and Objectives 4 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Wealth Planning Services  Discuss Financial Priorities and Identify Wealth Planning Goals  Develop and Implement Financial Planning Recommendations  Monitor Progress Towards Goals and Reevaluate them Periodically  Evaluate Estate Planning Needs  Tax Planning  Charitable Planning  Coordinate Wealth Planning Objectives with Other Professional Advisors Tax Related Services, Family Office, and Other Ancillary Services  Tax Consulting and Planning  Tax Return Preparation  Bill Pay and Bookkeeping Investment Supervisory Services Adviser provides investment supervisory services on a discretionary and non-discretionary basis including, but not limited to the following:  Adviser designs, revises, and reallocates a Client’s custom portfolios. Investments are determined based upon the Client’s investment objectives, risk tolerance, net worth, net income, age, time horizon, tax situation, and other suitability factors.  Adviser manages the Client’s custom accounts on an individualized basis. Restrictions and guidelines imposed by Clients may affect the composition and performance of custom portfolios (as a result, performance of custom portfolios within the same investment objective may differ and Clients should not expect that the performance of their custom portfolios will be identical to any other individual’s portfolio performance).  Adviser uses the services of sub-advisers and established third party research services to assist Adviser with formulating asset allocation, industry and sector selection, and individual security investment recommendations in constructing and maintaining custom portfolios. Adviser’s Clients enter into a fee-based agreement for investment supervisory services. Advisory fees stated in CAPTRUST’s fee-based agreements may or may not include the cost of transactions/trade executions, depending upon the type of account the client chooses and whether the fee is negotiated on “wrap fee” or “non-wrap fee” basis. Advisory Fees may be higher or lower than obtainable elsewhere. Wrap Fee Accounts CAPTRUST sponsors wrap fee program services (see “CAPTRUST Wrap Fee Programs Brochure” at Appendix 1 to this Brochure for a complete description of the wrap fee programs offered through CAPTRUST). Wrap fee programs are designed to help Clients identify their investment needs and obtain professional asset management for a convenient single "wrap" fee that includes both the cost of transactions/executions and investment 5 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  advisory fees. Wrap fee programs may be offered through portfolio management account (“PMA”) services, in which CAPTRUST provides PMA services, or separately managed account (“SMA”) services, in which CAPTRUST recommends and the Client selects a third- party manager. An investor should consider all the information within the CAPTRUST Wrap Fee Programs Brochure before participating in a wrap fee program. The information in the CAPTRUST Wrap Fee Programs Brochure has not been approved or verified by any governmental authority. CAPTRUST sponsored wrap free programs include programs with accounts held at Pershing, LLC (“Pershing”). CAPTRUST also participates in wrap fee programs sponsored by the Schwab Advisor Services division of Charles Schwab & Co. Inc. (“Schwab”), i.e., Schwab’s Managed Account Select and Managed Account Access. SMA Accounts CAPTRUST performs due diligence on various independent investment managers. Based on the Client's individual circumstances, CAPTRUST determines which SMA manager's portfolio management style is appropriate for that Client. Factors considered in making this determination include account size, risk tolerance, the objectives of each Client and the investment philosophy of the selected manager. Clients should refer to their SMA manager's disclosure brochure or other disclosure documents for a full description of the services offered. CAPTRUST will furnish a copy of the disclosure brochures for each SMA manager recommended. CAPTRUST may recommend one or more SMA managers to manage a Client's assets on a discretionary basis. CAPTRUST monitors the performance of the SMA managers on an ongoing basis. Some Clients with their accounts at Schwab have accessed SMA managers though Schwab’s Managed Account Marketplace (which is not a wrap-fee program). These Schwab programs allow access to independent SMA investment management firms offered by Schwab. With the exception of CAPTRUST’s SMA Wrap Fee Program, CAPTRUST’s fee is independent of the fee charged by SMA managers for the management of separate accounts. Fees associated with SMA managers vary and are separately disclosed in each manager’s disclosure brochure and, depending on the SMA program chosen by the client, may or may not include the cost of execution. CAPTRUST will make its recommendations in the best interest of the Client, taking into account the Client’s preferences. Schwab SMA Programs Schwab’s Managed Account Select and Managed Account Access fees are bundled as a single, all-inclusive wrap fee, which is in addition to the fee charged by CAPTRUST. For Clients who have chosen one of these programs, CAPTRUST will deliver Schwab’s brochure, which explains how Schwab calculates their SMA program fees. Generally, Schwab multiplies the actual daily balance of the Client’s account by the daily pro rata portion of the annual rate and then adds together the fees for each day of the month. The program fee is billed to the Client’s account monthly, which may result in Clients paying a higher fee on an annual basis than the annual rate due to the effects of compounding. 6 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Managed accounts established under the Schwab’s Managed Account Marketplace (non-wrap fee accounts) are charged separately by Schwab for brokerage and custody services and by the SMA manager under the SMA manager’s advisory agreement. In general, access to managers in Schwab’s programs is available at the following account levels: $100,000 for Stock/Equity Managers and $250,000 for Bond/Fixed Income Managers. Although some money managers may have higher account minimums. Schwab’s program fees include the institutional money manager fee, Schwab’s program fee and fees for brokerage/clearing/custodial services. Fees may include a minimum monthly fee. Please see related program documents for a complete description of specific fees. Depending on the service utilized, program fees for the SMA services may be up to 3.00%, depending on the services provided. Subadvisory Agreements CAPTRUST occasionally establishes a subadvisory agreement with an SMA manager that may or may not participate in one or more of the programs described in this section. Under this type of arrangement, CAPTRUST’s fee can be quoted to include or exclude the subadvisor’s fee. In this way, Clients can decide whether to permit the subadvisor to charge their fee directly to the Client’s account or to have CAPTRUST combine their fee to include the subadvisor’s fee. Either way, the advisory agreement governing the relationship describes the method by which advisory fees will be charged and paid and whether the quoted fee includes both CAPTRUST’s fee and subadvisory fees. Other Investment Advisor Services CAPTRUST provides investment advisory services that do not involve investment supervisory services on a discretionary or non-discretionary basis. Consultations. Adviser furnishes investment advice through individual consultations. To the extent it is requested to do so, Adviser provides Clients with investment advisory and consultation services on a “fee for service” basis. In order to determine a suitable course of action for an individual Client, Adviser performs a review of the variables that are presented. Such review may include, but would not necessarily be limited to, investment objectives, consideration of the Client’s overall financial condition, income and tax status, personal and business assets, risk profile, and other factors unique to the Client’s particular circumstances. Adviser obtains pertinent information from the Client to assist Adviser in determining the most appropriate course of action for its Client’s financial and investment activity. Alternative Investments. Adviser offers advice on private placements and/or limited partnerships that are considered “alternative investments.” Adviser also offers advice on private equity funds that contain investments in equities, futures, options, and other securities. Any such recommendation will be made only when determined to be suitable and must be accompanied by or preceded by a prospectus or offering memorandum. See Item 10 below for a detailed description of material conflicts regarding private funds. 7 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 5: Fees and Compensation Advisory Fees As noted above, CAPTRUST advisory fees are typically charged quarterly in advance based on the market value of the Client’s account on the last business day of the previous calendar quarter. Clients who have assigned their advisory agreements to CAPTRUST in connection with an acquisition may pay their advisory fees in arrears. In either case, the terms of the advisory agreement determine the fee arrangements. Additions to and withdrawals from an account during a quarter will be reflected in a fee adjustment in the following quarter’s client statement. Fees generally are deducted from the Client’s account or may be direct billed to the Client or to a third-party custodian at the Client’s instruction. Some client portfolios include private equity and/or other private investments for which quarterly values lag for up to 60 days following a quarter-end. In those limited cases, CAPTRUST uses the latest valuation date available for purposes of computing investment advisory fees. CAPTRUST relies on the Client’s capital account statement (provided by the issuer or qualified custodian) for the values of such private investments. The advisory agreement continues in effect until terminated by either party upon thirty days written notice to the other party. However, if the Client has not received this Brochure at least 48 hours prior to entering into the advisory agreement, the Client may terminate the advisory agreement within five business days of entering into the advisory agreement without penalty. If any advisory relationship terminates before the last day of a quarter, fees are prorated accordingly, and the Adviser will refund any unearned fees due to the Client. Fees, minimum account sizes, and services are negotiable and may be waived under certain circumstances. For example, Adviser, in its sole discretion, may charge a lesser (or no) advisory fee based upon certain criteria (e.g., existing financial planning client relationship, anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with Client). Adviser’s fees for these services are negotiable depending on the specific type of investment management services to be rendered (as detailed in the advisory agreement), but generally will be calculated as a percentage of total assets under management according to the following schedule: Gross Market Value 0-$500,000 $500,001 – $1,000,000 $1,000,001 – $2,000,000 $2,000,001 - $5,000,000 Over $5,000,000 Maximum Annual Fee 2.25% 2.00% 1.75% 1.25% 1.00% Advisory fees are subject to negotiation. When negotiating fees, factors considered, but not limited to, include: (i) clients with multiple accounts; (ii) size of the account; (iii) a prior or existing relationship; and (iv) a client’s particular needs or financial characteristics. Since fees 8 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  vary, Clients with existing accounts may be charged fees not precisely matching the foregoing fee schedules or the fees paid by other Clients. CAPTRUST may give advice to one Client that may be different from the advice given to another Client. Clients should consider the value of the additional consulting services when making such comparisons. Certain combinations of custodial, consulting, and brokerage services may not be available separately or may require multiple accounts, documentation, and fees. For Clients who do not elect a “wrap-fee” account, CAPTRUST’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses incurred by the Client. Clients who elect to use CAPTRUST wrap program should refer to the CAPTRUST Wrap Fee Programs Brochure for a description of fees. Clients may incur certain charges imposed by custodians, brokers, third party investment advisors, and other third parties, such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange-traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. These charges and fees are exclusive of and in addition to CAPTRUST’s fee. CAPTRUST is independently owned and operated and not affiliated with any custodial broker-dealer. Clients choose the brokerage platform to hold their investment accounts. CAPTRUST has prime broker and/or brokerage custody agreements to provide execution, brokerage and custodial account services to CAPTRUST clients with Schwab, Pershing, and Fidelity Investments through Fidelity Brokerage Services, LLC/National Financial Services, LLC (“Fidelity”). In general, Clients use Schwab, Pershing, or Fidelity for execution and custodial services (each such provider, a “custodian”). Custodians are FINRA registered broker-dealers. Some Clients choose to use custodians other than Pershing, Fidelity, or Schwab (such as trust companies). In those cases, CAPTRUST works with the Client’s chosen custodian to manage the Client’s investments. Custodial and execution fees charged by custodians vary so that Clients may pay more or less for similar services than Clients who choose a different custodian. Adviser may recommend Clients invest in funds-of-funds. Funds-of-funds typically carry additional fees over and above the fees discussed in this section. Because hedge fund managers typically charge performance fees (over and above their management fee) and because funds-of-funds are comprised of allocations to many hedge fund managers, each manager charges its own management fee and many also charge performance fees which creates a layering effect. Consequently, Clients should be aware of these additional costs associated with investing in funds-of-funds. Each fund-of-fund discloses its own fee structure in the prospectus for that fund. In general, CAPTRUST does not receive any portion of these charges, fees and costs, however, please refer to Item 6 below for more information on the limited cases when CAPTRUST participates in performance fees. 9 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  12b-1 and Other Miscellaneous Fees Generally, CAPTRUST purchases institutional class or no-load mutual funds in investment portfolios which do not generate sales charges. Load and no-load mutual funds may pay annual distribution charges, sometimes referred to as 12b-1 fees. These 12b-1 fees come from fund assets, and therefore indirectly from Client assets. Client’s custodian may be compensated by 12b-1 fees for general promotion, advertising, and distribution in relation to Client purchases and sales of mutual fund shares in a managed account. CAPTRUST does not participate in 12b-1 fees. Other costs that may be assessed that are not part of those outlined above include fees for portfolio transactions executed away from the custodian selected by the Client, dealer mark- ups, electronic fund and wire transfers, spreads paid to market-makers, and exchange fees. Custodian may charge Client certain additional and/or minimum fees. Fixed Fee Service. Some Clients engage CAPTRUST to provide investment advisory, consultation or other ancillary services for a fixed or flat fee. Fixed fees are negotiable, but generally range from $10,000 to $250,000 on an annual basis, depending upon the level and scope of the services required. Adviser’s fixed rate is determined based on anticipated work to be done. Fixed fees will be charged quarterly in advance calculated on a per diem basis upon the signing of an agreement by the Client. Fees for Clients engaging Adviser mid- quarter will be prorated on a per diem basis. Hourly Fee Service. When performing family office and/or other ancillary services, including tax consulting and planning, accounting/tax preparation, and bill pay, CAPTRUST charges hourly fees that can range from $50 to $500 per hour depending upon the type and complexity of the ancillary services to be provided. These services and fees will be negotiated and agreed upon with the Client, prior to performing the services. Item 6: Performance-Based Fees and Side-By-Side Management In general, CAPTRUST does not charge performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a Client). Please see Item 10 – “Other Financial Industry Activities and Affiliations – Material Conflicts Regarding Private Funds” for a detailed explanation of conflicts in connection to the One Brick Select Private Credit Fund, LP and One Brick Select Private Credit Qualified Fund I, LP (collectively, the “One Brick Funds”) which invest in T. Rowe Price OHA Select Private Credit Fund (“OCredit”). Incentive fees earned by OCredit will be shared with investors in the One Brick Funds. CAPTRUST does not charge performance fees to the One Brick Funds, but indirectly participates in fees earned by OCredit. The assets in the One Brick Funds represent less than 0.006% of all Client assets. 10 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 7: Types of Clients CAPTRUST provides investment advisory services to Wealth Clients, including but not limited to, individuals, high net worth individuals, trusts, estates, charitable organizations, foundations, endowments, and corporate entities. CAPTRUST also provides advisory services to Institutional Clients including, but not limited to, 401(k) plans, 403(b) plans, pensions and profit-sharing plans, non-qualified plans, foundations, endowments, corporations. These services are disclosed separately in CAPTRUST’s Institutional Brochure. CAPTRUST generally maintains a minimum account size requirement for its Wealth Clients of $50,000 to initially establish an account. The value of this account is subject to fluctuation, and therefore there is not a minimum maintenance requirement. Adviser retains the right to waive minimum initial account sizes should Adviser feel it is necessary and appropriate. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss CAPTRUST’s investment strategy begins with an understanding of a Client’s financial goals. Adviser uses demographic and financial information provided by the Client to assess the Client’s risk profile and investment objectives when determining an appropriate plan for the Client’s assets. Investment strategies generally include long or short-term purchases of stock portfolios, mutual funds, exchange traded funds, fixed income securities, and other investment vehicles where appropriate, and may include margin transactions and options strategies. Investment strategies. CAPTRUST uses both a risk-based and outcome-based approach to asset allocation. Client portfolios will predominantly be invested in the following asset classes: US equities, international equities, fixed income, alternative investments (strategic opportunities), commodities, and real estate. CAPTRUST Financial Advisors may build custom allocations for Clients or select from pre- built models managed by the Investment Committee. Investment recommendations, including model selection, are based on an analysis of the Client’s individual needs and are drawn from research and analysis. In general, investment analysis methods may include fundamental analysis as well as quantitative and qualitative research on a given investment vehicle. Information for this analysis may be drawn from financial newspapers, magazines and databases, research materials prepared by others, annual reports, corporate filings, and prospectuses. Additional sources of information utilized by CAPTRUST include meetings and discussions with investment managers employed by investment companies, statistical summaries and analysis and such other sources CAPTRUST deems appropriate. CAPTRUST may utilize services of subadvisers and established third party research services to assist CAPTRUST with formulating asset allocation, industry and sector selection, and investment recommendations in managing the Client’s funds. Technical analysis may be used when analyzing indices and/or securities. 11 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  It is important to note that investing in securities involves certain risks that are borne by the investor. For risks associated with investment company (mutual fund) products, Clients should refer to fund prospectuses. Our investment approach constantly keeps the risk of loss in mind. These risks include, but are not limited to:  Interest rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market value to decline.  Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events.  Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.  Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities.  Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.  Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Some funds, such as interval funds, that could be utilized in select strategies employed by CAPTRUST, carry liquidity risk. In some circumstances, Clients have had to wait several quarters or longer when requesting liquidity from the manager of interval funds within select CAPTRUST asset allocated model strategies that utilize these semi- liquid instruments.  Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value.  Concentration Risk: The probability of loss due to heavy exposure to a single investment, equity or issuer. Some funds utilized in model strategies employed by CAPTRUST, carry a kind of concentration risk because Clients may own more than one fund managed by the same issuer; or Clients may be invested in several funds with similar strategies which poses a type of concentration risk. Another form of concentration risk occurs when one group of Clients comprise a large portion of a mutual fund’s total asset base, those Clients experience an additional risk over and above the risks associated with the investment’s strategy due directly to the concentration of their assets in that fund. CAPTRUST strategies may involve some or all of the types of concentration risk described here.  Other risks: CAPTRUST’s recommended strategies include the risks listed above as well as other risks that are more specifically associated with managers, strategies, funds, or instruments CAPTRUST selects or recommends. For example, some recommended managers use derivatives (e.g., options as a hedge) which pose special risks; others carry liquidity risk specific to underlying investments; additionally, some of Adviser’s 12 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  asset allocated model strategies have a particular concentration risk because Adviser may allocate a large portion of a portfolio to a single manager, or a fund complex. Some portfolios include alternative or uncommon investment strategies, or allocations to funds with limited or no prior history of operations. Each recommended manager discloses risks associated with investing in their funds separately in their respective brochures and/or prospectuses. o Although CAPTRUST acknowledges that Clients are relying on CAPTRUST to manage portfolio risk, Clients are encouraged to read managers’ disclosure brochures and prospectuses and ask questions of CAPTRUST’S Financial Advisors, Investment Committee members, or compliance team members. Please contact us at 919.870.6822 or send a message to compliance@captrust.com.  Private investment funds: Clients who are qualified to invest in private funds must acknowledge and accept the specific risk factors that are associated with investing in private funds. Private fund investments involve various risk factors, including, but not limited to, potential for complete loss of principal, illiquidity, and lack of transparency. Item 9: Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a Client or prospective Client’s evaluation of CAPTRUST or the integrity of CAPTRUST’s management. Neither CAPTRUST management nor members of CAPTRUST’s Investment Committee have any reportable disciplinary history for this Item. Each Financial Advisor who acts as a Portfolio Manager has a separate Form ADV Part 2B. Please refer to Form ADV Part 2B for personal disciplinary information for individual Financial Advisors. Item 10: Other Financial Industry Activities and Affiliations CAPTRUST is affiliated by common ownership to CapFinancial Securities, LLC (“CFS”), a FINRA broker-dealer (Member SIPC). CAPTRUST does not manage any proprietary mutual funds. CFS, as an affiliated registered broker-dealer, provides individuals and institutions with general securities investment services. Many Investment Adviser Representatives with Adviser are also registered as CFS Registered Representatives. A CAPTRUST Financial Advisor who focuses primarily on wealth advisory services generally spends less than 10% of their time on work done for Clients focused on activities consistent with the definition of broker-dealer activities. A CAPTRUST Financial Advisor whose focus is Institutional Clients will generally spend less than 1% of their time on broker-dealer activities. CAPTRUST business divisions called “1776 Advisor Group,” “Strategic Advisor Group,” and “Family Office Risk Advisors” together with several CAPTRUST Financial Advisors, are licensed to act as agent of record for Clients who own life insurance products or for retirement plans funded with group variable products. Financial Advisors may occasionally recommend fixed or variable annuities or life insurance (including Private Placement Life 13 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Insurance (“PPLI”) to their Wealth Clients when assisting them in executing their financial plan. CFS and CAPTRUST have business entity insurance licenses. Strategic Advisor Group’s primary source of revenue is life insurance commissions not involving CAPTRUST qualified retirement plan clients. As a result of certain investment-related recommendations provided to its Clients, CFS may facilitate certain securities purchases and/or sales, or insurance product purchases and/or sales on behalf of CAPTRUST Clients. Such transactions may be facilitated by CFS, in its capacity as a registered broker-dealer or insurance agent/agency (business entity). Commissions charged by CFS may be higher or lower than obtainable elsewhere. When CFS is being compensated by commissions, general promotion, advertising, and distribution fees (such as 12b-1 fees) in relation to purchases and sales of commission-based investment products or mutual fund shares, CAPTRUST does not also charge an advisory fee on those assets but includes the accounts at a 0% advisory fee. In the fourth quarter of 2024, CFG acquired the assets of four different firms: Campbell Wealth Management (CRD #152956) in Alexandria, VA, TruNorth Wealth Partners (CRD #284807) in St. Paul, MN, Wealth Covenant Group (CRD #291453) in Houston, TX., and Boston Financial Management (CRD #112360) (“BFM”) with offices in Boston, MA, Centerville, MA, and Portland, ME. CFG also acquired BFM’s wholly-owned subsidiary, Boston Fiduciary Services, LLC, which provides professional trustee and fiduciary services to individuals, businesses, and non-profit organizations. Material Conflicts Regarding Private Funds CAPTRUST provides investment recommendations and advice regarding both affiliated and non-affiliated private investment funds. CAPTRUST provides the fund’s offering materials at or prior to recommending the investment. Clients should refer to the fund’s confidential offering memorandum for applicable disclosures regarding management of the fund, its investment objective, risk factors, tax, and related factors. One Brick. CAPTRUST serves as investment advisor to One Brick Select Private Equity 2024, L.P. CAIS One Brick Select Private Equity 2024 GP LLC, an unaffiliated entity, serves as general partner. CAPTRUST also serves as investment advisor to One Brick Select Private Credit Fund, LP and One Brick Select Private Credit Qualified Fund I, LP (the “One Brick Funds”), for which PPB Capital Partners ("PPB") serves as general partner and fund administrator. The One Brick Funds invest in T. Rowe Price OHA Select Private Credit Fund (“OCredit”). OHA Private Credit Advisors LLC (“OHA Advisor”) is the investment adviser to OCredit. OCredit pays OHA Advisor an incentive fee for serving as its investment manager. As more people invest in OCredit, OHA Advisor will earn more fees. One Brick Funds will also share in those incentive fees, which creates an incentive for CAPTRUST to recommend OCredit in order to increase the potential profits eligible to be shared with investors in the One Brick Funds which include CAPTRUST Clients and employees. (Please see Item 6.). One Brick Funds pay nominal fees to PPB for fund administration as well as 10bps/year in advisory fees to CAPTRUST.  14 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Homecourt. CAPTRUST is the owner of CAPTRUST 2022 Homecourt Fund GP, LLC, a Delaware single member limited liability company, for which the sole purpose was the organization of a private fund called CAPTRUST 2022 Homecourt Fund, L.P. (“Homecourt”). Homecourt was formed as an “Access Fund” into Dyal HomeCourt US Investors LP (“Dyal”), and independent third party private limited partnership. CAPTRUST acts as the investment adviser to Homecourt. The interests were offered pursuant to an exemption from the registration requirements of the Securities Act of 1933, as amended (the “Securities Act”). Each investor must be a U.S. person that is a person with the requisite skill and expertise to adequately assess the risks of investing in the Access Fund (and indirectly investing in the Underlying Fund); an “accredited investor” as defined within the meaning of Rule 501(a) of Regulation D promulgated under the Securities Act; a “qualified purchaser” as defined under the Investment Company Act, and a “qualified client,” as defined under the U.S. Investment Advisers Act of 1940, as amended, and the rules and regulations promulgated thereunder (the “Advisers Act”). There is no public market for the interests, and no such market is expected to develop in the future. CAPTRUST’s “Management Fee Rate” is 0.10% per annum (e.g. 0.025% per quarter) for limited partners who are Clients and 1.00% per annum (e.g. 0.25% per quarter) for limited partners who are no longer Clients. MRA. CAPTRUST acts as investment adviser to a series of private funds, namely, MR Investment Fund 1 LLC, MRA Opportunities Fund 1-A, MRA Opportunities Fund 1-B, MRA Credit Strategies Fund 1-A Fund LP, and MRA Credit Strategies Fund 1-B Fund LP. SALI. CAPTRUST acts as subadvisor to three private funds, Covenant Global Equities Fund Series Interests of the SALI Multi-Series Fund II 3(c)(1), LP, Covenant Global Equities Fund Series Interests of the SALI Multi-Series Fund II, L.P., and Vega Multi-Strategy Fund Series of the SALI Multi-Series Fund, L.P., for which SALI Fund Services acts as investment advisor and fund administrator. TRUSTCORE. CAPTRUST acts as subadvisor to Trustcore Private Opportunities Fund, LP for which PPB Advisors acts as investment advisor and NAV Consulting provides fund administration. RINET. CAPTRUST and RINET Company, LLC entered into a limited (administrative) services agreement whereby CAPTRUST will assist RINET in winding down four private funds RINET manages. Item 11: Code of Ethics CAPTRUST’s Code of Ethics addresses, among other things: (i) CAPTRUST’s fiduciary obligations to its Clients, (ii) personal securities trading procedures restricting the purchase and sale, by employees for their own accounts, of specific securities; (iii) provisions relating to the confidentiality of Client information; (iv) a prohibition on insider trading; (v) limits on political contributions; and (vi) restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment. 15 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Personal transactions in securities by directors, officers, and employees of CAPTRUST who have access to nonpublic information regarding Clients’ purchase and sale of securities, are involved in making securities recommendations to Clients, or who have access to such non- public recommendations are subject to the restrictions and procedures in CAPTRUST’s Code of Ethics. All employees at CAPTRUST must acknowledge the terms of the Code of Ethics annually, or as amended. Occasionally, Adviser’s employees may recommend that Clients buy or sell the same securities or investment products that Adviser’s employees also own. CAPTRUST’s employees and persons associated with CAPTRUST are required to follow the Code of Ethics. The Code of Ethics is intended to identify and address potential conflicts of interest that might arise in the context of personal securities transactions, activities, and interests of CAPTRUST employees that might interfere or appear to interfere with making decisions in the best interest of advisory Clients. Under the Code of Ethics certain classes of securities have been designated as exempt transactions, based upon a determination that they would not materially interfere with the best interest of CAPTRUST’s Clients. In addition, the Code of Ethics requires pre-approval of specific types of transactions, and, depending on the transaction, may restrict trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as Clients, there is a possibility that employees might benefit from market activity by a Client. Employee trading is monitored under the Code of Ethics to reasonably prevent conflicts of interest between CAPTRUST and its Clients. CAPTRUST employees whose accounts are managed by CAPTRUST are included in block trading where CAPTRUST places trades for execution that include accounts of two or more clients and when CAPTRUST believes trade aggregation is appropriate and in the best interest of its Clients. (See “Block Trades” under “Brokerage Practices” below for additional information). CAPTRUST’s Clients may request a copy of the Adviser’s Code of Ethics by contacting the Compliance Department at 919.870.6822 or 800.216.0645 or by email at compliance@captrust.com. Item 12: Brokerage Practices Some CAPTRUST Financial Advisors (Investment Adviser Representatives) also affect securities transactions for Clients as registered representatives of a broker-dealer (see Item 10). Further, Adviser or its associated persons may receive compensation for such transactions, where such compensation is separate and distinct from Adviser’s compensation related to its investment advisory services. All FINRA, SEC, and other regulatory agencies disclosure requirements and policies are observed for all transactions. Wrap Fee Programs. Clients who have chosen a wrap fee arrangement when utilizing a brokerage platform should review the CAPTRUST Wrap Fee Programs Brochure, available at 16 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  https://captrust.com/important-disclosures, for a description of wrap fee programs sponsored by CAPTRUST. CAPTRUST uses risk-based and outcomes-based approaches to portfolio management. Regardless of whether a Client is in a wrap or a non-wrap account, when executing trade orders within a risk-based strategy described in Item 8, trades for accounts are blocked together at each of the three custodians if the objectives and/or instructions for the order are similar. Block Trades. CAPTRUST may aggregate, or “block” orders being placed for execution at the same time for the accounts of two or more Clients, where it believes such aggregation is appropriate and in the best interest of the Clients. All accounts within the block will receive the same execution price on each trade date. This practice may include accounts in which CAPTRUST’s affiliates and employees have an ownership interest. However, CAPTRUST is not obligated to block orders or to include any account in a blocked order if portfolio management decisions for such accounts are made separately or if CAPTRUST determines that blocking trades would be inconsistent with the Adviser’s investment management duties. These duties may include the consideration of any investment objectives, guidelines, special requests, or restrictions applicable to a particular account. All block orders placed for execution are subject to CAPTRUST’s Trade Allocation Procedures. Under these procedures, CAPTRUST will block orders where appropriate for the participating Clients and when consistent with CAPTRUST's duty to seek best execution. Prior to or contemporaneous with the entry of a blocked order, CAPTRUST will capture the pre- allocation for the blocked trade identifying Client accounts or trading groups of Client accounts participating in the blocked order detailed either in dollars, number of shares, or percent of market value for the referenced Client accounts. Based on the individual market for security, CAPTRUST may not receive complete execution on the entire volume of securities purchased or sold during a single trading session. Thus, the effect of the aggregation may operate in some circumstances to a particular Client’s disadvantage. When a blocked order is partially filled, the securities purchased or sold by the close of each business day will be allocated in a manner that is consistent with the initial pre- allocation statement and does not consistently advantage or disadvantage particular Clients or groups of Client accounts. However, adjustments to the allocation may be made to avoid de minimis allocations to Client accounts or to avoid deviations from pre-determined holding limits or other such limitations established for any account. CAPTRUST will retain records of the trade order specifying each participating account and its allocation. Although CAPTRUST generally attempts to block trades for Client accounts, aggregation may not be possible because of that Client’s specific brokerage arrangements or other factors. The majority of CAPTRUST PMA & SMA Wrap Fee accounts use Pershing as their custodian. Some Clients may select Schwab, Fidelity, or upon occasion, other financial institutions to act as custodian and broker/dealer for their accounts. When the Investment Committee, a Portfolio Manager, or Investment Strategist implements a portfolio decision or strategy ahead of or contemporaneously with similar portfolio decisions or strategies of other Clients certain factors may create less favorable execution results when compared to other Clients. Such factors may include liquidity constraints, potential market impact or the time executions occur at different custodians. While CAPTRUST makes every effort to reduce conflicts of 17 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  interest, there can be no assurance that any actual or potential conflicts of interest will not result in a particular Client or group of Clients receiving less favorable investment terms or returns from certain investments than if such conflicts of interest did not exist. For CAPTRUST Client accounts maintained by the custodians, custodians generally do not charge separately for custody services but may be compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through the custodian or that settle in accounts held by the custodian. Custodians may also make available to CAPTRUST products and services that could benefit CAPTRUST but may not benefit all Clients’ accounts. Some of these other products and services assist CAPTRUST in managing and administering Client accounts. These include software and other technology that provide access to Client account data (such as trade confirmations and account statements); the facilitation of trade execution and allocation of aggregated trade orders for multiple client accounts; research, pricing information and other market data; facilitating payment of CAPTRUST’s fees from its Clients’ accounts; and assistance with back-office functions, recordkeeping and client reporting. Many of these services generally may be used to service all or a substantial number of CAPTRUST’s accounts, including accounts not maintained at the custodian. The foregoing arrangements pose a conflict of interest to the extent they create an incentive for CAPTRUST to suggest that Clients maintain their assets in accounts at a custodian based on products and services that may become available to CAPTRUST rather than solely based on the nature, cost or quality of custody and brokerage services provided by custodian to Clients. However, CAPTRUST is constrained by fiduciary principles to act in its Clients’ best interests and will suggest a custodian to clients only when it is appropriate to do so. In addition, CAPTRUST maintains an awareness of the services provided to Clients by these custodians to confirm that Clients are well served by these partners. In general, when a trade error occurs in a managed account CAPTRUST absorbs the loss from correcting transactions and the custodian typically makes a charitable donation of any resulting profit. However, each custodian handles trade error corrections slightly differently. CAPTRUST has controls in place to limit trade errors. Some transactions that must be made by application or subscription agreement will be facilitated directly with the fund administrator, insurance company, or other legal entity responsible for effecting such transactions. While most of the Adviser’s business is done on a fee basis, an investment adviser representative may be compensated in connection to a transaction (by commission) when appointed by the client as “broker or agent of record” for a direct-to-the-fund account set up through CFS. In that case, CFS may be compensated by commissions, general promotion, advertising, and distribution fees (such as 12b-1 fees) in relation to purchases and sales of commission-based investment products or mutual fund shares in those types of accounts. There are a limited number of these non-advisory commissions-based Client accounts. CAPTRUST advises these types of accounts at a 0% advisory fee. CAPTRUST Clients utilize the brokerage platforms provided by Pershing, Fidelity, or Schwab. While CAPTRUST does have the ability to negotiate fees or commissions on behalf of Clients, 18 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  CAPTRUST does not direct brokerage to a particular venue for execution, but rather relies on Pershing, Schwab, or Fidelity to utilize their resources to select the most appropriate venue for execution. An exception to this practice involves bond trades that are directed by a CAPTRUST Financial Advisor to an executing broker dealer. Fees and commissions charged by these brokerage platforms may be higher or lower than obtainable elsewhere. Circumstances occasionally arise when the brokerage platforms must impose a separate or special handling or custodial charge for acting as custodian for an exempt security or private placement that was recommended by CAPTRUST to a CAPTRUST advisory Client. On a case-by-case basis, CAPTRUST may cover the cost of this type of fee on a “value-added” basis by having the fee directly billed to CAPTRUST rather than the Client or by reimbursing the Client. Finally, CAPTRUST participates in several referral programs offered by the custodians that benefit CAPTRUST which are identified in the detailed disclosure under Item 14 (below). Item 13: Review of Accounts Client accounts are advised by the Client’s Financial Advisor who is responsible for performing periodic reviews, consulting with their Clients, and staying abreast of changes to their Clients’ goals and objectives. Ongoing reviews of markets, sectors, and individual securities are conducted by the Investment Group. Unaffiliated mutual fund holdings and outside Investment Managers are monitored on a continuous and regular basis by the CAPTRUST Investment Group. Michael Vogelzang, Chief Investment Officer, leads the Investment Group. ADV Part 2B (attached to this Brochure) lists the members of the Investment Group who are also members of the Investment Committee or who are involved in the review process and in determining the investment advice to be given by the Adviser. In addition to monthly statements provided by the custodian of the Client’s assets, CAPTRUST prepares quarterly performance reports for Wealth Client accounts. Clients may access their quarterly performance reports electronically via CAPTRUST’s client portal. Clients should contact their Financial Advisor, or contact CAPTRUST at the contact details in Item 1, for questions about how to access their reports. CAPTRUST receives a daily download of transaction information from Pershing, Schwab, and Fidelity and has access to Wealth Client accounts through their institutional advisor platforms. Clients agree to inform CAPTRUST in writing of any material changes to the Client’s investment goals and objectives or financial situation that might affect the manner with which Client’s assets should be invested. Additionally, Clients who wish to impose reasonable restrictions on the management of their accounts may do so by contacting their Financial Advisor or CAPTRUST at the contact details in Item 1. Clients with portfolios that include private equity and/or other private investments (“private funds”) should be advised that quarterly values lag for up to 60 days following a quarter-end. Because CAPTRUST relies on the Client’s capital account statement (provided by the issuer or qualified custodian) for private fund values used for purposes of quarterly portfolio review and reporting, quarterly review reports will reflect the latest valuation date available. Consequently, a Client’s actual private fund holdings could be significantly more or less than the value reflected on their portfolio report. Unless otherwise indicated, the Client’s advisory 19 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  fee will be based upon the value reflected in CAPTRUST’s client portal . Clients may contact CAPTRUST during normal business hours to consult with CAPTRUST concerning the management of the Client’s accounts. Item 14: Client Referrals and Other Compensation Clients (or prospective Clients) who are being referred to CAPTRUST, either by means of a paid endorsement by a third-party or in connection with a paid testimonial by a current client, must be made aware of the arrangement at the time the testimonial or endorsement is disseminated in a clear and prominent manner. The disclosure of the arrangement must explain whether the testimonial was given by a current Client or investor; or if the endorsement was given by a person other than a current Client or investor; explain whether cash or non-cash compensation was provided for the testimonial or endorsement; and if applicable, include brief statement of any material conflicts of interest on the part of the person giving the testimonial or endorsement resulting from the investment adviser's relationship with such person. In cases where a referral takes place in person, these required disclosures will be delivered in writing at the time the testimonial or endorsement is being mad. CAPTRUST has entered into referral agreements with various third-party solicitors for Client referrals. For a solicitor to be compensated by CAPTRUST for referring a Client to CAPTRUST, the solicitor must be engaged by CAPTRUST under a solicitor or referral agreement (“Referral Agreement”) in compliance with Rule 206(4)-1 under the Investment Advisers Act of 1940. In general, a solicitor is compensated by a percentage of the advisory fee collected for a specified period of time (as detailed in the Referral Agreement). Clients pay no additional fee for the referral over and above CAPTRUST’s quoted advisory fee; to the contrary, the fee the Adviser earns is reduced by the amount of the compensation to the solicitor. Each Referral Agreement requires the solicitor to deliver the required disclosures either in writing or via the internet at the time of the testimonial or endorsement is made. Clients may request details regarding a particular Referral Agreement by contacting CAPTRUST at the contact details in Item 1. Schwab Advisor Network® CAPTRUST receives client referrals from Schwab through CAPTRUST’s participation in Schwab Advisor Network® (the “Service”). The Service is designed to help investors find an independent investment advisor. Schwab is a broker-dealer independent of and unaffiliated with CAPTRUST. Schwab does not supervise CAPTRUST and has no responsibility for CAPTRUST’s management of clients’ portfolios or CAPTRUST’s other advice or services. CAPTRUST pays Schwab fees to receive client referrals through the Service. CAPTRUST’s participation in the Service may raise potential conflicts of interest described below. CAPTRUST pays Schwab a participation fee on all referred Client accounts that are maintained in custody at Schwab and a non-Schwab custody fee on all accounts that are maintained at, or transferred to, another custodian. The participation fee paid by CAPTRUST is a percentage of the fees the client owes to CAPTRUST or a percentage of the value of the 20 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  assets in the Client’s account, subject to a minimum Participation Fee. CAPTRUST pays Schwab the participation fee for so long as the referred Client’s account remains in custody at Schwab. The participation fee is billed to CAPTRUST quarterly and may be increased, decreased or waived by Schwab from time to time. The participation fee is paid by CAPTRUST and not by the Client. CAPTRUST has agreed not to charge Clients referred through the Service fees or costs greater than the fees or costs CAPTRUST charges Clients with similar portfolios who were not referred through the Service. CAPTRUST generally pays Schwab a non-Schwab custody fee if custody of a referred Client’s account is not maintained by, or assets in the account are transferred from Schwab. This fee does not apply if the Client was solely responsible for the decision not to maintain custody at Schwab. The non-Schwab custody fee is a one-time payment equal to a percentage of the assets placed with a custodian other than Schwab. The non-Schwab custody fee is higher than the participation fees CAPTRUST generally would pay in a single year. Thus, CAPTRUST will have an incentive to recommend that Client accounts be held in custody at Schwab. The participation and non-Schwab custody fees will be based on assets in accounts of CAPTRUST’s Clients who were referred by Schwab and those referred Clients’ family members living in the same household. Thus, CAPTRUST will have incentives to encourage household members of Clients referred through the Service to maintain custody of their accounts and execute transactions at Schwab and to instruct Schwab to debit CAPTRUST’s fees directly from the accounts. For accounts of CAPTRUST’s Clients maintained in custody at Schwab, Schwab will not charge the Client separately for custody but will receive compensation from CAPTRUST’s Clients in the form of commission or other transaction-related compensation on securities trades executed through Schwab. Schwab also will receive a fee (generally lower than the applicable commission on trades it executes) for clearance and settlement of trades executed through broker-dealers other than Schwab. Schwab’s fees for trades executed at other broker-dealers are in addition to the other broker-dealer’s fees. Thus, CAPTRUST may have an incentive to cause trades to be executed through Schwab rather than another broker- dealer. CAPTRUST nevertheless acknowledges its duty to seek best execution of trades for Client accounts. Trades for Client accounts held in custody at Schwab may be executed through a different broker-dealer than trades for CAPTRUST’s other Clients. Thus, trades for accounts custodied at Schwab may be executed at different times and different prices than trades for other accounts that are executed at other broker-dealers. Fidelity Wealth advisor Solutions® CAPTRUST participates in the Fidelity Wealth Advisor Solutions® Program (the “WAS Program”), through which CAPTRUST receives referrals from Fidelity Personal and Workplace Advisors LLC (FPWA), a registered investment adviser and Fidelity Investments company. CAPTRUST is independent and not affiliated with FPWA or any Fidelity Investments company. FPWA does not supervise or control CAPTRUST and FPWA has no responsibility or oversight for CAPTRUST’s provision of investment management or other advisory services. Under the WAS Program, FPWA acts as a solicitor for CAPTRUST and CAPTRUST pays referral fees to FPWA for each referral received based on CAPTRUST’s assets under management attributable to each Client referred by FPWA or members of each Client’s household. The WAS Program is designed to help investors find an independent investment 21 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  advisor, and any referral from FPWA to CAPTRUST does not constitute a recommendation or endorsement by FPWA of CAPTRUST’s particular investment management services or strategies. More specifically, CAPTRUST pays the following amounts to FPWA for referrals: the sum of (i) an annual percentage of 0.10% of any and all assets in client accounts where such assets are identified as “fixed income” assets by FPWA and (ii) an annual percentage of 0.25% of all other assets held in client accounts. In addition, CAPTRUST has agreed to pay FPWA a minimum annual fee amount in connection with its participation in the WAS Program. These referral fees are paid by CAPTRUST and not the Client. To receive referrals from the WAS Program, CAPTRUST must meet certain minimum participation criteria, but CAPTRUST may have been selected for participation in the WAS Program as a result of its other business relationships with FPWA and its affiliates, including Fidelity Brokerage Services, LLC (“FBS”). As a result of its participation in the WAS Program, CAPTRUST may have a potential conflict of interest with respect to its decision to use certain affiliates of FPWA, including FBS, for execution, custody and clearing for certain client accounts, and CAPTRUST may have a potential incentive to suggest the use of FBS and its affiliates to its advisory Clients, whether or not those Clients were referred to CAPTRUST as part of the WAS Program. Under an agreement with FPWA, CAPTRUST has agreed that Adviser will not charge Clients more than the standard range of advisory fees disclosed in its Brochure to cover solicitation fees paid to FPWA as part of the WAS Program. Pursuant to these arrangements, CAPTRUST has agreed not to solicit Clients to transfer their brokerage accounts from affiliates of FPWA or establish brokerage accounts at other custodians for referred Clients other than when CAPTRUST’s fiduciary duties would so require, and CAPTRUST has agreed to pay FPWA a one-time fee equal to 0.75% of the assets in a client account that is transferred from FPWA’s affiliates to another custodian; therefore, CAPTRUST may have an incentive to suggest that referred clients and their household members maintain custody of their accounts with affiliates of FPWA. However, participation in the WAS Program does not limit CAPTRUST’s duty to select brokers on the basis of best execution. Item 15: Custody Clients should receive statements at least quarterly from the qualified custodian that holds and maintains the Client’s investment assets. CAPTRUST urges Clients to carefully review such statements and compare the official custodial records to any reports provided by CAPTRUST. CAPTRUST reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. CAPTRUST does not act as a qualified custodian for Client assets. CAPTRUST discloses in Item 9 of Form ADV Part 1 that it has custody of Clients’ funds or assets for certain reasons (e.g., where a Wealth Client has granted their CAPTRUST Financial Advisor the ability to access the Client’s assets). CAPTRUST is subject to an annual surprise custody examination by an independent certified public accounting firm. Item 16: Investment Discretion For certain CAPTRUST Clients, Adviser has the authority to determine, without obtaining specific Client consent, both the securities to be bought and sold in their accounts as well as 22 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  the amount of the securities to be bought or sold. However, this discretion must be provided at the beginning of the Adviser/Client relationship and documented in the advisory agreement. There is no particular set limit to this discretion established as part of the agreement or this Brochure. Adviser has the authority to negotiate commission rates charged by the custodians, but does not have any control over the fees charged by the custodians for the services they provide. These fee changes have a direct impact to the Client as they may be charged commissions for transactions. There is no limitation on such discretion, and the Client may pay commissions higher than those obtainable from other broker-dealers for the same products and services. Commissions and/or transaction fees charged Pershing, Fidelity, and Schwab may be higher or lower than obtainable elsewhere. Item 17: Voting Client Securities In general, CAPTRUST Clients delegate the authority to vote their proxies to CAPTRUST in their agreement. It is CAPTRUST’s aim to see that proxies are voted in the best interest of its Clients. As such, CAPTRUST has engaged Institutional Shareholder Services Inc. (“ISS”), to vote proxies on behalf of Clients who delegate proxy voting authority to CAPTRUST. ISS is an independent proxy voting service provider, which performs extensive research, and has designed and maintains a number of proxy voting guidelines. While Clients are always free to vote their own proxies, for those that delegate that responsibility to CAPTRUST, CAPTRUST generally leverages ISS Benchmark Proxy Voting Guidelines (“Guidelines”). The Guidelines are based on widely accepted good governance practices and principles, are designed to be responsive to the wide range of issues that can be raised in proxy situations, and to increase total shareholder value and risk mitigation. Additionally, Clients may revoke their delegation of proxy voting authority at any time, with written notice to CAPTRUST. The Proxy Voting Policy contains additional guidelines and methods by which conflicts of interests are addressed. Such conflict may include situations where CAPTRUST has or is seeking a Client relationship with the issuer of the security that is the subject of the proxy vote. Generally, because the Guidelines pre-establish voting positions, application should adequately address any possible conflicts of interest. SMA Accounts. Where CAPTRUST has recommended an SMA Manager, Clients delegate proxy voting authority to their SMA Manager. The SMA Manager’s proxy voting policies will be detailed in their Form ADV Part 2 brochure. To obtain a copy of CAPTRUST’s Proxy Voting Policy or for a copy of CAPTRUST’s Proxy Voting record, Clients can contact CAPTRUST at the contact details in Item 1. Alternatively, Clients may email IG.Investment.Admin@captrust.com or write to CAPTRUST “Investment Administration” to obtain the information at the address below: CAPTRUST Investment Administration 4208 Six Forks Road, Suite 1700 Raleigh, NC, 27609. 23 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 18: Financial Information Registered investment advisers are required to provide Clients with certain financial information or disclosures about CAPTRUST’s financial condition. CAPTRUST has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of any bankruptcy proceeding. CAPTRUST’s Privacy Policy and Business Continuity Plan CAPTRUST’s Privacy Policy and Business Continuity Plan can be found on the CAPTRUST internet site by navigating to:  Privacy Policy: https://www.captrust.com/privacy-policy/  Business Continuity Plan: https://www.captrust.com/business-continuity-plan/ 24 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645 

Item 1: Cover Page March 18, 2025 CAPTRUST Financial Advisors 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 Firm CRD #175112 Phone: 919.870.6822 Toll Free: 800.216.0645 www.captrust.com This Form ADV Part 2A is the CAPTRUST Institutional Client Brochure (“Brochure” or “Institutional Brochure”) and provides information about the qualifications and business practices of CAPTRUST Financial Advisors with respect to services provided to institutional clients. If you have any questions about the contents of this Brochure, please contact us by phone at 919.870.6822 or toll-free at 800.216.0645 or by email compliance@captrust.com. 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. CAPTRUST Financial Advisors is an investment adviser registered under the Investment Advisers Act of 1940. Registration does not imply any level of skill or training. Additional information about CAPTRUST Financial Advisors also is available on the SEC’s website at www.adviserinfo.sec.gov. 1 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 2: Summary of Material Changes This Summary of Material Changes reflects only material changes to this Brochure since our last annual update of this Brochure which was dated March 28, 2024. A full copy of our Brochure may be requested by email at compliance@captrust.com or by contacting us toll- free at 800.216.0645. Item 10 - Other Financial Industry Activities and Affiliations Item 10 has been amended to disclose the following acquisition activity: In the fourth quarter of 2024, CFG acquired the assets of four different firms: Campbell Wealth Management (CRD #152956) in Alexandria, VA, TruNorth Wealth Partners (CRD #284807) in St. Paul, MN, Wealth Covenant Group (CRD #291453) in Houston, TX., and Boston Financial Management (CRD #112360) (“BFM”) with offices in Boston, MA, Centerville, MA, and Portland, ME. CFG also acquired BFM’s wholly-owned subsidiary, Boston Fiduciary Services, LLC, which provides professional trustee and fiduciary services to individuals, businesses, and non-profit organizations. 2 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 3: Table of Contents Item 1: Cover Page .......................................................................................................................................................... 1 Item 2: Summary of Material Changes .................................................................................................................. 2 Item 3: Table of Contents ........................................................................................................................................... 3 Item 4: Advisory Business ..........................................................................................................................................4 Item 5: Fees and Compensation .............................................................................................................................. 7 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................... 9 Item 7: Types of Clients ............................................................................................................................................... 9 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................................................. 10 Item 9: Disciplinary Information .............................................................................................................................. 11 Item 10: Other Financial Industry Activities and Affiliations ...................................................................... 11 Item 11: Code of Ethics ............................................................................................................................................... 14 Item 12: Brokerage Practices ................................................................................................................................... 15 Item 13: Review of Accounts ................................................................................................................................... 15 Item 14: Client Referrals and Other Compensation ....................................................................................... 16 Item 15: Custody ........................................................................................................................................................... 17 Item 16: Investment Discretion ............................................................................................................................... 17 Item 17: Voting Client Securities ............................................................................................................................ 18 Item 18: Financial Information ................................................................................................................................. 18 3 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 4: Advisory Business Introduction CAPTRUST Financial Advisors, also known as CapFinancial Partners, LLC, (“CAPTRUST” or “Adviser”) was established in April 2003 and approved as a registered investment adviser in September 2003. The CapFinancial Group, LLC (“CFG”, a North Carolina limited liability company) owns just under 100% of CAPTRUST. Each of CapFinancial Holdings, Inc. and Halftime Holdings, LLC owns more than 25% of The CapFinancial Group, LLC. GTCR Fund XII B indirectly owns more than 25% of CAPTRUST through its ownership of Halftime Holdings, LLC. CAPTRUST is an investment adviser registered under the Investment Advisers Act of 1940 (the “Advisers Act”). CAPTRUST provides investment advisory services on either a “non- discretionary” basis or “discretionary” basis. With respect to ERISA qualified plans, CAPTRUST serves as a "fiduciary" as defined by §3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974 ("ERISA"); or if on a “discretionary” basis, CAPTRUST serves as an "investment manager" as defined by §3(38) of ERISA. CAPTRUST provides advisory services to institutional clients including, but not limited to, retirement plan sponsors, 401(k) plans, 403(b) plans, pensions, profit-sharing plans, non- qualified plans, endowments and foundations, religious organization, and other asset pools such as, corporations or other businesses not listed above (collectively referred to throughout this Brochure as “Client”). Under the Advisers Act, CAPTRUST renders continuous and regular investment supervisory services as a fiduciary to Clients. As of December 31, 2024, CAPTRUST managed a total of just under $1.1 trillion in total assets under management, comprised of just over $845 billion in nondiscretionary assets under advisement (primarily Institutional Client assets) and just over $237 billion in discretionary assets under advisement (Institutional and Wealth Client assets). CAPTRUST requires each Client to make a selection of services in writing as part of an investment advisory agreement (for example, a Consulting Services Agreement or “CSA”; a Retirement Plan Advisory Services Agreement or “RPASA”; an Advisory Services Agreement or “ASA”; or an Investment Advisory Agreement “IAA”, collectively referred to herein as “Agreement”), which sets forth the rights and obligations of CAPTRUST and the Client. Each Agreement is customized to state the negotiated fee. Retirement Plan Advisory Services Include, but are not limited to: ERISA 3(21) Investment Adviser Fiduciary Services (Non-Discretionary)  Development of Investment Policy Statement  Investment Performance Measurement & Analysis  Recommendations for Selecting & Monitoring the Plan’s Investments  Assistance with Plan Fiduciaries’ Selection & Management of Service Providers 4 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645   CAPTRUST At Work  CAPTRUST Advice Solutions (asset allocation model portfolios) ERISA 3(38) Investment Manager Fiduciary Services (Discretionary)  Development of Investment Policy Statement  Investment Performance Measurement & Analysis  Selecting & Monitoring the Plan’s Investments  Assistance with Plan Fiduciaries’ Selection & Management of Service Providers  CAPTRUST At Work  CAPTRUST Advice Solutions (asset allocation model portfolios) ERISA Non-Fiduciary Services  Assistance with Fiduciary Oversight & Committee Education  Additional Consulting Services  Employee Investment Education & Communication Nonqualified Plan Advisory Services (Non-Discretionary and Discretionary)  Plan Design  Plan Financing & Security  Plan Administration & Fee Benchmarking  Development of Investment Policy Statement  Investment Performance Measurement & Analysis  Selecting & Monitoring the Plan’s Investments  Employee Investment Education & Communication Endowments & Foundation Advisory Services include, but are not limited to:  Discretionary o Selecting & Monitoring Investments o Development of Investment Policy Statement o Investment Performance Measurement & Analysis  Nondiscretionary o Recommendations for Selecting & Monitoring Investments o Development of Investment Policy Statement o Investment Performance Measurement & Analysis  Non-Investment Related Advisory Services include but are not limited to: o Assistance with Oversight & Committee Education o Additional Consulting Services 5 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Religious Organizations Advisory Service include, but are not limited to:  Discretionary o Selecting & Monitoring Investments o Development of Investment Policy Statement o Investment Performance Measurement & Analysis  Nondiscretionary o Recommendations for Selecting & Monitoring Investments o Development of Investment Policy Statement o Investment Performance Measurement & Analysis  Non-Investment Related Advisory Services include but are not limited to: o Assistance with Oversight & Committee Education o Additional Consulting Services CAPTRUST Advice Solutions Some retirement plans offer CAPTRUST Advice Solutions to their plan participants. The plan sponsor decides how the plan will pay for these services for plan participants, but the plan participant elects whether to use the services or not. CAPTRUST Advice Solutions uses a third-party technology provider to gather personal information from the plan sponsor, the plan recordkeeper, and the plan participant, to calculate an appropriate asset allocation specifically for the plan participant. There are two types of Advice Solutions:  Blueprint Managed Advice is a discretionary advisory service using a third-party technology. CAPTRUST sends transaction instructions to the plan recordkeeper to implement the asset allocation for each enrolled participant.  Online Advice is a nondiscretionary, point-in-time, investment recommendation with respect to the allocation of the plan participant’s account. The plan participant decides whether to implement the investment recommendation. CAPTRUST At Work CAPTRUST At Work is a comprehensive financial wellness program designed to help employees achieve their personal financial goals and objectives through education, personalized advice, and ongoing support. Personalized investment advice is offered in a fiduciary capacity. Plan participants will exercise final decision-making authority and responsibility for the implementation of any recommendations made by CAPTRUST. The services may include, but are not limited to:  Access to live and on-demand webinars, workshops, and materials  Digital content and engagement 6 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645   One-on-one meetings with plan participants to provide personalized advice and/or guidance The plan sponsor decides how the plan will pay for CAPTRUST At Work services for plan participants, but the plan participant elects whether to use the services. Adviser may provide other services to plan participants when the services are independently contracted for or sought by participants, including financial planning and investment services. These other services will be performed separately from services to the plan, are not part of the Agreement with the plan sponsor but would be defined in a separate Agreement with the plan participant individually. Adviser may use data available under the Agreement with the plan sponsor in providing these services to participants. Alternative Investments Adviser offers advice on private placements and/or limited partnerships that are considered “alternative investments”, for example, limited partnerships that are known as a “fund of funds” (typically a fund of private funds). Adviser also offers advice on private equity funds that contain investments in equities, futures, options, and other securities. Any such recommendation will be made only when determined to be suitable and must be accompanied by or preceded by a prospectus or offering memorandum. In general, this type of advice is rendered to wealth clients or nonqualified plan or other institutional clients, not including defined contribution plans. In performing its services, CAPTRUST shall not be required to verify or audit the information received from the Client or from the Client’s other professionals and is expressly authorized to rely thereon. If requested by the Client, CAPTRUST shall recommend the services of other professionals for implementation purposes. The Client is under no obligation to engage the services of any such recommended professional. Item 5: Fees and Compensation CAPTRUST requires each Client to make a selection of services in writing as part of an Agreement, which sets forth the rights and obligations of CAPTRUST and the Client. Advisory fees are negotiated prior to the signing of the Agreement. The Agreement is then customized to state the negotiated fee, which, in general, is typically expressed as a percentage of total assets under advisement or can also be a flat fee. As summarized above, a Client may engage CAPTRUST on a discretionary or non-discretionary basis. In general, fees charged for investment advisory services are payable quarterly, in advance, and are based upon the market value of the Client’s assets on the last business day of the calendar quarter. Advisory fees are accounted for on a quarterly invoice in detail. Fees may be direct billed to the Client or to a third-party administrator (“TPA”) or custodian at the 7 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Client’s instruction. Fees for Clients engaging CAPTRUST in mid-quarter will be prorated and calculated on a per diem basis. Some Client portfolios include private equity and/or other private investments for which quarterly values lag for up to 60 days following a quarter-end. In those limited cases, CAPTRUST uses the latest valuation date available for purposes of computing investment advisory fees. CAPTRUST relies on the Client’s capital account statement (provided by the issuer or qualified custodian) for the values of such private investments. The Agreement will continue in effect until terminated by either party upon thirty (30) days written notice to the other party. However, if the Client has not received the CAPTRUST Form ADV Part 2 at least 48 hours prior to entering into the Agreement, the Client may terminate the Agreement within five business days of entering into the Agreement without penalty. If any advisory relationship terminates before the last day of a quarter, fees are prorated accordingly, and the Adviser will refund any unearned fees due to the Client. Flat/Fixed Fee Service: To the extent so engaged by the Client, the Adviser may charge a flat or fixed fee for investment advisory and consultation services. Flat/fixed fees are negotiable but generally range from $10,000 to $250,000 on an annual basis, depending upon the level and scope of the services required. Fixed fees are charged quarterly in advance, calculated on a per diem basis, upon the signing of an Agreement by the Client. Fees for Clients engaging Adviser mid-quarter will be prorated on a per diem basis. Occasionally advisory services will be quoted on an hourly or per diem basis. Some Clients who have assigned their advisory agreements to CAPTRUST in connection with an acquisition pay their advisory fees in arrears. But, in either case, the terms of the Agreement determine the fee arrangements. Broker of Record: Since inception, CAPTRUST has consistently and affirmatively acknowledged CAPTRUST’s role as a co-fiduciary (both publicly and by written contract with CAPTRUST Clients). CAPTRUST has a relatively small number of Clients who have chosen to name their Financial Advisor (“FA”), an investment adviser representative of CAPTRUST, as “broker of record” (“BOR”) in his/her capacity as registered representative of CAPTRUST’s affiliated broker-dealer CapFinancial Securities, LLC (“CFS”) for the purpose of capturing product revenue in order to reduce (or offset) contractually agreed upon and level investment advisory fees for the Client. Retirement plan Clients consider this a “value-added” service because it provides the Client flexibility in utilizing product fees to pay for plan expenses in the absence of a recordkeeper or another vendor-provided ERISA budget account. In cases where a retirement plan sponsor has elected to appoint a CAPTRUST FA as BOR, CFS may be compensated by general promotion, advertising, and distribution fees (“12b-1 fees”) in relation to purchases and sales of mutual fund shares in the retirement plan that is the subject of the Agreement. However, in accordance with the Agreement, these 12b-1 fees will be taken into account when calculating that plan’s advisory fee for service for a particular period and the typical fee reduced (or offset) by the 12b-1 fees received by CFS. CAPTRUST 8 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  tracks all 12b-1 or product revenue (by Client) that is actually received by CFS and offsets (reduces) advisory fees upon a quarterly invoice basis in accordance with the Agreement. Fees charged may be higher than otherwise available elsewhere. A portion of the fees charged by CAPTRUST for advisory services will be paid to investment advisory representatives employed by CAPTRUST. All fees described herein may be subject to negotiation depending on a range of factors including, but not limited to, plan size and overall range of services requested. CAPTRUST’s fees are exclusive of other related costs and expenses which shall be incurred by the Client. For example, Clients may incur certain charges imposed by custodians, brokers, and other third parties such as fees charged by managers, record-keeping/custodial fees, sales charges, redemption fees, wire transfer and electronic fund fees, and other fees and/or taxes. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to CAPTRUST’s fee, and CAPTRUST shall not receive any portion of these other fees or costs. Item 6: Performance-Based Fees and Side-By-Side Management In general, CAPTRUST does not charge performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a Client). Please see Item 10 – “Other Financial Industry Activities and Affiliations – Material Conflicts Regarding Private Funds” for a detailed explanation of conflicts in connection to the One Brick Select Private Credit Fund, LP and One Brick Select Private Credit Qualified Fund I, LP (collectively, the “One Brick Funds”) which invest in T. Rowe Price OHA Select Private Credit Fund (“OCredit”). Incentive fees earned by OCredit will be shared with investors in the One Brick Funds. CAPTRUST does not charge performance fees to the One Brick Funds, but indirectly participates in fees earned by OCredit. The assets in the One Brick Funds represent less than 0.006% of all Client assets. Item 7: Types of Clients CAPTRUST provides advisory services to institutional clients such as retirement plan sponsors, 401(k) plans, 403(b) plans, pensions, profit-sharing plans, non-qualified plans, or other institutional clients such as foundations, endowments; religious organization; and other asset pools such as, corporations or other businesses not listed above (collectively referred to throughout this Brochure as “Client”). In addition, CAPTRUST provides investment advisory services to individuals (“Wealth Clients”), on a continuous and regular basis, but those services are disclosed separately, in CAPTRUST’s Wealth Brochure and Wrap Fee Program Brochure (Appendix 1 to the Wealth Brochure). Adviser does not require a minimum account size but may impose a minimum annual consulting fee. Adviser retains the right to waive any minimums. 9 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Investment recommendations are based on an analysis of the Client’s specific needs and are drawn from research and analysis. Each Client’s needs are analyzed separately. For example, when analyzing a retirement plan, CAPTRUST pays particular attention to the limitations on the investment lineup as determined by the retirement plan documents, current service providers/platform and whether a plan’s current platform has an opened or closed architecture. In general, investment analysis methods may include fundamental analysis as well as quantitative and qualitative research on a given investment vehicle. Information for this analysis may be drawn from financial newspapers, magazines and databases, research materials prepared by others, annual reports, corporate filings and prospectuses. It is important to note that investing in securities involves certain risks that are borne by the investor. For any risks associated with investment company products, please refer to the prospectuses for additional details about these risks. CAPTRUST’s investment approach constantly keeps the risk of loss in mind. In general, risks associated with investing include, but are not limited to:  Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.  Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events.  Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.  Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities.  Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.  Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, treasury bills are highly liquid, while real estate properties are not. Some investments that might be utilized in select strategies, such as interval funds, employed by CAPTRUST carry liquidity risk. In some circumstances, Clients have had to wait several quarters or longer when requesting liquidity from the manager of interval funds in a CAPTRUST managed account.  Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. 10 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645   Concentration Risk: The probability of loss due to heavy exposure to a single investment, equity or issuer. Some investments utilized in recommended strategies carry a kind of concentration risk since Clients may own more than one fund managed by the same issuer; or Clients may be invested in several funds with similar strategies which poses a type of concentration risk.  Other Risk: CAPTRUST’s recommended strategies include the risks listed above as well as other risks that are more specifically associated with managers, strategies, funds, or instruments CAPTRUST selects or recommends. For example, some recommended managers use derivatives (such as options as a hedge) which pose special risks; others carry liquidity risk specific to underlying investments; additionally, some risk-based asset allocated models have a particular concentration risk because CAPTRUST may recommend a single manager, or a fund complex for a large portion model. Some recommended strategies include alternative investment strategies, or allocations to funds with limited or no prior history of operations. Each recommended manager discloses risks associated with investing in their funds separately (in their respective brochures and/or prospectuses). o Although CAPTRUST acknowledges that Clients are relying on CAPTRUST to manage portfolio risk, Clients are encouraged to read managers’ disclosure brochures, prospectuses and ask questions of FA, investment committee members or compliance team members. Please contact us at 919.870.6822 or send a message to compliance@captrust.com.  Private investment funds: Clients who are qualified to invest in private funds must acknowledge and accept the specific risk factors that are associated with investing in private funds. Private fund investments involve various risk factors, including, but not limited to, potential for complete loss of principal, illiquidity, and lack of transparency. Item 9: Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client or prospective client’s evaluation of CAPTRUST or the integrity of CAPTRUST’s management. Neither CAPTRUST management nor members of CAPTRUST’s investment committee have any reportable disciplinary history for this Item. Each FA who acts as a portfolio manager has a separate Form ADV Part 2B. Clients should refer to their FA’s Form ADV Part 2B for personal disciplinary information for that FA. Item 10: Other Financial Industry Activities and Affiliations CAPTRUST is affiliated by common ownership to CapFinancial Securities, LLC (“CFS”), a FINRA broker-dealer (Member SIPC). CAPTRUST does not manage any proprietary mutual funds. CFS, as an affiliated registered broker-dealer, provides individuals and institutions general securities investment services. Many investment adviser representatives with Adviser are simultaneously registered as CFS registered representatives. A CAPTRUST FA who focuses primarily on wealth advisory services generally spends less than 10% of their time on work done for Wealth Clients focused on activities consistent with the definition of broker-dealer 11 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  activities. A CAPTRUST FA whose focus is Institutional Clients will generally spend less than 1% of their time on broker-dealer activities. CAPTRUST divisions called “1776 Advisor Group,” “Strategic Advisor Group,” and “Family Office Risk Advisors” along with several CAPTRUST FAs, are life insurance licensed in order to act as agent of record for those Clients who own life insurance products or for retirement plans funded with group variable products. CAPTRUST FAs may occasionally recommend fixed or variable annuities or life insurance (including Private Placement Life Insurance (“PPLI”)) to their Wealth Clients when assisting them in executing their financial plan. CFS and CAPTRUST have business entity insurance licenses. Strategic Advisor Group’s primary source of revenue is life insurance commissions not involving CAPTRUST qualified retirement plan clients. As a result of certain investment-related recommendations provided to its Clients, CFS may facilitate certain securities purchases and sales, or insurance product purchases and sales on behalf of CAPTRUST Clients. Such transactions may be facilitated by CFS, in its capacity as a registered broker-dealer or insurance agent/agency (business entity). Commissions charged by CFS may be higher or lower than obtainable elsewhere. All related compensation is separate from advisory services. In general, product revenue associated with plan Client assets is captured to reduce the plan advisory fee pursuant to the terms of the Retirement Plan Advisory Services Agreement. In the fourth quarter of 2024, CFG acquired the assets of four different firms: Campbell Wealth Management (CRD #152956) in Alexandria, VA, TruNorth Wealth Partners (CRD #284807) in St. Paul, MN, Wealth Covenant Group (CRD #291453) in Houston, TX., and Boston Financial Management (CRD #112360) (“BFM”) with offices in Boston, MA, Centerville, MA, and Portland, ME. CFG also acquired BFM’s wholly-owned subsidiary, Boston Fiduciary Services, LLC, which provides professional trustee and fiduciary services to individuals, businesses, and non-profit organizations. Material Conflicts Regarding Private Funds CAPTRUST provides investment recommendations and advice regarding both affiliated and non-affiliated private investment funds. CAPTRUST provides the fund’s offering materials at or prior to recommending the investment. Please refer to the fund’s confidential offering memorandum for applicable disclosures regarding management of the fund, its investment objective, risk factors, tax, and related factors. One Brick. CAPTRUST serves as investment advisor to One Brick Select Private Equity 2024, L.P. CAIS One Brick Select Private Equity 2024 GP LLC, an unaffiliated entity, serves as general partner. CAPTRUST also serves as investment advisor to One Brick Select Private Credit Fund, LP and One Brick Select Private Credit Qualified Fund I, LP (the “One Brick Funds”) for which PPB Capital Partners ("PPB") serves as general partner and fund administrator. The One Brick Funds invest in T. Rowe Price OHA Select Private Credit Fund (“OCredit”). OHA Private Credit Advisors LLC (“OHA Advisor”) is the investment adviser to OCredit. OCredit pays OHA Advisor an incentive fee for serving as its investment manager. As more people invest in OCredit, OHA Advisor will earn more fees. One Brick Funds will also 12 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  share in those incentive fees, which creates an incentive for CAPTRUST to recommend OCredit in order to increase the potential profits eligible to be shared with investors in the One Brick Funds, which include CAPTRUST Clients and employees.  (Please see Item 6.) The One Brick Funds pay nominal fees to PPB for fund administration as well as 10bps/year in advisory fees to CAPTRUST.  Homecourt. CAPTRUST is the owner of “CAPTRUST 2022 Homecourt Fund GP, LLC” (s Delaware single member limited liability company), for which the sole purpose was the organization of a private fund called “CAPTRUST 2022 Homecourt Fund, L.P.” (“Homecourt”). Homecourt was formed as an “Access Fund” into Dyal HomeCourt US Investors LP (“Dyal”), and independent third party private limited partnership. CAPTRUST acts as the investment adviser to Homecourt. The interests were offered pursuant to an exemption from the registration requirements of the Securities Act of 1933, as amended (the “Securities Act”). Each investor must be a U.S. person with the requisite skill and expertise to adequately assess the risks of investing in the Access Fund (and indirectly investing in the underlying fund); an “accredited investor” as defined within the meaning of Rule 501(a) of Regulation D promulgated under the Securities Act; a “qualified purchaser” as defined under the Investment Company Act, and a “qualified client,” as defined under the U.S. Investment Advisers Act of 1940, as amended, and the rules and regulations promulgated thereunder (the “Advisers Act”). There is no public market for the interests, and no such market is expected to develop in the future. CAPTRUST’s “Management Fee Rate” is 0.10% per annum (e.g. 0.025% per quarter) for limited partners who are Clients and 1.00% per annum (e.g. 0.25% per quarter) for limited partners who are no longer Clients. MRA. CAPTRUST acts as investment adviser to a series of private funds, namely, MR Investment Fund 1 LLC, MRA Opportunities Fund 1-A, MRA Opportunities Fund 1-B, MRA Credit Strategies Fund 1-A Fund LP, and MRA Credit Strategies Fund 1-B Fund LP. SALI. CAPTRUST acts as subadvisor to three private funds, Covenant Global Equities Fund Series Interests of the SALI Multi-Series Fund II 3(c)(1), LP, Covenant Global Equities Fund Series Interests, and Vega Multi-Strategy Fund Series of the SALI Multi-Series Fund, L.P., for which SALI Fund Services acts as investment advisor and fund administrator. TRUSTCORE. CAPTRUST acts as subadvisor to Trustcore Private Opportunities Fund, LP for which PPB Advisors acts as investment advisor and NAV Consulting provides fund administration. RINET. CAPTRUST and RINET Company, LLC entered into a limited (administrative) services agreement whereby CAPTRUST will assist RINET in winding down four private funds RINET manages. 13 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 11: Code of Ethics CAPTRUST’s Code of Ethics addresses, among other things: (i) general principles that address CAPTRUST’s fiduciary obligations to its Clients, (ii) personal securities trading procedures restricting the purchase and sale, by access persons for their own accounts, of specific securities; (iii) provisions relating to the confidentiality of Client information; (iv) a prohibition on insider trading; (v) limits on political contributions; and (vi) and restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment. Personal transactions in securities by directors, officers, and employees of CAPTRUST who have access to nonpublic information regarding Clients’ purchase and sale of securities, are involved in making securities recommendations to Clients or who have access to such non- public recommendations (“access persons”) are subject to the restrictions and procedures in CAPTRUST’s Code of Ethics. All employees at CAPTRUST must acknowledge the terms of the Code of Ethics annually, or as amended. Occasionally, access persons of Adviser may recommend that Clients buy or sell the same securities or investment products that access persons of the Adviser also own. CAPTRUST’s employees and persons associated with CAPTRUST are required to follow the Code of Ethics. The Code of Ethics is intended to identify and address potential conflicts of interest that might arise in the context of personal securities transactions, activities, and interests of the employees of CAPTRUST that might interfere or appear to interfere with making decisions in the best interest of advisory Clients. Under the Code of Ethics certain classes of securities have been designated as exempt transactions, based upon a determination that they would not materially interfere with the best interest of CAPTRUST’s Clients. In addition, the Code of Ethics requires pre-approval of specific types of transactions, and, depending on the transaction, may restrict trading in close proximity to Client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as Clients, there is a possibility that employees might benefit from market activity by a Client. Employee trading is monitored under the Code of Ethics to reasonably prevent conflicts of interest between CAPTRUST and its Clients. CAPTRUST employees whose accounts are managed by CAPTRUST are included in block trading where CAPTRUST places trades for execution that include accounts of two or more Clients when CAPTRUST believes trade aggregation is appropriate and in the best interest of its Clients. CAPTRUST’s Clients may request a copy of the firm's Code of Ethics by contacting the Compliance Department at compliance@captrust.com or by calling 919. 870.6822 or 800 .967.9948. 14 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 12: Brokerage Practices CAPTRUST is required to describe the factors considered in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). When CAPTRUST is engaged with a Client through a non- discretionary Agreement, Client assets are held at various third-party custodians that have not been recommended by CAPTRUST and for which CAPTRUST has no interest or conflict to disclose. Please see Item 5: Fees and Compensation – Broker of Record for information about how CAPTRUST mitigates the potential conflict arising when Clients choose to name their FA as BOR in their capacity as registered representative of CFS. Brokerage Practices affecting Wealth Clients (including nonretirement plan clients such as foundations endowments, and other institutional clients) and Institutional Clients who have granted CAPTRUST discretionary authority are separately disclosed in the CAPTRUST Wealth Brochure and Appendix 1, which are disclosed separately (please see CAPTRUST Wealth Brochure which can be found here: https://www.captrust.com/important-disclosures/). Some Clients may use Bank of New York or an affiliate as a platform/custodian for their plan assets. Therefore, it is material to disclose that as a broker-dealer, CFS has an existing relationship with Pershing, LLC (“Pershing”), an affiliate of Bank of NY, in the form of a clearing agreement. Item 13: Review of Accounts Client accounts are advised by their FA who is responsible for performing periodic reviews and consulting with the respective Client. Additionally, investment company assets in plans are monitored on a continuous and regular basis by CAPTRUST Investment Group as well as CAPTRUST Consulting Solutions Group (“CSG”). Clients who are under an Agreement receive quarterly reviews produced by CAPTRUST for each plan. Ongoing reviews of markets, sectors and individual securities are conducted by the Investment Group. Unaffiliated mutual fund holdings and outside Investment Managers are monitored on a continuous and regular basis by the CAPTRUST Investment Group. Michael Vogelzang, Chief Investment Officer, heads up the Investment Group. ADV Part 2B (attached at end of document) lists the members of the Investment Group who are also members of the Investment Committee or who are involved in the review process and in determining the investment advice to be given by the Adviser. Additionally, monthly and quarterly statements are provided by the Client’s custodian, but additional reports may be provided by third party administrators or other service providers employed by the Client. Clients with portfolios that include private equity and/or other private investments (“private funds”) should be advised that quarterly values lag for up to 60 days following a quarter-end. Because CAPTRUST relies on the Client’s capital account statement (provided by the issuer or qualified custodian) for private fund values used for purposes of quarterly review reports will reflect the latest valuation date available. Consequently, a Client’s actual private fund holdings could be significantly more or less than the value reflected in their CAPTRUST quarterly review report. 15 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Clients agree to inform CAPTRUST in writing of any material changes to the Client’s financial circumstances that may affect advice being rendered to the Client. Clients may contact the Adviser during normal business hours to consult with the firm concerning any such material changes. Item 14: Client Referrals and Other Compensation Clients (or prospective Clients) who are being referred to CAPTRUST, either by means of a paid “endorsement” by a third-party or in connection with a paid “testimonial” by a current Client, must be made aware of the arrangement at the time the testimonial or endorsement is disseminated in a clear and prominent manner. The disclosure of the arrangement must explain whether the testimonial was given by a current Client or investor; or if the “endorsement” was given by a person other than a current Client or investor; explain whether cash or non-cash compensation was provided for the testimonial or endorsement; and if applicable, include brief statement of any material conflicts of interest on the part of the person giving the testimonial or endorsement resulting from the investment adviser's relationship with such person. In cases where a referral takes place in person, these required disclosures will be delivered in writing at the time the testimonial or endorsement is being made. CAPTRUST, has entered into referral agreements with various third-party solicitors (“Solicitors”) for Client referrals. In order for a Solicitor to be compensated by CAPTRUST for referring a Client to CAPTRUST, the solicitor must be engaged by CAPTRUST under a Solicitor or Referral Agreement (a “Referral Agreement”) in compliance with Section 206(4)-1 of the Investment Advisers Act of 1940. In general, a Solicitor is compensated by a percentage of the advisory fee collected for a specified period of time (as detailed in the Referral Agreement). Clients pay no additional fee for the referral over and above CAPTRUST’s quoted advisory fee; to the contrary, the fee the Adviser earns is reduced by the amount of the compensation to the Solicitor. Each Referral Agreement requires the Solicitor to deliver the required disclosures either in writing or via the internet at the time of the testimonial or endorsement is made. CAPTRUST participates in referral programs in which those institutional advisory platform providers to refer Wealth Clients to a CAPTRUST FA who participates in their program. In exchange for those referrals, a portion of the CAPTRUST advisory fee is paid to the referrer. Beginning in 2025, CAPTRUST will participate in a referral program from Empower Advisory Group, LLC (“EAG”), an affiliate of the institutional recordkeeper Empower. As part of this program, EAG will refer to CAPTRUST terminated plan participants who meet certain criteria and who have indicated an interest in speaking with an investment adviser. EAG will only refer terminated plan participants in plans for which the plan sponsor has consented to such a referral program. Plans from which EAG might refer terminated plan participants will generally be retirement plans for which CAPTRUST serves as the investment adviser, but EAG may choose to include plans for which CAPTRUST does not serve as the investment adviser. In exchange for these referrals, CAPTRUST will pay EAG a fee equal to 25% of all advisory and non-advisory revenue actually received by CAPTRUST from the referred Client. CAPTRUST 16 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  will work with EAG to make all disclosures required under Section 206(4)-1 of the Investment Advisers Act of 1940, as amended, at the time of the endorsement. Clients may request details regarding a particular Referral Agreement by contacting us toll- free at (800)216-0645 or sending an email to compliance@captrust.com. Item 15: Custody Clients should receive statements at least quarterly from the qualified custodian that holds and maintains the Client’s investment assets. CAPTRUST urges Clients to carefully review such statements and compare the official custodial records to any reports provided by CAPTRUST. CAPTRUST reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. CAPTRUST does not act as a qualified custodian for Client assets. CAPTRUST discloses in Item 9 of Form ADV Part 1 that it has custody of Clients’ funds or assets for certain purposes (e.g., where a Wealth Client has granted an FA the ability to access the Client’s assets). CAPTRUST is subject to an annual surprise custody examination by an independent certified public accounting firm. Item 16: Investment Discretion For certain CAPTRUST Clients, Adviser has the authority to determine, without obtaining specific Client consent, both the securities to be bought and sold in their accounts as well as the amount of the securities to be bought or sold. The discretionary Agreement covering an ERISA qualified retirement plan gives CAPTRUST the authority to take discretion over the investment selection in that retirement plan. This service elevates CAPTRUST’s fiduciary role to that of an ERISA 3(38) “investment manager” (i.e., when the Client’s retirement plan is subject to ERISA). CAPTRUST acts as a subadvisor with respect to Managed Account Portfolios (“MAPs”) that are collective investment trusts (“CITs”) for which Wilmington Trust (now “Great Gray Trust”) acts as investment manager. Some Clients may grant CAPTRUST ERISA 3(38) discretion over the investment line-up available inside their retirement plan which may also include the MAPs as available investment options for plan participants to select. However, Clients engaging CAPTRUST for non-discretionary ERISA 3(21) advisory services may utilize MAPS as well. CAPTRUST’s separate CAPTRUST Wealth Brochure discloses the level of authority and discretion CAPTRUST is granted, in general, for its Wealth Clients. Adviser may have the authority to negotiate fees on behalf of the Client with its other service providers. Specifically, in its efforts to perform requests for proposals (“RFPs”) on behalf of Clients, Adviser assists the Client in determining the most suitable fee for services structure that can be obtained within the constraints of the retirement plan documents. However, CAPTRUST does not have any control over the fees or commissions charged by custodians or 17 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  investment companies for the products or services they provide. Consequently, the Client may pay fees or commissions higher than obtainable elsewhere for similar products or services. Item 17: Voting Client Securities In general, CAPTRUST Clients delegate the authority to vote their proxies to CAPTRUST in their Agreement. It is CAPTRUST’s aim to see that proxies are voted in the best interest of its Clients. As such, CAPTRUST has engaged Institutional Shareholder Services Inc. (“ISS”), to vote proxies on behalf of Clients who delegate their proxy voting rights to CAPTRUST. ISS is an independent proxy voting service provider, which performs extensive research, and has designed and maintains a number of proxy voting guidelines. While Clients are always free to vote their own proxies, for those that delegate that responsibility to CAPTRUST, CAPTRUST generally leverages ISS Benchmark Proxy Voting Guidelines (“Guidelines”). The Guidelines are based on widely accepted good governance practices and principles, are designed to be responsive to the wide range of issues that can be raised in proxy situations, and to increase total shareholder value and risk mitigation. Additionally, Clients may revoke their delegation of proxy voting authority at any time, with written notice to CAPTRUST. The Proxy Voting Policy contains additional guidelines and methods by which conflicts of interests are addressed. Such conflict may include situations where CAPTRUST has or is seeking a client relationship with the issuer of the security that is the subject of the proxy vote. Generally, because the Guidelines pre-establish voting positions, application should adequately address any possible conflicts of interest. Please note, Freedom401(k) Clients retain the right to vote proxies, so although CAPTRUST has investment discretion, CAPTRUST, generally, does not vote proxies on behalf of Freedom401(k) Clients. To obtain a copy of CAPTRUST’s Proxy Voting Policy or for a copy of CAPTRUST’s Proxy Voting record, Clients can contact CAPTRUST directly at: 800.216.0645 or 919.870.6822 or may email IG.Investment.Admin@captrust.com or write to CAPTRUST “Investment Administration” ” to obtain the information at the address below: CAPTRUST Investment Administration 4208 Six Forks Road, Suite 1700 Raleigh, NC, 27609. Item 18: Financial Information Registered Investment Advisers are required to provide Clients with certain financial information or disclosures about the investment adviser’s financial condition. CAPTRUST has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of any bankruptcy proceedings. Important Disclosures About CAPTRUST’s Privacy Policy and Business Continuity Plan can be found on the CAPTRUST internet site by navigating to: 18 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645   Business Continuity Plan: https://www.captrust.com/business-continuity-plan  Privacy Policy: https://www.captrust.com/privacy-policy/ 19 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645 

Item 1: Cover Page March 18, 2025 CAPTRUST Financial Advisors 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 Phone: 919.870.6822 Toll Free: 800.216.0645 compliance@captrust.com Appendix 1 to Part 2A CAPTRUST Wealth Brochure | CAPTRUST Wrap Fee Programs Brochure This CAPTRUST Wrap Fee Programs Brochure (“Wrap Brochure”) provides information about the qualifications and business practices of CAPTRUST Financial Advisors. If you have any questions about the contents of this Brochure, please contact us by phone at 919.870.6822 or toll-free at 800.216.0645 or by email at compliance@captrust.com. 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. CAPTRUST Financial Advisors, also known as CapFinancial Partners, LLC (“CAPTRUST” or “Adviser”) is an investment adviser registered under the Investment Advisers Act of 1940. Registration does not imply any level of skill or training. Additional information about CAPTRUST Financial Advisors also is available on the SEC’s website at www.adviserinfo.sec.gov. 1 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 2: Summary of Material Changes This Summary of Material Changes reflects only material changes to this Brochure since our last annual update of this brochure which was dated March 28, 2024. Item 9: Other Financial Industry Activities and Affiliations Item 9 has been amended to disclose the following acquisition activity: In the fourth quarter of 2024, CFG acquired the assets of four different firms: Campbell Wealth Management (CRD #152956) in Alexandria, VA, TruNorth Wealth Partners (CRD #284807) in St. Paul, MN, Wealth Covenant Group (CRD #291453) in Houston, TX., and Boston Financial Management (CRD #112360) (“BFM”) with offices in Boston, MA, Centerville, MA, and Portland, ME. CFG also acquired BFM’s wholly-owned subsidiary, Boston Fiduciary Services, LLC, which provides professional trustee and fiduciary services to individuals, businesses, and non-profit organizations. 2 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 3: Table of Contents Item 1: Cover Page ............................................................................................................................. 1 Item 2: Summary of Material Changes ................................................................................................. 2 Item 3: Table of Contents .................................................................................................................... 3 Item 4: Services, Fees, and Compensation .......................................................................................... 4 Item 5: Account Requirements and Types of Clients ............................................................................ 9 Item 6: Portfolio Manager Selection and Evaluation ............................................................................. 9 Item 7: Client Information Provided to Portfolio Managers ................................................................. 12 Item 8: Client Contact with Portfolio Managers .................................................................................. 12 Item 9: Additional Information .......................................................................................................... 13 3 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 4: Services, Fees, and Compensation Types of Advisory Services CAPTRUST wrap fee programs (“Wrap Fee Programs” or “Programs”) are designed to assist clients, both wealthy individuals and institutions (such as corporations, trusts, estates, charitable organizations, and other business entities) (each a “Client”), to identify their investment needs and to obtain professional asset / portfolio management for a convenient single "wrap" fee. Wrap fees include both asset/portfolio management and the cost of execution (ticket charges). CAPTRUST is the “Program Sponsor” of the Wrap Fee Programs discussed in this Brochure. Wrap Fee Programs may be offered through portfolio management account (“PMA”) services, in which CAPTRUST provides PMA services, or separately managed account (“SMA”) services, in which CAPTRUST recommends and the Client selects a third-party manager. Other investment advisory services include:  Portfolio management on a non-wrap fee basis—where investment advisory/portfolio management fees do not include the cost of execution;  Business, financial and/or estate planning;  Institutional and retirement plan advisory and/or consulting services;  Participant Advisory Services; and other services disclosed separately Please see disclosure brochures for CAPTRUST’s wealth and institutional advisory services at: https://www.captrust.com/important-disclosures/ or you may request information at the contact information in Item 1. CAPTRUST Clients choose the brokerage platform to hold their investment accounts. CAPTRUST has prime broker and/or brokerage custody agreements to provide execution, brokerage, and custodial account services to Clients with Charles Schwab & Co., Inc. (‘Schwab”); Pershing Advisor Solutions, LLC through Pershing, LLC (“Pershing”); and Fidelity Investments through Fidelity Brokerage Services, LLC/National Financial, LLC (“Fidelity”). Regardless of which brokerage platform or Program Clients select, Clients will retain the right to: (1) withdraw securities or cash; (2) vote on shareholder proposals of beneficially owned security issues, or delegate the authority to vote on shareholder proposals to CAPTRUST or to another person; (3) be provided in a timely manner with a written confirmation or other notification of each securities transaction, and all other documents required by law to be provided to security holders; and (4) proceed directly as a security holder against the issuer of any security in the Client’s account. Client Investment Process. The CAPTRUST Financial Advisor (“FA”) assists the Client in determining their investment goals and objectives (“IGO”) before selecting and recommending an investment style, allocation and/or a diversified portfolio of investments, including investment vehicles and/or independent investment managers (“Investment Managers”) appropriate for the Client. This is done both initially and on an on-going basis. The FA collects financial and personal information from the Client, assists the Client in establishing Client’s IGO and strategies, and evaluates the suitability of products for the Client. The FA 4 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  recommends investments and/or Investment Managers to the Client. See Item 6 for the Investment Manager selection and portfolio management process. PMA Services and Wrap Fee Programs Description of Program. PMA or CAPTRUST Wrap Fee Program accounts (also referred to as “Wrap Advisory Services” or “WAS”) can be set up on either a discretionary basis or a non- discretionary basis and the PMA or WAS portfolio manager (“Portfolio Manager”) will be either: (1) the Investment Committee, comprised of members of CAPTRUST’s Investment Group (“Investment Group”), and described in Appendix 1 to CAPTRUST’s Wealth Brochure or (2) the Client’s CAPTRUST FA. CAPTRUST uses both a risk-based and outcome-based approach to asset allocation and allocates the following asset classes across Client portfolios: US equities, international equities, fixed income, alternative investments, commodities and real estate. When managing PMA or WAS portfolios on a discretionary basis, the Client’s Portfolio Manager makes changes in the Client’s account, including any of the investment selections (for example, opened-end or closed-end mutual funds/ETFs, stocks, bonds, or cash) or allocations to a CAPTRUST managed investment model allocation, without obtaining the Client’s consent prior to making those changes. For example, the Portfolio Manager may determine changes to the portfolio are advisable if an investment selection no longer meets the Client’s IGO, or if a mutual fund experiences a fundamental change in management which would mandate a replacement of that fund, or if such changes are otherwise in the Client’s best interest. Under those conditions, the Portfolio Manager can replace an investment selection without consulting with the Client first. When managing PMA or WAS portfolios on a non-discretionary basis, the Client’s Portfolio Manager must be the Client’s FA (and not the Investment Committee) because the FA must first make a recommendation before implementing changes in the Client’s investment portfolio. In this case, before changing any of the investment selections, the FA would obtain the Client’s consent. Regardless of whether the wrap fee account is discretionary or non-discretionary, the Client can elect to change investment selections or make reasonable modifications to their investment portfolio at any time by sending written notice to the FA. CAPTRUST Clients may have more than one wrap fee account, such as a nondiscretionary PMA where the FA is the Portfolio Manager, and a PMA where the Investment Committee acts as Portfolio Manager and allocates to strategic asset allocated investment models. Services provided in Wrap Fee Programs Include:  Establishing investment strategies through the documentation of a Client’s IGO as outlined by the Client and their FA;  Determining asset allocation strategies to meet the financial goals of the Client;  Determining specific investment style allocations;  Identifying tax optimization strategies; 5 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645   Researching and evaluating investment management firms, their mutual funds, exchange traded funds (“ETFs”), collective trusts, and other investment vehicles appropriate for the Client’s investment portfolio;  Identifying specific independent, unaffiliated money management firms appropriate for the Client’s investment portfolio;  Hiring independent money management firms on behalf of the Client;  Reporting and reviewing the performance of money management firms and other investment vehicles;  Performing quarterly investment reviews;  Periodic rebalancing and investment plan re-allocating Client’s investment portfolio  Acting as the Portfolio Manager; and  Providing investment consulting services not related to managed account services Fees for PMA and WAS. The maximum annual fees for CAPTRUST’s Wrap Fee Programs are: Assets Under Management First $1mill Next $4mil Maximum Fee Rate Up to 2.25% Up to 1.75% Above $5mill Up to 1.25% SMA Wrap Fee Program Description of Program. Each account in the SMA Wrap Fee Program (“SMA Program”) is a discretionary account where each selected SMA Investment Manager (“SMA Manager”) implements changes to the Client’s investment portfolio without obtaining the Client’s prior consent to those changes. The minimum initial investment for participation in this CAPTRUST Program is typically $100,000 or more and varies from one SMA Manager to the next. CAPTRUST has limited investment discretion with respect to the Client’s securities in the SMA Program. Rather, the SMA Manager selected by the Client is granted investment discretion by the Client and exercises this authority in the day-to-day portfolio management of the Client’s accounts. In accordance with the Client’s IGO and the asset classes in their investment portfolio, CAPTRUST recommends certain SMA Managers for each asset class and based on an SMA Manager’s investment style. Under this model, CAPTRUST uses strategic asset allocation and Investment Manager recommendations based on CAPTRUST’s research and forward-looking views. Applying its strategic investment models that vary according to varying risk levels, CAPTRUST recommends an SMA Manager by asset class. The Client, however, selects the particular SMA Manager(s) for its accounts. The Client can elect to change SMA Managers at any time. CAPTRUST does have the discretion to change the Client’s SMA Manager but an SMA Manager will generally not be removed or replaced by CAPTRUST without the Client’s knowledge. However, if the Client is not otherwise available and CAPTRUST’s Investment Committee or the Client’s CAPTRUST 6 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  FA deems it advisable to do so, CAPTRUST will exercise the right to remove or replace an SMA Manager without the Client’s prior consent. In such a case, CAPTRUST will promptly advise the Client of each such change. Examples would be where the Client’s financial circumstances change or economic or market conditions change, or, if in CAPTRUST’s opinion, a selected SMA Manager no longer meets the Client’s IGO or no longer manages according to its stated investment style parameters or there is a fundamental change in the management of the SMA Manager which would mandate a switch. The Client may override CAPTRUST’s suggestions as to SMA Managers or investment vehicles, in whole or in part. Investments/Strategies. Most SMA Managers in the SMA Program use long-only equity and/or fixed income strategies. Some SMA Managers sell covered calls. Occasionally, CAPTRUST recommends an SMA Manager for the SMA Program that shorts securities, uses options, futures, and other derivatives/securities, or employs more sophisticated trading techniques, but only if deemed suitable for a particular Client who is a sophisticated investor. SMA Manager Reviews. Performance of SMA Managers is monitored on a quarterly basis by members of the Investment Group. The Investment Group monitors each recommended SMA Manager in the SMA Program for performance against its peers, the stated benchmark, and for adherence to its stated strategy. The Investment Group requests quarterly due diligence questionnaires from each SMA Manager for consideration by the Investment Group in its analyses. Performance of SMAs is calculated from several different sources. The actual performance of an individual SMA that is reported to a Client is calculated by CAPTRUST’s performance reporting team. Fees for SMA Wrap-Fee Services. The maximum annual fees for CAPTRUST’s SMA Program are: SMA Accounts: Fixed Income Assets under management Manager & Platform Fee Minimum Manager & Platform Fee Maximum CAPTRUST Maximum Fee First $1mill 0.35% 0.65% Up to 2.25% Next $4mill 0.25% 0.55% Up to 1.75% Over $5mill 0.20% 0.50% Up to 1.25% SMA Accounts: Equity Assets under management Manager & Platform Fee Minimum Manager & Platform Fee Maximum CAPTRUST Maximum Fee First $1mill 0.60% 1.00% Up to 2.25% Next $4mill 0.45% 0.85% Up to 1.75% Over $5mill 0.40% 0.80% Up to 1.25% 7 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Negotiability of Fees CAPTRUST fees and services are negotiable and may be reduced or waived under certain circumstances. For example, Adviser, in its sole discretion, may charge a lesser (or no) advisory fee based upon certain criteria, including but not limited to.  Existing financial planning client relationship;  Anticipated future earning capacity;  Anticipated future additional assets;  Dollar amount of assets to be managed;  Related accounts, account composition; and  Negotiations with Client Other Important Factors to Consider Wrap fees paid to CAPTRUST are exclusive of and distinct from the fees and expenses charged by mutual funds, ETFs, or other investment pools to their shareholders (generally including a management fee and fund expenses, as described in each fund’s prospectus or offering materials). Clients also pay certain fees to their custodian, such as margin interest, check fees, fees for trades executed away from custodian, odd lot differentials, mark- up/mark-downs (spreads), and other similar types of fees, as more fully described in CAPTRUST Wealth Brochure. Costs and fees that CAPTRUST does not have to pay to third parties in connection with transaction and execution expenses are retained by CAPTRUST, therefore CAPTRUST has an incentive to limit trade securities in the accounts of Clients in the Program. Schwab has eliminated commissions for online trades of equities and ETFs. Similarly, Fidelity and Pershing have also eliminated commissions on online trades of equities and ETFs. This means that, in most cases, when CAPTRUST buys and sells these types of securities, CAPTRUST does not have to pay any commissions to the custodian of the Client’s account. Clients are encouraged to review their custodian’s pricing to compare the total costs of entering a wrap fee arrangement versus a non-wrap fee arrangement. If a Client chooses to enter into a wrap fee arrangement, the total cost to invest could exceed the cost of paying for brokerage and advisory services separately. CAPTRUST encourages Clients to review the pricing schedules of their respective custodians for fees charged in non-wrap fee accounts. Schwab’s pricing schedules are available at https://www.schwab.com/legal/schwab-pricing-guide-for-advisor-services. For fee schedules for Fidelity or Pershing, please send a request to compliance@captrust.com. Clients should review all fees charged by funds, CAPTRUST, and other third-party providers to fully understand the total amount of fees paid by the Client for investment and financial- related services. Clients participating in a CAPTRUST Wrap Fee Program may pay higher or lower fees than Clients purchasing such services separately, depending on the cost of services if provided separately and the level of trading in a particular Client’s account. Clients 8 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  should contact compliance@captrust.com with any questions on this or any other information in this Brochure. Item 5: Account Requirements and Types of Clients Types of Clients. CAPTRUST provides investment advisory services to Client types that include individuals, high net worth individuals, pensions, profit-sharing plans, trusts, estates, charitable organizations, foundations, endowments, and corporations. Minimums. In general, CAPTRUST maintains a minimum account size requirement for its PMA Program Clients of $50,000 to initially establish an account. The value of this account is subject to fluctuation, and therefore there is not a minimum maintenance requirement. Adviser retains the right to waive minimum initial account sizes should Adviser feel it is necessary. CAPTRUST does not generally impose a minimum portfolio value for participation in the WAS Wrap Fee Program. For SMA Program accounts, the minimum initial investment for participation is typically $100,000 or more and varies from one SMA Manager to the next. Clients should review their SMA Manager’s Form ADV Part 2 Disclosure Brochure for a detailed disclosure of their SMA Manager’s fees, services, and minimums. Clients should reach out to their FA for more information on the SMA Manager. Item 6: Portfolio Manager Selection and Evaluation PMA and WAS Wrap Program accounts are designed primarily to simplify the payment of management fees and brokerage expenses for Clients. As noted in Item 4 above, Portfolio Managers for those accounts can be either CAPTRUST’s Investment Committee or the Client’s CAPTRUST FA. The Investment Committee manages several risk-based and outcomes-based model strategies using individual equities, bonds, independent third-party mutual funds, ETFs, and alternatives, such as registered closed-end funds. Mutual funds and ETFs are managed by third party Investment Managers. CAPTRUST evaluates Investment Managers’ investment strategies including mutual funds, indexes, or other managed investment vehicles that may be included in one or more of CAPTRUST’s model strategies to which a PMA or WAS account may be allocated. The Investment Committee employs a multi-step process in screening the underlying Investment Managers to determine if they are suitable for the CAPTRUST Wrap Fee Programs. Ongoing due diligence is performed on the underlying managers, including quarterly due diligence questionnaires and analysis. The Investment Committee monitors the performance of underlying managers against appropriate benchmarks and the Investment Committee uses its discretion to replace underlying managers who do not meet the Investment Committee’s rigorous standards. 9 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Methods of Analysis, Investment Strategies, and Risk of Loss Investment strategies. CAPTRUST’s investment strategies begin with an understanding of a Client’s IGO. FAs use demographic and financial information provided by the Client to assess the Client’s risk profile and investment objectives in determining an appropriate strategy for the Client’s assets. Investment strategies generally include long- or short-term purchases of stock portfolios, mutual funds and fixed income securities and may include margin transactions and options strategies. CAPTRUST utilizes both a risk-based and outcomes- based approach to asset allocation. The following asset classes are allocated across Client portfolios: US equities, international equities, fixed income, alternative investments, commodities and real estate. CAPTRUST FAs may recommend a combination of our risk-based and outcomes-based models managed by CAPTRUST’s Investment Committee. The Investment Committee is composed of members of CAPTRUST’s Investment Group. Investment Managers. CAPTRUST’s Investment Group researches Investment Managers using proprietary screening and evaluation of registered investment companies (such as mutual funds) and their portfolio managers, other managed investment vehicles, and SMA Managers. CAPTRUST employs a multi-step process in screening the Investment Managers to determine if they are suitable for its SMA Programs. Each Investment Manager is evaluated based on extensive information provided by that Investment Manager, including descriptions of its investment process, investment strategies employed, operational structure, and its Form ADV, Part 2 and/or its mutual fund prospectus. CAPTRUST then attempts to verify that information by comparing it to other data from publicly available data collection sources. During this process, CAPTRUST also employs proprietary technical quantitative and qualitative analyses. CAPTRUST also evaluates certain investment strategies including mutual funds, indexes, or other managed investment vehicles which may be included in an overall asset allocation for Wealth Clients. CAPTRUST requests that Investment Managers adhere to Global Investment Performance Standards (GIPS) issued by the CFA Institute. Every attempt is made to obtain performance information which is calculated on a uniform and consistent basis. In most cases, performance data approved by CAPTRUST for Client viewing will have been calculated based on a uniform and consistent standard. However, some Investment Managers may provide information which does not entirely conform to these uniform standards. In those instances, the affected performance information will be specifically identified as having not been calculated based on the uniform standard normally used. CAPTRUST uses industry standards to measure the performance of the SMA Managers the firm recommends and selects; however, CAPTRUST does not use a third-party auditor to review and verify the performance of SMA Managers. Risk of Loss. It is important to note that investing in securities involves certain risks that are borne by the investor. For any risks associated with registered investment company products, Clients should refer to their prospectuses for additional details about these risks. CAPTRUST investment approach constantly keeps the risk of loss in mind These risks include, but are not limited to: 10 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645   Interest-rate Risk: Fluctuations in interest rates may cause investment prices to change. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market value to decline.  Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events.  Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year because purchasing power is eroding at the rate of inflation.  Reinvestment Risk: Future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities.  Business Risk: Particular industries or companies within an industry pose business- specific risks. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.  Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Some funds utilized in strategies employed by CAPTRUST carry liquidity risk. In some circumstances, Clients have had to wait several quarters or longer when requesting liquidity from the manager of interval funds in PMA model portfolios.  Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value.  Concentration Risk: The probability of loss due to heavy exposure to a single investment, equity, or issuer. Some funds utilized in risk-based asset allocation strategies carry a kind of concentration risk because Clients may own more than one fund managed by the same issuer; or Clients may be invested in several funds with similar strategies which poses a type of concentration risk. Another form of concentration risk occurs when one group of Clients comprise a large portion of a mutual fund’s total asset base, those investors experience an additional risk (over and above the risks associated with the investment’s strategy) due directly to the concentration of their assets in that fund. CAPTRUST strategies may involve some or all of the types of concentration risk described here.  Other risks: CAPTRUST’s recommended strategies include the risks listed above as well as other risks that are more specifically associated with Investment Managers, strategies, funds, or instruments CAPTRUST selects or recommends. For example, some recommended Investment Managers use derivatives (such as options as a hedge) which pose special risks; others carry liquidity risk specific to underlying investments; additionally, some of CAPTRUST’s asset allocated model portfolios have a particular concentration risk because CAPTRUST we may allocate a large portion of a portfolio to a single Investment Manager, or a fund complex. Some portfolios include alternative (or uncommon) investment strategies, or allocations to funds with limited or no prior history of operations. Each recommended Investment Manager discloses risks 11 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  associated with investing in their fund(s) separately (in their respective brochures and/or prospectuses). o Although CAPTRUST acknowledges that Clients are relying on CAPTRUST to manage portfolio risk, Clients are encouraged to read prospectuses and ask questions of FAs, Portfolio Managers, or compliance team members. Please contact us at 919.870.6822 or send a message to compliance@captrust.com.  Private investment funds: Clients who are qualified to invest in private funds must acknowledge and accept the specific risk factors that are associated with investing in private funds. Private fund investments involve various risk factors, including, but not limited to, potential for complete loss of principal, illiquidity, and lack of transparency. Item 7: Client Information Provided to Portfolio Managers Under the PMA and WAS Programs, CAPTRUST is both the Client’s investment adviser and Portfolio Manager. Therefore, the Portfolio Manager has the same access to Client information as CAPTRUST. Client information includes, among other things, income, net worth, risk tolerance, and investment objectives. A Client’s Portfolio Manager uses this information to determine the appropriate asset allocation and to manage Client investments. When a Client updates their information with CAPTRUST, the updates are also available to their Portfolio Manager. Under the SMA Program, CAPTRUST is the Client’s investment adviser and the SMA Manager is the Client’s Portfolio Manager. SMA Managers do not have the same access to Client personal information as CAPTRUST. Client personal information such as income, net worth, risk tolerance, and investment objectives is not communicated to SMA Managers but is used by CAPTRUST to determine the appropriate asset allocation and make recommendations regarding SMA Manager selection. Item 8: Client Contact with Portfolio Managers Under the PMA and WAS Programs, the Portfolio Manager is either the Client’s CAPTRUST FA or the Investment Committee and there are no specific restrictions on direct Client communications with Portfolio Managers. Clients typically communicate with their CAPTRUST FA, who acts as the relationship manager, and/or the client management consultant (“CMC”), who acts in a supporting role to the FA. The Client is required to inform CAPTRUST and the FA, at least annually, of any changes to their financial condition or of any additional investment restrictions and/or modifications to existing investment restrictions the Client wishes to impose. Under the SMA Program, Clients generally do not have direct contact with third party SMA Managers. CAPTRUST will provide initial and ongoing communication with Clients regarding selected SMA Managers and will assist Clients in understanding the management style and other information regarding the SMA Managers. In general, Clients are encouraged to direct questions about their portfolio or accounts to their CAPTRUST FA, or to their CMC. However, Clients may direct questions to members of the Investment Committee whose names are included Form ADV Part 2B, which is incorporated into the Form ADV Part 2 Wealth Brochure. 12 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 9: Additional Information Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a Client or prospective Client’s evaluation of CAPTRUST or the integrity of CAPTRUST’s management. Neither CAPTRUST’s Investment Committee, nor its Management Persons have any disciplinary disclosure required. Each FA who acts as a Portfolio Manager has a separate Form ADV Part 2B. Clients should refer to their FA’s Form ADV Part 2B for personal disciplinary information for that FA. Other Financial Industry Activities and Affiliations CAPTRUST is affiliated by common ownership to CapFinancial Securities, LLC (“CFS”), a FINRA broker-dealer (Member SIPC). CAPTRUST does not manage any proprietary mutual funds. CFS, as an affiliated registered broker-dealer, provides general securities investment services to individuals and institutions. Many investment adviser representatives with Adviser are also registered as CFS registered representatives. A CAPTRUST FA who focuses primarily on wealth advisory services generally spends less than 10% of their time on work done for wealth Clients focused on activities consistent with the definition of broker-dealer activities. A CAPTRUST FA whose focus is institutional clients will generally spend less than 1% of his/her time on broker-dealer activities. CAPTRUST divisions called “1776 Advisor Group,” “Strategic Advisor Group,” and “Family Office Risk Advisors” together with several CAPTRUST FAs, are licensed to act as agent of record for Clients who own life insurance products or for retirement plans funded with group variable products. FAs may occasionally recommend fixed or variable annuities or life insurance (including Private Placement Life Insurance (“PPLI”)) to their wealth Clients when assisting them in executing their financial plan. CFS and CAPTRUST have business entity insurance licenses. Strategic Advisor Group’s primary source of revenue is life insurance commissions not involving CAPTRUST qualified retirement plan clients. As a result of certain investment-related recommendations provided to its Clients, CFS may facilitate certain securities purchases and/or sales, or insurance product purchases and/or sales on behalf of CAPTRUST Clients. Such transactions may be facilitated by CFS, in its capacity as a registered broker-dealer or insurance agent/agency (business entity). Commissions charged by CFS may be higher or lower than obtainable elsewhere. In the fourth quarter of 2024, CFG acquired the assets of four different firms: Campbell Wealth Management (CRD #152956) in Alexandria, VA, TruNorth Wealth Partners (CRD #284807) in St. Paul, MN, Wealth Covenant Group (CRD #291453) in Houston, TX., and Boston Financial Management (CRD #112360) (“BFM”) with offices in Boston, MA, Centerville, MA, and Portland, ME. CFG also acquired BFM’s wholly-owned subsidiary, Boston Fiduciary Services, LLC, which provides professional trustee and fiduciary services to individuals, businesses, and non-profit organizations. 13 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Material Conflicts Regarding Private Funds CAPTRUST provides investment recommendations and advice regarding both affiliated and non-affiliated private investment funds. CAPTRUST provides the fund’s offering materials at or prior to recommending the investment. Clients should refer to the fund’s confidential offering memorandum for applicable disclosures regarding management of the fund, its investment objective, risk factors, tax, and related factors. One Brick. CAPTRUST serves as investment advisor to One Brick Select Private Equity 2024, L.P. CAIS One Brick Select Private Equity 2024 GP LLC, an unaffiliated entity, serves as general partner. CAPTRUST also serves as investment advisor to One Brick Select Private Credit Fund, LP and One Brick Select Private Credit Qualified Fund I, LP (the “One Brick Funds”), for which PPB Capital Partners ("PPB") serves as general partner and fund administrator. The One Brick Funds invest in T. Rowe Price OHA Select Private Credit Fund (“OCredit”). OHA Private Credit Advisors LLC (“OHA Advisor”) is the investment adviser to OCredit. OCredit pays OHA Advisor an incentive fee for serving as its investment manager. As more people invest in OCredit, OHA Advisor will earn more fees. One Brick Funds will also share in those incentive fees, which creates an incentive for CAPTRUST to recommend OCredit in order to increase the potential profits eligible to be shared with investors in the One Brick Funds which include CAPTRUST Clients and employees.  The One Brick Funds pay nominal fees to PPB for fund administration as well as 10bps/year in advisory fees to CAPTRUST.  Homecourt. CAPTRUST is the owner of “CAPTRUST 2022 Homecourt Fund GP, LLC” (a Delaware single member limited liability company), for which the sole purpose was the organization of a private fund called “CAPTRUST 2022 Homecourt Fund, L.P.” (“Homecourt”). Homecourt was formed as an “Access Fund” into Dyal HomeCourt US Investors LP (“Dyal”), and independent third party private limited partnership. CAPTRUST acts as the investment adviser to Homecourt. The interests were offered pursuant to an exemption from the registration requirements of the Securities Act of 1933, as amended (the “Securities Act”). Each investor must be a U.S. person with the requisite skill and expertise to adequately assess the risks of investing in the Access Fund (and indirectly investing in the Underlying Fund); an “accredited investor” as defined within the meaning of Rule 501(a) of Regulation D promulgated under the Securities Act; a “qualified purchaser” as defined under the Investment Company Act, and a “qualified client,” as defined under the U.S. Investment Advisers Act of 1940, as amended, and the rules and regulations promulgated thereunder (the “Advisers Act”). There is no public market for the interests, and no such market is expected to develop in the future. CAPTRUST’s “Management Fee Rate” is 0.10% per annum (e.g. 0.025% per quarter) for limited partners who are Clients and 1.00% per annum (e.g. 0.25% per quarter) for limited partners who are no longer Clients. MRA. CAPTRUST acts as investment adviser to a series of private funds, namely, MR Investment Fund 1 LLC, MRA Opportunities Fund 1-A, MRA Opportunities Fund 1-B, MRA Credit Strategies Fund 1-A Fund LP, and MRA Credit Strategies Fund 1-B Fund LP. SALI. CAPTRUST acts as subadvisor to three private funds, Covenant Global Equities Fund Series Interests of the SALI Multi-Series Fund II 3(c)(1), LP, Covenant Global Equities Fund 14 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Series Interests of the SALI Multi-Series Fund II, L.P., and Vega Multi-Strategy Fund Series of the SALI Multi-Series Fund, L.P., for which SALI Fund Services acts as investment advisor and fund administrator. TRUSTCORE. CAPTRUST acts as subadvisor to Trustcore Private Opportunities Fund, LP for which PPB Advisors acts as investment advisor and NAV Consulting provides fund administration. RINET. CAPTRUST and RINET Company, LLC entered into a limited (administrative) services agreement whereby CAPTRUST will assist RINET in winding down four private funds RINET manages. Code of Ethics CAPTRUST’s Code of Ethics. addresses, among other things: (i) fiduciary obligations to its Clients, (ii) personal securities trading procedures restricting the purchase and sale, by employees for their own accounts, of specific securities; (iii) provisions relating to the confidentiality of Client information; (iv) a prohibition on insider trading; and (v) limits on political contributions; and (vi) restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment. Personal transactions in securities by directors, officers, and employees of CAPTRUST who have access to nonpublic information regarding Clients’ purchase and sale of securities, are involved in making securities recommendations to Clients or who have access to such non- public recommendations are subject to the restrictions and procedures in CAPTRUST’s Code of Ethics. All employees at CAPTRUST must acknowledge the terms of the Code of Ethics annually or as amended. Occasionally, CAPTRUST’s employees may recommend that Clients buy or sell the same securities or investment products that employees of the Advisor also own. CAPTRUST’s employees and persons associated with CAPTRUST are required to follow the Code of Ethics. The Code of Ethics is intended identify and address potential conflicts of interest that might arise in the context of that the personal securities transactions, activities and interests of the CAPTRUST employees that might interfere or appear to interfere with making decisions in the best interest of advisory Clients. Under the Code of Ethics, certain classes of securities have been designated as exempt transactions, based upon a determination that they would not materially interfere with the best interest of CAPTRUST’s Clients. In addition, the Code of Ethics requires pre-approval of specific types of transactions, and depending on the transaction, may restrict trading in close proximity to Client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as Clients, there is a possibility that employees might benefit from market activity by a Client. Employee trading is monitored under the Code of Ethics to reasonably prevent conflicts of interest between CAPTRUST and its Clients. CAPTRUST employees whose accounts are managed by CAPTRUST are included in block trading where CAPTRUST places trades for execution that include accounts of two or more 15 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Clients when CAPTRUST believes trade aggregation is appropriate and in the best interest of its Clients. CAPTRUST’s Clients may request a copy of the firm's Code of Ethics by contacting the Compliance Department at compliance@captrust.com or by calling (919) 870-6822 or (800) 967-9948. Review of Accounts Client Accounts are advised by the Client’s FA who is responsible for performing periodic reviews, consulting with their Clients, and staying abreast of changes to their Clients’ IGO. Ongoing reviews of markets, sectors and individual securities are conducted by the Investment Group. Unaffiliated mutual fund holdings and outside Investment Managers are monitored on a continuous and regular basis by the CAPTRUST Investment Group. Michael Vogelzang, Chief Investment Officer, heads the Investment Group. ADV Part 2B (which is incorporated into the Form ADV Part 2 Wealth Brochure) lists the members of the Investment Group who are also members of the Investment Committee or who are involved in the review process and in determining the investment advice to be given by the Adviser. In addition to monthly statements provided by the custodian of the Client’s Assets, CAPTRUST prepares quarterly performance reports for Wealth Client accounts. Clients may access their quarterly performance reports electronically via CAPTRUST’s client portal. For information on how to access reports, Clients should call their CAPTRUST FA at 919.870.6822 or 800.216.0685 or email compliance@captrust.com. CAPTRUST receives a daily download of transaction information from Pershing, Schwab, and Fidelity and has access to Wealth Client accounts through their institutional advisor platforms. Clients agree to inform CAPTRUST in writing of any material changes to the Client’s IGO or financial situation that might affect the manner with which Client’s assets should be invested. Additionally, Clients who wish to impose reasonable restrictions on the management of their accounts may do so by contacting their FA at 800.216.0645 or by email at compliance@captrust.com. Clients with portfolios that include private equity and/or other private investments (“private funds”) should be advised that quarterly values lag for up to 60 days following a quarter-end. Because CAPTRUST relies on the Client’s capital account statement (provided by the issuer or qualified custodian) for private fund values used for purposes of quarterly portfolio review/reporting in Black Diamond®, quarterly review reports will reflect the latest valuation date available. Consequently, a Client’s actual private fund holdings could be significantly more or less than the value reflected on the Black Diamond portfolio report. Unless otherwise indicated, the Client’s advisory fee will be based upon the value reflected in Black Diamond®. Clients may contact CAPTRUST during normal business hours to consult with CAPTRUST concerning the management of the Client’s accounts. Client Referrals and Other Compensation Clients (or prospective Clients) who are being referred to CAPTRUST, either by means of a paid “endorsement” by a third-party or in connection with a paid “testimonial” by a current Client, must be made aware of the arrangement at the time the testimonial or endorsement is disseminated in a clear and prominent manner. The disclosure of the arrangement must 16 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  explain whether the testimonial was given by a current Client or investor; or if the endorsement was given by a person other than a current Client or investor; explain whether cash or non-cash compensation was provided for the testimonial or endorsement; and if applicable, include brief statement of any material conflicts of interest on the part of the person giving the testimonial or endorsement resulting from the investment adviser's relationship with such person. In cases where a referral takes place in person, these required disclosures will be delivered in writing at the time the testimonial or endorsement is being made. CAPTRUST, has entered into referral agreements with various third-party solicitors (“Solicitors”) for Client referrals. For a Solicitor to be compensated by CAPTRUST for referring a Client to CAPTRUST, the Solicitor must be engaged by CAPTRUST under a Solicitor or Referral Agreement (a “ Referral Agreement”) in compliance with Section 206(4)- 1 of the Investment Advisers Act of 1940. In general, a Solicitor is compensated by a percentage of the advisory fee collected for a specified period of time (as detailed in the Referral Agreement). Clients pay no additional fee for the referral over and above CAPTRUST’s quoted advisory fee; to the contrary, the fee the Advisor earns is reduced by the amount of the compensation to the Solicitor. Each Referral Agreement requires the Solicitor to deliver the required disclosures either in writing or via the internet at the time of the testimonial or endorsement is made. Clients may request details regarding a particular Agreement by contacting CAPTRUST at 800.216.0645 or compliance@captrust.com. Schwab Advisor Network® CAPTRUST receives client referrals from Charles Schwab & Co., Inc. (“Schwab”) through CAPTRUST’s participation in Schwab Advisor Network® (the “Service”). The Service is designed to help investors find an independent investment advisor. Schwab is a broker-dealer independent of and unaffiliated with CAPTRUST. Schwab does not supervise CAPTRUST and has no responsibility for CAPTRUST’s management of Clients’ portfolios or CAPTRUST’s other advice or services. CAPTRUST pays Schwab fees to receive client referrals through the Service. CAPTRUST’s participation in the Service may raise potential conflicts of interest described below. CAPTRUST pays Schwab a Participation Fee on all referred Clients’ accounts that are maintained in custody at Schwab and a Non-Schwab Custody Fee on all accounts that are maintained at, or transferred to, another custodian. The Participation Fee paid by CAPTRUST is a percentage of the fees the Client owes to CAPTRUST or a percentage of the value of the assets in the Client’s account, subject to a minimum Participation Fee. CAPTRUST pays Schwab the Participation Fee for so long as the referred Client’s account remains in custody at Schwab. The Participation Fee is billed to CAPTRUST quarterly and may be increased, decreased or waived by Schwab from time to time. The Participation Fee is paid by CAPTRUST and not by the Client. CAPTRUST has agreed not to charge Clients referred through the Service fees or costs greater than the fees or costs CAPTRUST charges Clients with similar portfolios who were not referred through the Service. CAPTRUST generally pays Schwab a Non-Schwab Custody Fee if custody of a referred Client’s account is not maintained by, or assets in the account are transferred from Schwab. 17 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  This Fee does not apply if the Client was solely responsible for the decision not to maintain custody at Schwab.The Non-Schwab Custody Fee is a one-time payment equal to a percentage of the assets placed with a custodian other than Schwab. The Non-Schwab Custody Fee is higher than the Participation Fees CAPTRUST generally would pay in a single year. Thus, CAPTRUST will have an incentive to recommend that Client accounts be held in custody at Schwab. The Participation and Non-Schwab Custody Fees will be based on assets in accounts of CAPTRUST’s Clients who were referred by Schwab and those referred Clients’ family members living in the same household. Thus, CAPTRUST will have incentives to encourage household members of Clients referred through the Service to maintain custody of their accounts and execute transactions at Schwab and to instruct Schwab to debit CAPTRUST’s fees directly from the accounts. For accounts of CAPTRUST’s Clients maintained in custody at Schwab, Schwab will not charge the Client separately for custody but will receive compensation from CAPTRUST’s Clients in the form of commission or other transaction-related compensation on securities trades executed through Schwab. Schwab also will receive a fee (generally lower than the applicable commission on trades it executes) for clearance and settlement of trades executed through broker-dealers other than Schwab. Schwab’s fees for trades executed at other broker-dealers are in addition to the other broker-dealer’s fees. Thus, CAPTRUST may have an incentive to cause trades to be executed through Schwab rather than another broker- dealer. CAPTRUST nevertheless acknowledges its duty to seek best execution of trades for Client accounts. Trades for Client accounts held in custody at Schwab may be executed through a different broker-dealer than trades for CAPTRUST’s other Clients. Thus, trades for accounts custodied at Schwab may be executed at different times and different prices than trades for other accounts that are executed at other broker-dealers. Fidelity Wealth Advisor Solutions® CAPTRUST participates in the Fidelity Wealth Advisor Solutions® Program (the “WAS Program”), through which CAPTRUST receives referrals from Fidelity Personal and Workplace Advisors LLC (FPWA), a registered investment adviser and Fidelity Investments company. CAPTRUST is independent and not affiliated with FPWA or any Fidelity Investments company. FPWA does not supervise or control CAPTRUST and FPWA has no responsibility or oversight for CAPTRUST’s provision of investment management or other advisory services. Under the WAS Program, FPWA acts as a solicitor for CAPTRUST and CAPTRUST pays referral fees to FPWA for each referral received based on CAPTRUST’s assets under management attributable to each Client referred by FPWA or members of each Client’s household. The WAS Program is designed to help investors find an independent investment advisor, and any referral from FPWA to CAPTRUST does not constitute a recommendation or endorsement by FPWA of CAPTRUST’s particular investment management services or strategies. More specifically, CAPTRUST pays the following amounts to FPWA for referrals: the sum of (i) an annual percentage of 0.10% of any and all assets in Client accounts where such assets are identified as “fixed income” assets by FPWA and (ii) an annual percentage of 0.25% of all other assets held in Client accounts. In addition, CAPTRUST has agreed to pay 18 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  FPWA a minimum annual fee amount in connection with its participation in the WAS Program. These referral fees are paid by CAPTRUST and not the Client. To receive referrals from the WAS Program, CAPTRUST must meet certain minimum participation criteria, but CAPTRUST may have been selected for participation in the WAS Program as a result of its other business relationships with FPWA and its affiliates, including Fidelity Brokerage Services, LLC (“FBS”). As a result of its participation in the WAS Program, CAPTRUST may have a potential conflict of interest with respect to its decision to use certain affiliates of FPWA, including FBS, for execution, custody and clearing for certain Client accounts, and CAPTRUST may have a potential incentive to suggest the use of FBS and its affiliates to its advisory Clients, whether or not those Clients were referred to CAPTRUST as part of the WAS Program. Under an agreement with FPWA, CAPTRUST has agreed that Advisor will not charge Clients more than the standard range of advisory fees disclosed in its Form ADV 2A Brochure to cover solicitation fees paid to FPWA as part of the WAS Program. Pursuant to these arrangements, CAPTRUST has agreed not to solicit Clients to transfer their brokerage accounts from affiliates of FPWA or establish brokerage accounts at other custodians for referred Clients other than when CAPTRUST’s fiduciary duties would so require, and CAPTRUST has agreed to pay FPWA a one-time fee equal to 0.75% of the assets in a Client account that is transferred from FPWA’s affiliates to another custodian; therefore, CAPTRUST may have an incentive to suggest that referred Clients and their household members maintain custody of their accounts with affiliates of FPWA. However, participation in the WAS Program does not limit CAPTRUST’s duty to select brokers on the basis of best execution. Financial Information Registered Investment Advisers are required to provide Clients with certain financial information or disclosures about CAPTRUST’s financial condition. CAPTRUST has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of any bankruptcy proceeding. Important Disclosures About CAPTRUST’s Privacy Policy and Business Continuity Plan The CAPTRUST Privacy Policy and Business Continuity Disclosure/Summary can be found on the CAPTRUST internet site by navigating to:  Business Continuity Plan: https://www.captrust.com/business-continuity-plan  Privacy Policy: https://www.captrust.com/privacy-policy/ 19 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645 

Item 1: Cover Page March 18, 2025 CAPTRUST Financial Advisors 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 Firm CRD #175112 Phone: 919.870.6822 Toll Free: 800.216.0645 www.captrust.com This Form ADV Part 2A is the CAPTRUST Institutional Client Brochure (“Brochure” or “Institutional Brochure”) and provides information about the qualifications and business practices of CAPTRUST Financial Advisors with respect to services provided to institutional clients. If you have any questions about the contents of this Brochure, please contact us by phone at 919.870.6822 or toll-free at 800.216.0645 or by email compliance@captrust.com. 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. CAPTRUST Financial Advisors is an investment adviser registered under the Investment Advisers Act of 1940. Registration does not imply any level of skill or training. Additional information about CAPTRUST Financial Advisors also is available on the SEC’s website at www.adviserinfo.sec.gov. 1 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 2: Summary of Material Changes This Summary of Material Changes reflects only material changes to this Brochure since our last annual update of this Brochure which was dated March 28, 2024. A full copy of our Brochure may be requested by email at compliance@captrust.com or by contacting us toll- free at 800.216.0645. Item 10 - Other Financial Industry Activities and Affiliations Item 10 has been amended to disclose the following acquisition activity: In the fourth quarter of 2024, CFG acquired the assets of four different firms: Campbell Wealth Management (CRD #152956) in Alexandria, VA, TruNorth Wealth Partners (CRD #284807) in St. Paul, MN, Wealth Covenant Group (CRD #291453) in Houston, TX., and Boston Financial Management (CRD #112360) (“BFM”) with offices in Boston, MA, Centerville, MA, and Portland, ME. CFG also acquired BFM’s wholly-owned subsidiary, Boston Fiduciary Services, LLC, which provides professional trustee and fiduciary services to individuals, businesses, and non-profit organizations. 2 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 3: Table of Contents Item 1: Cover Page .......................................................................................................................................................... 1 Item 2: Summary of Material Changes .................................................................................................................. 2 Item 3: Table of Contents ........................................................................................................................................... 3 Item 4: Advisory Business ..........................................................................................................................................4 Item 5: Fees and Compensation .............................................................................................................................. 7 Item 6: Performance-Based Fees and Side-By-Side Management ........................................................... 9 Item 7: Types of Clients ............................................................................................................................................... 9 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................................................. 10 Item 9: Disciplinary Information .............................................................................................................................. 11 Item 10: Other Financial Industry Activities and Affiliations ...................................................................... 11 Item 11: Code of Ethics ............................................................................................................................................... 14 Item 12: Brokerage Practices ................................................................................................................................... 15 Item 13: Review of Accounts ................................................................................................................................... 15 Item 14: Client Referrals and Other Compensation ....................................................................................... 16 Item 15: Custody ........................................................................................................................................................... 17 Item 16: Investment Discretion ............................................................................................................................... 17 Item 17: Voting Client Securities ............................................................................................................................ 18 Item 18: Financial Information ................................................................................................................................. 18 3 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 4: Advisory Business Introduction CAPTRUST Financial Advisors, also known as CapFinancial Partners, LLC, (“CAPTRUST” or “Adviser”) was established in April 2003 and approved as a registered investment adviser in September 2003. The CapFinancial Group, LLC (“CFG”, a North Carolina limited liability company) owns just under 100% of CAPTRUST. Each of CapFinancial Holdings, Inc. and Halftime Holdings, LLC owns more than 25% of The CapFinancial Group, LLC. GTCR Fund XII B indirectly owns more than 25% of CAPTRUST through its ownership of Halftime Holdings, LLC. CAPTRUST is an investment adviser registered under the Investment Advisers Act of 1940 (the “Advisers Act”). CAPTRUST provides investment advisory services on either a “non- discretionary” basis or “discretionary” basis. With respect to ERISA qualified plans, CAPTRUST serves as a "fiduciary" as defined by §3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974 ("ERISA"); or if on a “discretionary” basis, CAPTRUST serves as an "investment manager" as defined by §3(38) of ERISA. CAPTRUST provides advisory services to institutional clients including, but not limited to, retirement plan sponsors, 401(k) plans, 403(b) plans, pensions, profit-sharing plans, non- qualified plans, endowments and foundations, religious organization, and other asset pools such as, corporations or other businesses not listed above (collectively referred to throughout this Brochure as “Client”). Under the Advisers Act, CAPTRUST renders continuous and regular investment supervisory services as a fiduciary to Clients. As of December 31, 2024, CAPTRUST managed a total of just under $1.1 trillion in total assets under management, comprised of just over $845 billion in nondiscretionary assets under advisement (primarily Institutional Client assets) and just over $237 billion in discretionary assets under advisement (Institutional and Wealth Client assets). CAPTRUST requires each Client to make a selection of services in writing as part of an investment advisory agreement (for example, a Consulting Services Agreement or “CSA”; a Retirement Plan Advisory Services Agreement or “RPASA”; an Advisory Services Agreement or “ASA”; or an Investment Advisory Agreement “IAA”, collectively referred to herein as “Agreement”), which sets forth the rights and obligations of CAPTRUST and the Client. Each Agreement is customized to state the negotiated fee. Retirement Plan Advisory Services Include, but are not limited to: ERISA 3(21) Investment Adviser Fiduciary Services (Non-Discretionary)  Development of Investment Policy Statement  Investment Performance Measurement & Analysis  Recommendations for Selecting & Monitoring the Plan’s Investments  Assistance with Plan Fiduciaries’ Selection & Management of Service Providers 4 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645   CAPTRUST At Work  CAPTRUST Advice Solutions (asset allocation model portfolios) ERISA 3(38) Investment Manager Fiduciary Services (Discretionary)  Development of Investment Policy Statement  Investment Performance Measurement & Analysis  Selecting & Monitoring the Plan’s Investments  Assistance with Plan Fiduciaries’ Selection & Management of Service Providers  CAPTRUST At Work  CAPTRUST Advice Solutions (asset allocation model portfolios) ERISA Non-Fiduciary Services  Assistance with Fiduciary Oversight & Committee Education  Additional Consulting Services  Employee Investment Education & Communication Nonqualified Plan Advisory Services (Non-Discretionary and Discretionary)  Plan Design  Plan Financing & Security  Plan Administration & Fee Benchmarking  Development of Investment Policy Statement  Investment Performance Measurement & Analysis  Selecting & Monitoring the Plan’s Investments  Employee Investment Education & Communication Endowments & Foundation Advisory Services include, but are not limited to:  Discretionary o Selecting & Monitoring Investments o Development of Investment Policy Statement o Investment Performance Measurement & Analysis  Nondiscretionary o Recommendations for Selecting & Monitoring Investments o Development of Investment Policy Statement o Investment Performance Measurement & Analysis  Non-Investment Related Advisory Services include but are not limited to: o Assistance with Oversight & Committee Education o Additional Consulting Services 5 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Religious Organizations Advisory Service include, but are not limited to:  Discretionary o Selecting & Monitoring Investments o Development of Investment Policy Statement o Investment Performance Measurement & Analysis  Nondiscretionary o Recommendations for Selecting & Monitoring Investments o Development of Investment Policy Statement o Investment Performance Measurement & Analysis  Non-Investment Related Advisory Services include but are not limited to: o Assistance with Oversight & Committee Education o Additional Consulting Services CAPTRUST Advice Solutions Some retirement plans offer CAPTRUST Advice Solutions to their plan participants. The plan sponsor decides how the plan will pay for these services for plan participants, but the plan participant elects whether to use the services or not. CAPTRUST Advice Solutions uses a third-party technology provider to gather personal information from the plan sponsor, the plan recordkeeper, and the plan participant, to calculate an appropriate asset allocation specifically for the plan participant. There are two types of Advice Solutions:  Blueprint Managed Advice is a discretionary advisory service using a third-party technology. CAPTRUST sends transaction instructions to the plan recordkeeper to implement the asset allocation for each enrolled participant.  Online Advice is a nondiscretionary, point-in-time, investment recommendation with respect to the allocation of the plan participant’s account. The plan participant decides whether to implement the investment recommendation. CAPTRUST At Work CAPTRUST At Work is a comprehensive financial wellness program designed to help employees achieve their personal financial goals and objectives through education, personalized advice, and ongoing support. Personalized investment advice is offered in a fiduciary capacity. Plan participants will exercise final decision-making authority and responsibility for the implementation of any recommendations made by CAPTRUST. The services may include, but are not limited to:  Access to live and on-demand webinars, workshops, and materials  Digital content and engagement 6 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645   One-on-one meetings with plan participants to provide personalized advice and/or guidance The plan sponsor decides how the plan will pay for CAPTRUST At Work services for plan participants, but the plan participant elects whether to use the services. Adviser may provide other services to plan participants when the services are independently contracted for or sought by participants, including financial planning and investment services. These other services will be performed separately from services to the plan, are not part of the Agreement with the plan sponsor but would be defined in a separate Agreement with the plan participant individually. Adviser may use data available under the Agreement with the plan sponsor in providing these services to participants. Alternative Investments Adviser offers advice on private placements and/or limited partnerships that are considered “alternative investments”, for example, limited partnerships that are known as a “fund of funds” (typically a fund of private funds). Adviser also offers advice on private equity funds that contain investments in equities, futures, options, and other securities. Any such recommendation will be made only when determined to be suitable and must be accompanied by or preceded by a prospectus or offering memorandum. In general, this type of advice is rendered to wealth clients or nonqualified plan or other institutional clients, not including defined contribution plans. In performing its services, CAPTRUST shall not be required to verify or audit the information received from the Client or from the Client’s other professionals and is expressly authorized to rely thereon. If requested by the Client, CAPTRUST shall recommend the services of other professionals for implementation purposes. The Client is under no obligation to engage the services of any such recommended professional. Item 5: Fees and Compensation CAPTRUST requires each Client to make a selection of services in writing as part of an Agreement, which sets forth the rights and obligations of CAPTRUST and the Client. Advisory fees are negotiated prior to the signing of the Agreement. The Agreement is then customized to state the negotiated fee, which, in general, is typically expressed as a percentage of total assets under advisement or can also be a flat fee. As summarized above, a Client may engage CAPTRUST on a discretionary or non-discretionary basis. In general, fees charged for investment advisory services are payable quarterly, in advance, and are based upon the market value of the Client’s assets on the last business day of the calendar quarter. Advisory fees are accounted for on a quarterly invoice in detail. Fees may be direct billed to the Client or to a third-party administrator (“TPA”) or custodian at the 7 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Client’s instruction. Fees for Clients engaging CAPTRUST in mid-quarter will be prorated and calculated on a per diem basis. Some Client portfolios include private equity and/or other private investments for which quarterly values lag for up to 60 days following a quarter-end. In those limited cases, CAPTRUST uses the latest valuation date available for purposes of computing investment advisory fees. CAPTRUST relies on the Client’s capital account statement (provided by the issuer or qualified custodian) for the values of such private investments. The Agreement will continue in effect until terminated by either party upon thirty (30) days written notice to the other party. However, if the Client has not received the CAPTRUST Form ADV Part 2 at least 48 hours prior to entering into the Agreement, the Client may terminate the Agreement within five business days of entering into the Agreement without penalty. If any advisory relationship terminates before the last day of a quarter, fees are prorated accordingly, and the Adviser will refund any unearned fees due to the Client. Flat/Fixed Fee Service: To the extent so engaged by the Client, the Adviser may charge a flat or fixed fee for investment advisory and consultation services. Flat/fixed fees are negotiable but generally range from $10,000 to $250,000 on an annual basis, depending upon the level and scope of the services required. Fixed fees are charged quarterly in advance, calculated on a per diem basis, upon the signing of an Agreement by the Client. Fees for Clients engaging Adviser mid-quarter will be prorated on a per diem basis. Occasionally advisory services will be quoted on an hourly or per diem basis. Some Clients who have assigned their advisory agreements to CAPTRUST in connection with an acquisition pay their advisory fees in arrears. But, in either case, the terms of the Agreement determine the fee arrangements. Broker of Record: Since inception, CAPTRUST has consistently and affirmatively acknowledged CAPTRUST’s role as a co-fiduciary (both publicly and by written contract with CAPTRUST Clients). CAPTRUST has a relatively small number of Clients who have chosen to name their Financial Advisor (“FA”), an investment adviser representative of CAPTRUST, as “broker of record” (“BOR”) in his/her capacity as registered representative of CAPTRUST’s affiliated broker-dealer CapFinancial Securities, LLC (“CFS”) for the purpose of capturing product revenue in order to reduce (or offset) contractually agreed upon and level investment advisory fees for the Client. Retirement plan Clients consider this a “value-added” service because it provides the Client flexibility in utilizing product fees to pay for plan expenses in the absence of a recordkeeper or another vendor-provided ERISA budget account. In cases where a retirement plan sponsor has elected to appoint a CAPTRUST FA as BOR, CFS may be compensated by general promotion, advertising, and distribution fees (“12b-1 fees”) in relation to purchases and sales of mutual fund shares in the retirement plan that is the subject of the Agreement. However, in accordance with the Agreement, these 12b-1 fees will be taken into account when calculating that plan’s advisory fee for service for a particular period and the typical fee reduced (or offset) by the 12b-1 fees received by CFS. CAPTRUST 8 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  tracks all 12b-1 or product revenue (by Client) that is actually received by CFS and offsets (reduces) advisory fees upon a quarterly invoice basis in accordance with the Agreement. Fees charged may be higher than otherwise available elsewhere. A portion of the fees charged by CAPTRUST for advisory services will be paid to investment advisory representatives employed by CAPTRUST. All fees described herein may be subject to negotiation depending on a range of factors including, but not limited to, plan size and overall range of services requested. CAPTRUST’s fees are exclusive of other related costs and expenses which shall be incurred by the Client. For example, Clients may incur certain charges imposed by custodians, brokers, and other third parties such as fees charged by managers, record-keeping/custodial fees, sales charges, redemption fees, wire transfer and electronic fund fees, and other fees and/or taxes. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to CAPTRUST’s fee, and CAPTRUST shall not receive any portion of these other fees or costs. Item 6: Performance-Based Fees and Side-By-Side Management In general, CAPTRUST does not charge performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a Client). Please see Item 10 – “Other Financial Industry Activities and Affiliations – Material Conflicts Regarding Private Funds” for a detailed explanation of conflicts in connection to the One Brick Select Private Credit Fund, LP and One Brick Select Private Credit Qualified Fund I, LP (collectively, the “One Brick Funds”) which invest in T. Rowe Price OHA Select Private Credit Fund (“OCredit”). Incentive fees earned by OCredit will be shared with investors in the One Brick Funds. CAPTRUST does not charge performance fees to the One Brick Funds, but indirectly participates in fees earned by OCredit. The assets in the One Brick Funds represent less than 0.006% of all Client assets. Item 7: Types of Clients CAPTRUST provides advisory services to institutional clients such as retirement plan sponsors, 401(k) plans, 403(b) plans, pensions, profit-sharing plans, non-qualified plans, or other institutional clients such as foundations, endowments; religious organization; and other asset pools such as, corporations or other businesses not listed above (collectively referred to throughout this Brochure as “Client”). In addition, CAPTRUST provides investment advisory services to individuals (“Wealth Clients”), on a continuous and regular basis, but those services are disclosed separately, in CAPTRUST’s Wealth Brochure and Wrap Fee Program Brochure (Appendix 1 to the Wealth Brochure). Adviser does not require a minimum account size but may impose a minimum annual consulting fee. Adviser retains the right to waive any minimums. 9 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Investment recommendations are based on an analysis of the Client’s specific needs and are drawn from research and analysis. Each Client’s needs are analyzed separately. For example, when analyzing a retirement plan, CAPTRUST pays particular attention to the limitations on the investment lineup as determined by the retirement plan documents, current service providers/platform and whether a plan’s current platform has an opened or closed architecture. In general, investment analysis methods may include fundamental analysis as well as quantitative and qualitative research on a given investment vehicle. Information for this analysis may be drawn from financial newspapers, magazines and databases, research materials prepared by others, annual reports, corporate filings and prospectuses. It is important to note that investing in securities involves certain risks that are borne by the investor. For any risks associated with investment company products, please refer to the prospectuses for additional details about these risks. CAPTRUST’s investment approach constantly keeps the risk of loss in mind. In general, risks associated with investing include, but are not limited to:  Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.  Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events.  Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.  Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities.  Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.  Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, treasury bills are highly liquid, while real estate properties are not. Some investments that might be utilized in select strategies, such as interval funds, employed by CAPTRUST carry liquidity risk. In some circumstances, Clients have had to wait several quarters or longer when requesting liquidity from the manager of interval funds in a CAPTRUST managed account.  Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. 10 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645   Concentration Risk: The probability of loss due to heavy exposure to a single investment, equity or issuer. Some investments utilized in recommended strategies carry a kind of concentration risk since Clients may own more than one fund managed by the same issuer; or Clients may be invested in several funds with similar strategies which poses a type of concentration risk.  Other Risk: CAPTRUST’s recommended strategies include the risks listed above as well as other risks that are more specifically associated with managers, strategies, funds, or instruments CAPTRUST selects or recommends. For example, some recommended managers use derivatives (such as options as a hedge) which pose special risks; others carry liquidity risk specific to underlying investments; additionally, some risk-based asset allocated models have a particular concentration risk because CAPTRUST may recommend a single manager, or a fund complex for a large portion model. Some recommended strategies include alternative investment strategies, or allocations to funds with limited or no prior history of operations. Each recommended manager discloses risks associated with investing in their funds separately (in their respective brochures and/or prospectuses). o Although CAPTRUST acknowledges that Clients are relying on CAPTRUST to manage portfolio risk, Clients are encouraged to read managers’ disclosure brochures, prospectuses and ask questions of FA, investment committee members or compliance team members. Please contact us at 919.870.6822 or send a message to compliance@captrust.com.  Private investment funds: Clients who are qualified to invest in private funds must acknowledge and accept the specific risk factors that are associated with investing in private funds. Private fund investments involve various risk factors, including, but not limited to, potential for complete loss of principal, illiquidity, and lack of transparency. Item 9: Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client or prospective client’s evaluation of CAPTRUST or the integrity of CAPTRUST’s management. Neither CAPTRUST management nor members of CAPTRUST’s investment committee have any reportable disciplinary history for this Item. Each FA who acts as a portfolio manager has a separate Form ADV Part 2B. Clients should refer to their FA’s Form ADV Part 2B for personal disciplinary information for that FA. Item 10: Other Financial Industry Activities and Affiliations CAPTRUST is affiliated by common ownership to CapFinancial Securities, LLC (“CFS”), a FINRA broker-dealer (Member SIPC). CAPTRUST does not manage any proprietary mutual funds. CFS, as an affiliated registered broker-dealer, provides individuals and institutions general securities investment services. Many investment adviser representatives with Adviser are simultaneously registered as CFS registered representatives. A CAPTRUST FA who focuses primarily on wealth advisory services generally spends less than 10% of their time on work done for Wealth Clients focused on activities consistent with the definition of broker-dealer 11 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  activities. A CAPTRUST FA whose focus is Institutional Clients will generally spend less than 1% of their time on broker-dealer activities. CAPTRUST divisions called “1776 Advisor Group,” “Strategic Advisor Group,” and “Family Office Risk Advisors” along with several CAPTRUST FAs, are life insurance licensed in order to act as agent of record for those Clients who own life insurance products or for retirement plans funded with group variable products. CAPTRUST FAs may occasionally recommend fixed or variable annuities or life insurance (including Private Placement Life Insurance (“PPLI”)) to their Wealth Clients when assisting them in executing their financial plan. CFS and CAPTRUST have business entity insurance licenses. Strategic Advisor Group’s primary source of revenue is life insurance commissions not involving CAPTRUST qualified retirement plan clients. As a result of certain investment-related recommendations provided to its Clients, CFS may facilitate certain securities purchases and sales, or insurance product purchases and sales on behalf of CAPTRUST Clients. Such transactions may be facilitated by CFS, in its capacity as a registered broker-dealer or insurance agent/agency (business entity). Commissions charged by CFS may be higher or lower than obtainable elsewhere. All related compensation is separate from advisory services. In general, product revenue associated with plan Client assets is captured to reduce the plan advisory fee pursuant to the terms of the Retirement Plan Advisory Services Agreement. In the fourth quarter of 2024, CFG acquired the assets of four different firms: Campbell Wealth Management (CRD #152956) in Alexandria, VA, TruNorth Wealth Partners (CRD #284807) in St. Paul, MN, Wealth Covenant Group (CRD #291453) in Houston, TX., and Boston Financial Management (CRD #112360) (“BFM”) with offices in Boston, MA, Centerville, MA, and Portland, ME. CFG also acquired BFM’s wholly-owned subsidiary, Boston Fiduciary Services, LLC, which provides professional trustee and fiduciary services to individuals, businesses, and non-profit organizations. Material Conflicts Regarding Private Funds CAPTRUST provides investment recommendations and advice regarding both affiliated and non-affiliated private investment funds. CAPTRUST provides the fund’s offering materials at or prior to recommending the investment. Please refer to the fund’s confidential offering memorandum for applicable disclosures regarding management of the fund, its investment objective, risk factors, tax, and related factors. One Brick. CAPTRUST serves as investment advisor to One Brick Select Private Equity 2024, L.P. CAIS One Brick Select Private Equity 2024 GP LLC, an unaffiliated entity, serves as general partner. CAPTRUST also serves as investment advisor to One Brick Select Private Credit Fund, LP and One Brick Select Private Credit Qualified Fund I, LP (the “One Brick Funds”) for which PPB Capital Partners ("PPB") serves as general partner and fund administrator. The One Brick Funds invest in T. Rowe Price OHA Select Private Credit Fund (“OCredit”). OHA Private Credit Advisors LLC (“OHA Advisor”) is the investment adviser to OCredit. OCredit pays OHA Advisor an incentive fee for serving as its investment manager. As more people invest in OCredit, OHA Advisor will earn more fees. One Brick Funds will also 12 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  share in those incentive fees, which creates an incentive for CAPTRUST to recommend OCredit in order to increase the potential profits eligible to be shared with investors in the One Brick Funds, which include CAPTRUST Clients and employees.  (Please see Item 6.) The One Brick Funds pay nominal fees to PPB for fund administration as well as 10bps/year in advisory fees to CAPTRUST.  Homecourt. CAPTRUST is the owner of “CAPTRUST 2022 Homecourt Fund GP, LLC” (s Delaware single member limited liability company), for which the sole purpose was the organization of a private fund called “CAPTRUST 2022 Homecourt Fund, L.P.” (“Homecourt”). Homecourt was formed as an “Access Fund” into Dyal HomeCourt US Investors LP (“Dyal”), and independent third party private limited partnership. CAPTRUST acts as the investment adviser to Homecourt. The interests were offered pursuant to an exemption from the registration requirements of the Securities Act of 1933, as amended (the “Securities Act”). Each investor must be a U.S. person with the requisite skill and expertise to adequately assess the risks of investing in the Access Fund (and indirectly investing in the underlying fund); an “accredited investor” as defined within the meaning of Rule 501(a) of Regulation D promulgated under the Securities Act; a “qualified purchaser” as defined under the Investment Company Act, and a “qualified client,” as defined under the U.S. Investment Advisers Act of 1940, as amended, and the rules and regulations promulgated thereunder (the “Advisers Act”). There is no public market for the interests, and no such market is expected to develop in the future. CAPTRUST’s “Management Fee Rate” is 0.10% per annum (e.g. 0.025% per quarter) for limited partners who are Clients and 1.00% per annum (e.g. 0.25% per quarter) for limited partners who are no longer Clients. MRA. CAPTRUST acts as investment adviser to a series of private funds, namely, MR Investment Fund 1 LLC, MRA Opportunities Fund 1-A, MRA Opportunities Fund 1-B, MRA Credit Strategies Fund 1-A Fund LP, and MRA Credit Strategies Fund 1-B Fund LP. SALI. CAPTRUST acts as subadvisor to three private funds, Covenant Global Equities Fund Series Interests of the SALI Multi-Series Fund II 3(c)(1), LP, Covenant Global Equities Fund Series Interests, and Vega Multi-Strategy Fund Series of the SALI Multi-Series Fund, L.P., for which SALI Fund Services acts as investment advisor and fund administrator. TRUSTCORE. CAPTRUST acts as subadvisor to Trustcore Private Opportunities Fund, LP for which PPB Advisors acts as investment advisor and NAV Consulting provides fund administration. RINET. CAPTRUST and RINET Company, LLC entered into a limited (administrative) services agreement whereby CAPTRUST will assist RINET in winding down four private funds RINET manages. 13 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 11: Code of Ethics CAPTRUST’s Code of Ethics addresses, among other things: (i) general principles that address CAPTRUST’s fiduciary obligations to its Clients, (ii) personal securities trading procedures restricting the purchase and sale, by access persons for their own accounts, of specific securities; (iii) provisions relating to the confidentiality of Client information; (iv) a prohibition on insider trading; (v) limits on political contributions; and (vi) and restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment. Personal transactions in securities by directors, officers, and employees of CAPTRUST who have access to nonpublic information regarding Clients’ purchase and sale of securities, are involved in making securities recommendations to Clients or who have access to such non- public recommendations (“access persons”) are subject to the restrictions and procedures in CAPTRUST’s Code of Ethics. All employees at CAPTRUST must acknowledge the terms of the Code of Ethics annually, or as amended. Occasionally, access persons of Adviser may recommend that Clients buy or sell the same securities or investment products that access persons of the Adviser also own. CAPTRUST’s employees and persons associated with CAPTRUST are required to follow the Code of Ethics. The Code of Ethics is intended to identify and address potential conflicts of interest that might arise in the context of personal securities transactions, activities, and interests of the employees of CAPTRUST that might interfere or appear to interfere with making decisions in the best interest of advisory Clients. Under the Code of Ethics certain classes of securities have been designated as exempt transactions, based upon a determination that they would not materially interfere with the best interest of CAPTRUST’s Clients. In addition, the Code of Ethics requires pre-approval of specific types of transactions, and, depending on the transaction, may restrict trading in close proximity to Client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as Clients, there is a possibility that employees might benefit from market activity by a Client. Employee trading is monitored under the Code of Ethics to reasonably prevent conflicts of interest between CAPTRUST and its Clients. CAPTRUST employees whose accounts are managed by CAPTRUST are included in block trading where CAPTRUST places trades for execution that include accounts of two or more Clients when CAPTRUST believes trade aggregation is appropriate and in the best interest of its Clients. CAPTRUST’s Clients may request a copy of the firm's Code of Ethics by contacting the Compliance Department at compliance@captrust.com or by calling 919. 870.6822 or 800 .967.9948. 14 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 12: Brokerage Practices CAPTRUST is required to describe the factors considered in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). When CAPTRUST is engaged with a Client through a non- discretionary Agreement, Client assets are held at various third-party custodians that have not been recommended by CAPTRUST and for which CAPTRUST has no interest or conflict to disclose. Please see Item 5: Fees and Compensation – Broker of Record for information about how CAPTRUST mitigates the potential conflict arising when Clients choose to name their FA as BOR in their capacity as registered representative of CFS. Brokerage Practices affecting Wealth Clients (including nonretirement plan clients such as foundations endowments, and other institutional clients) and Institutional Clients who have granted CAPTRUST discretionary authority are separately disclosed in the CAPTRUST Wealth Brochure and Appendix 1, which are disclosed separately (please see CAPTRUST Wealth Brochure which can be found here: https://www.captrust.com/important-disclosures/). Some Clients may use Bank of New York or an affiliate as a platform/custodian for their plan assets. Therefore, it is material to disclose that as a broker-dealer, CFS has an existing relationship with Pershing, LLC (“Pershing”), an affiliate of Bank of NY, in the form of a clearing agreement. Item 13: Review of Accounts Client accounts are advised by their FA who is responsible for performing periodic reviews and consulting with the respective Client. Additionally, investment company assets in plans are monitored on a continuous and regular basis by CAPTRUST Investment Group as well as CAPTRUST Consulting Solutions Group (“CSG”). Clients who are under an Agreement receive quarterly reviews produced by CAPTRUST for each plan. Ongoing reviews of markets, sectors and individual securities are conducted by the Investment Group. Unaffiliated mutual fund holdings and outside Investment Managers are monitored on a continuous and regular basis by the CAPTRUST Investment Group. Michael Vogelzang, Chief Investment Officer, heads up the Investment Group. ADV Part 2B (attached at end of document) lists the members of the Investment Group who are also members of the Investment Committee or who are involved in the review process and in determining the investment advice to be given by the Adviser. Additionally, monthly and quarterly statements are provided by the Client’s custodian, but additional reports may be provided by third party administrators or other service providers employed by the Client. Clients with portfolios that include private equity and/or other private investments (“private funds”) should be advised that quarterly values lag for up to 60 days following a quarter-end. Because CAPTRUST relies on the Client’s capital account statement (provided by the issuer or qualified custodian) for private fund values used for purposes of quarterly review reports will reflect the latest valuation date available. Consequently, a Client’s actual private fund holdings could be significantly more or less than the value reflected in their CAPTRUST quarterly review report. 15 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Clients agree to inform CAPTRUST in writing of any material changes to the Client’s financial circumstances that may affect advice being rendered to the Client. Clients may contact the Adviser during normal business hours to consult with the firm concerning any such material changes. Item 14: Client Referrals and Other Compensation Clients (or prospective Clients) who are being referred to CAPTRUST, either by means of a paid “endorsement” by a third-party or in connection with a paid “testimonial” by a current Client, must be made aware of the arrangement at the time the testimonial or endorsement is disseminated in a clear and prominent manner. The disclosure of the arrangement must explain whether the testimonial was given by a current Client or investor; or if the “endorsement” was given by a person other than a current Client or investor; explain whether cash or non-cash compensation was provided for the testimonial or endorsement; and if applicable, include brief statement of any material conflicts of interest on the part of the person giving the testimonial or endorsement resulting from the investment adviser's relationship with such person. In cases where a referral takes place in person, these required disclosures will be delivered in writing at the time the testimonial or endorsement is being made. CAPTRUST, has entered into referral agreements with various third-party solicitors (“Solicitors”) for Client referrals. In order for a Solicitor to be compensated by CAPTRUST for referring a Client to CAPTRUST, the solicitor must be engaged by CAPTRUST under a Solicitor or Referral Agreement (a “Referral Agreement”) in compliance with Section 206(4)-1 of the Investment Advisers Act of 1940. In general, a Solicitor is compensated by a percentage of the advisory fee collected for a specified period of time (as detailed in the Referral Agreement). Clients pay no additional fee for the referral over and above CAPTRUST’s quoted advisory fee; to the contrary, the fee the Adviser earns is reduced by the amount of the compensation to the Solicitor. Each Referral Agreement requires the Solicitor to deliver the required disclosures either in writing or via the internet at the time of the testimonial or endorsement is made. CAPTRUST participates in referral programs in which those institutional advisory platform providers to refer Wealth Clients to a CAPTRUST FA who participates in their program. In exchange for those referrals, a portion of the CAPTRUST advisory fee is paid to the referrer. Beginning in 2025, CAPTRUST will participate in a referral program from Empower Advisory Group, LLC (“EAG”), an affiliate of the institutional recordkeeper Empower. As part of this program, EAG will refer to CAPTRUST terminated plan participants who meet certain criteria and who have indicated an interest in speaking with an investment adviser. EAG will only refer terminated plan participants in plans for which the plan sponsor has consented to such a referral program. Plans from which EAG might refer terminated plan participants will generally be retirement plans for which CAPTRUST serves as the investment adviser, but EAG may choose to include plans for which CAPTRUST does not serve as the investment adviser. In exchange for these referrals, CAPTRUST will pay EAG a fee equal to 25% of all advisory and non-advisory revenue actually received by CAPTRUST from the referred Client. CAPTRUST 16 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  will work with EAG to make all disclosures required under Section 206(4)-1 of the Investment Advisers Act of 1940, as amended, at the time of the endorsement. Clients may request details regarding a particular Referral Agreement by contacting us toll- free at (800)216-0645 or sending an email to compliance@captrust.com. Item 15: Custody Clients should receive statements at least quarterly from the qualified custodian that holds and maintains the Client’s investment assets. CAPTRUST urges Clients to carefully review such statements and compare the official custodial records to any reports provided by CAPTRUST. CAPTRUST reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. CAPTRUST does not act as a qualified custodian for Client assets. CAPTRUST discloses in Item 9 of Form ADV Part 1 that it has custody of Clients’ funds or assets for certain purposes (e.g., where a Wealth Client has granted an FA the ability to access the Client’s assets). CAPTRUST is subject to an annual surprise custody examination by an independent certified public accounting firm. Item 16: Investment Discretion For certain CAPTRUST Clients, Adviser has the authority to determine, without obtaining specific Client consent, both the securities to be bought and sold in their accounts as well as the amount of the securities to be bought or sold. The discretionary Agreement covering an ERISA qualified retirement plan gives CAPTRUST the authority to take discretion over the investment selection in that retirement plan. This service elevates CAPTRUST’s fiduciary role to that of an ERISA 3(38) “investment manager” (i.e., when the Client’s retirement plan is subject to ERISA). CAPTRUST acts as a subadvisor with respect to Managed Account Portfolios (“MAPs”) that are collective investment trusts (“CITs”) for which Wilmington Trust (now “Great Gray Trust”) acts as investment manager. Some Clients may grant CAPTRUST ERISA 3(38) discretion over the investment line-up available inside their retirement plan which may also include the MAPs as available investment options for plan participants to select. However, Clients engaging CAPTRUST for non-discretionary ERISA 3(21) advisory services may utilize MAPS as well. CAPTRUST’s separate CAPTRUST Wealth Brochure discloses the level of authority and discretion CAPTRUST is granted, in general, for its Wealth Clients. Adviser may have the authority to negotiate fees on behalf of the Client with its other service providers. Specifically, in its efforts to perform requests for proposals (“RFPs”) on behalf of Clients, Adviser assists the Client in determining the most suitable fee for services structure that can be obtained within the constraints of the retirement plan documents. However, CAPTRUST does not have any control over the fees or commissions charged by custodians or 17 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  investment companies for the products or services they provide. Consequently, the Client may pay fees or commissions higher than obtainable elsewhere for similar products or services. Item 17: Voting Client Securities In general, CAPTRUST Clients delegate the authority to vote their proxies to CAPTRUST in their Agreement. It is CAPTRUST’s aim to see that proxies are voted in the best interest of its Clients. As such, CAPTRUST has engaged Institutional Shareholder Services Inc. (“ISS”), to vote proxies on behalf of Clients who delegate their proxy voting rights to CAPTRUST. ISS is an independent proxy voting service provider, which performs extensive research, and has designed and maintains a number of proxy voting guidelines. While Clients are always free to vote their own proxies, for those that delegate that responsibility to CAPTRUST, CAPTRUST generally leverages ISS Benchmark Proxy Voting Guidelines (“Guidelines”). The Guidelines are based on widely accepted good governance practices and principles, are designed to be responsive to the wide range of issues that can be raised in proxy situations, and to increase total shareholder value and risk mitigation. Additionally, Clients may revoke their delegation of proxy voting authority at any time, with written notice to CAPTRUST. The Proxy Voting Policy contains additional guidelines and methods by which conflicts of interests are addressed. Such conflict may include situations where CAPTRUST has or is seeking a client relationship with the issuer of the security that is the subject of the proxy vote. Generally, because the Guidelines pre-establish voting positions, application should adequately address any possible conflicts of interest. Please note, Freedom401(k) Clients retain the right to vote proxies, so although CAPTRUST has investment discretion, CAPTRUST, generally, does not vote proxies on behalf of Freedom401(k) Clients. To obtain a copy of CAPTRUST’s Proxy Voting Policy or for a copy of CAPTRUST’s Proxy Voting record, Clients can contact CAPTRUST directly at: 800.216.0645 or 919.870.6822 or may email IG.Investment.Admin@captrust.com or write to CAPTRUST “Investment Administration” ” to obtain the information at the address below: CAPTRUST Investment Administration 4208 Six Forks Road, Suite 1700 Raleigh, NC, 27609. Item 18: Financial Information Registered Investment Advisers are required to provide Clients with certain financial information or disclosures about the investment adviser’s financial condition. CAPTRUST has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of any bankruptcy proceedings. Important Disclosures About CAPTRUST’s Privacy Policy and Business Continuity Plan can be found on the CAPTRUST internet site by navigating to: 18 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645   Business Continuity Plan: https://www.captrust.com/business-continuity-plan  Privacy Policy: https://www.captrust.com/privacy-policy/ 19 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645          

Item 1: Cover Page March 18, 2025 CAPTRUST Financial Advisors 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 Firm CRD #175112 Phone: 919.870.6822 Toll Free: 800.216.0645 www.captrust.com This Form ADV Part 2A is the CAPTRUST Wealth Client Brochure (“Brochure” or “Wealth Brochure”), the disclosure brochure for wealth clients and other non-institutional clients utilizing CAPTRUST investment advisory and portfolio management services. If you have any questions about the contents of this Brochure, please contact us by phone at 919.870.6822 or toll-free at 800.216.0645 or by email at compliance@captrust.com. 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. CAPTRUST Financial Advisors is an investment adviser registered under the Investment Advisers Act of 1940. Registration does not imply any level of skill or training. Additional information about CAPTRUST Financial Advisors also is available on the SEC’s website at www.adviserinfo.sec.gov. 1 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 2: Summary of Material Changes This Summary of Material Changes reflects only material changes to this Brochure since our last annual update of this Brochure which was dated March 28, 2024. A full copy of our Brochure may be requested by email at compliance@captrust.com or by contacting us toll- free at 800.216.0645. Item 10 - Other Financial Industry Activities and Affiliations Item 10 has been amended to disclose the following acquisition activity: In the fourth quarter of 2024, CFG acquired the assets of four different firms: Campbell Wealth Management (CRD #152956) in Alexandria, VA, TruNorth Wealth Partners (CRD #284807) in St. Paul, MN, Wealth Covenant Group (CRD #291453) in Houston, TX., and Boston Financial Management (CRD #112360) (“BFM”) with offices in Boston, MA, Centerville, MA, and Portland, ME. CFG also acquired BFM’s wholly-owned subsidiary, Boston Fiduciary Services, LLC, which provides professional trustee and fiduciary services to individuals, businesses, and non-profit organizations. 2 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 3: Table of Contents Item 1: Cover Page .......................................................................................................................................................... 1 Item 2: Summary of 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 ......................................................... 10 Item 7: Types of Clients .............................................................................................................................................. 11 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 11 Item 9: Disciplinary Information ............................................................................................................................. 13 Item 10: Other Financial Industry Activities and Affiliations ..................................................................... 13 Item 11: Code of Ethics ............................................................................................................................................... 15 Item 12: Brokerage Practices ................................................................................................................................... 16 Item 13: Review of Accounts ................................................................................................................................... 19 Item 14: Client Referrals and Other Compensation ...................................................................................... 20 Item 15: Custody .......................................................................................................................................................... 22 Item 16: Investment Discretion .............................................................................................................................. 22 Item 17: Voting Client Securities ........................................................................................................................... 23 Item 18: Financial Information ................................................................................................................................ 24 3 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 4: Advisory Business Introduction CAPTRUST Financial Advisors, also known as CapFinancial Partners, LLC, (“CAPTRUST” or “Adviser”) was established in April 2003 and approved as a registered investment adviser in September 2003. The CapFinancial Group, LLC (“CFG”, a North Carolina limited liability company) owns just under 100% of CAPTRUST. Each of CapFinancial Holdings, Inc. and Halftime Holdings, LLC owns more than 25% of The CapFinancial Group, LLC. GTCR Fund XII B indirectly owns more than 25% of CAPTRUST through its ownership of Halftime Holdings, LLC. CAPTRUST provides investment advisory services to wealth management clients including, but not limited to, individuals, trusts, estates, charitable organizations, foundations, endowments, and corporations (each, a “Client” or “Wealth Client”). CAPTRUST renders continuous and regular investment supervisory services to Clients. CAPTRUST also provides investment advisory services to institutional clients including, but not limited to, retirement plan sponsors, 401(k) plans, 403(b) plans, pensions, profit-sharing plans, non-qualified plans; endowments and foundations; religious organization; and other asset pools (each, an “Institutional Client”). These services are disclosed separately (please see CAPTRUST Institutional Brochure which can be found here: https://www.captrust.com/important-disclosures/). As of December 31, 2024, CAPTRUST managed a total of just under $1.1 trillion in total assets under management, comprised of just over $845 billion in nondiscretionary assets under advisement (primarily Institutional Client assets) and just over $237 billion in discretionary assets under advisement (Institutional and Wealth Client assets). CAPTRUST offers the following services to Clients: Investment Advisory Services  Establishment of Investment Goals and Objectives  Asset Allocation Analysis  Investment Manager Selection / Mutual Fund Evaluation  Ongoing Investment Manager / Mutual Fund Due Diligence  Ongoing Portfolio Performance Measurement  Periodic Review of Client Investment Accounts Compared to Client’s Investment Goals and Objectives 4 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Wealth Planning Services  Discuss Financial Priorities and Identify Wealth Planning Goals  Develop and Implement Financial Planning Recommendations  Monitor Progress Towards Goals and Reevaluate them Periodically  Evaluate Estate Planning Needs  Tax Planning  Charitable Planning  Coordinate Wealth Planning Objectives with Other Professional Advisors Tax Related Services, Family Office, and Other Ancillary Services  Tax Consulting and Planning  Tax Return Preparation  Bill Pay and Bookkeeping Investment Supervisory Services Adviser provides investment supervisory services on a discretionary and non-discretionary basis including, but not limited to the following:  Adviser designs, revises, and reallocates a Client’s custom portfolios. Investments are determined based upon the Client’s investment objectives, risk tolerance, net worth, net income, age, time horizon, tax situation, and other suitability factors.  Adviser manages the Client’s custom accounts on an individualized basis. Restrictions and guidelines imposed by Clients may affect the composition and performance of custom portfolios (as a result, performance of custom portfolios within the same investment objective may differ and Clients should not expect that the performance of their custom portfolios will be identical to any other individual’s portfolio performance).  Adviser uses the services of sub-advisers and established third party research services to assist Adviser with formulating asset allocation, industry and sector selection, and individual security investment recommendations in constructing and maintaining custom portfolios. Adviser’s Clients enter into a fee-based agreement for investment supervisory services. Advisory fees stated in CAPTRUST’s fee-based agreements may or may not include the cost of transactions/trade executions, depending upon the type of account the client chooses and whether the fee is negotiated on “wrap fee” or “non-wrap fee” basis. Advisory Fees may be higher or lower than obtainable elsewhere. Wrap Fee Accounts CAPTRUST sponsors wrap fee program services (see “CAPTRUST Wrap Fee Programs Brochure” at Appendix 1 to this Brochure for a complete description of the wrap fee programs offered through CAPTRUST). Wrap fee programs are designed to help Clients identify their investment needs and obtain professional asset management for a convenient single "wrap" fee that includes both the cost of transactions/executions and investment 5 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  advisory fees. Wrap fee programs may be offered through portfolio management account (“PMA”) services, in which CAPTRUST provides PMA services, or separately managed account (“SMA”) services, in which CAPTRUST recommends and the Client selects a third- party manager. An investor should consider all the information within the CAPTRUST Wrap Fee Programs Brochure before participating in a wrap fee program. The information in the CAPTRUST Wrap Fee Programs Brochure has not been approved or verified by any governmental authority. CAPTRUST sponsored wrap free programs include programs with accounts held at Pershing, LLC (“Pershing”). CAPTRUST also participates in wrap fee programs sponsored by the Schwab Advisor Services division of Charles Schwab & Co. Inc. (“Schwab”), i.e., Schwab’s Managed Account Select and Managed Account Access. SMA Accounts CAPTRUST performs due diligence on various independent investment managers. Based on the Client's individual circumstances, CAPTRUST determines which SMA manager's portfolio management style is appropriate for that Client. Factors considered in making this determination include account size, risk tolerance, the objectives of each Client and the investment philosophy of the selected manager. Clients should refer to their SMA manager's disclosure brochure or other disclosure documents for a full description of the services offered. CAPTRUST will furnish a copy of the disclosure brochures for each SMA manager recommended. CAPTRUST may recommend one or more SMA managers to manage a Client's assets on a discretionary basis. CAPTRUST monitors the performance of the SMA managers on an ongoing basis. Some Clients with their accounts at Schwab have accessed SMA managers though Schwab’s Managed Account Marketplace (which is not a wrap-fee program). These Schwab programs allow access to independent SMA investment management firms offered by Schwab. With the exception of CAPTRUST’s SMA Wrap Fee Program, CAPTRUST’s fee is independent of the fee charged by SMA managers for the management of separate accounts. Fees associated with SMA managers vary and are separately disclosed in each manager’s disclosure brochure and, depending on the SMA program chosen by the client, may or may not include the cost of execution. CAPTRUST will make its recommendations in the best interest of the Client, taking into account the Client’s preferences. Schwab SMA Programs Schwab’s Managed Account Select and Managed Account Access fees are bundled as a single, all-inclusive wrap fee, which is in addition to the fee charged by CAPTRUST. For Clients who have chosen one of these programs, CAPTRUST will deliver Schwab’s brochure, which explains how Schwab calculates their SMA program fees. Generally, Schwab multiplies the actual daily balance of the Client’s account by the daily pro rata portion of the annual rate and then adds together the fees for each day of the month. The program fee is billed to the Client’s account monthly, which may result in Clients paying a higher fee on an annual basis than the annual rate due to the effects of compounding. 6 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Managed accounts established under the Schwab’s Managed Account Marketplace (non-wrap fee accounts) are charged separately by Schwab for brokerage and custody services and by the SMA manager under the SMA manager’s advisory agreement. In general, access to managers in Schwab’s programs is available at the following account levels: $100,000 for Stock/Equity Managers and $250,000 for Bond/Fixed Income Managers. Although some money managers may have higher account minimums. Schwab’s program fees include the institutional money manager fee, Schwab’s program fee and fees for brokerage/clearing/custodial services. Fees may include a minimum monthly fee. Please see related program documents for a complete description of specific fees. Depending on the service utilized, program fees for the SMA services may be up to 3.00%, depending on the services provided. Subadvisory Agreements CAPTRUST occasionally establishes a subadvisory agreement with an SMA manager that may or may not participate in one or more of the programs described in this section. Under this type of arrangement, CAPTRUST’s fee can be quoted to include or exclude the subadvisor’s fee. In this way, Clients can decide whether to permit the subadvisor to charge their fee directly to the Client’s account or to have CAPTRUST combine their fee to include the subadvisor’s fee. Either way, the advisory agreement governing the relationship describes the method by which advisory fees will be charged and paid and whether the quoted fee includes both CAPTRUST’s fee and subadvisory fees. Other Investment Advisor Services CAPTRUST provides investment advisory services that do not involve investment supervisory services on a discretionary or non-discretionary basis. Consultations. Adviser furnishes investment advice through individual consultations. To the extent it is requested to do so, Adviser provides Clients with investment advisory and consultation services on a “fee for service” basis. In order to determine a suitable course of action for an individual Client, Adviser performs a review of the variables that are presented. Such review may include, but would not necessarily be limited to, investment objectives, consideration of the Client’s overall financial condition, income and tax status, personal and business assets, risk profile, and other factors unique to the Client’s particular circumstances. Adviser obtains pertinent information from the Client to assist Adviser in determining the most appropriate course of action for its Client’s financial and investment activity. Alternative Investments. Adviser offers advice on private placements and/or limited partnerships that are considered “alternative investments.” Adviser also offers advice on private equity funds that contain investments in equities, futures, options, and other securities. Any such recommendation will be made only when determined to be suitable and must be accompanied by or preceded by a prospectus or offering memorandum. See Item 10 below for a detailed description of material conflicts regarding private funds. 7 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 5: Fees and Compensation Advisory Fees As noted above, CAPTRUST advisory fees are typically charged quarterly in advance based on the market value of the Client’s account on the last business day of the previous calendar quarter. Clients who have assigned their advisory agreements to CAPTRUST in connection with an acquisition may pay their advisory fees in arrears. In either case, the terms of the advisory agreement determine the fee arrangements. Additions to and withdrawals from an account during a quarter will be reflected in a fee adjustment in the following quarter’s client statement. Fees generally are deducted from the Client’s account or may be direct billed to the Client or to a third-party custodian at the Client’s instruction. Some client portfolios include private equity and/or other private investments for which quarterly values lag for up to 60 days following a quarter-end. In those limited cases, CAPTRUST uses the latest valuation date available for purposes of computing investment advisory fees. CAPTRUST relies on the Client’s capital account statement (provided by the issuer or qualified custodian) for the values of such private investments. The advisory agreement continues in effect until terminated by either party upon thirty days written notice to the other party. However, if the Client has not received this Brochure at least 48 hours prior to entering into the advisory agreement, the Client may terminate the advisory agreement within five business days of entering into the advisory agreement without penalty. If any advisory relationship terminates before the last day of a quarter, fees are prorated accordingly, and the Adviser will refund any unearned fees due to the Client. Fees, minimum account sizes, and services are negotiable and may be waived under certain circumstances. For example, Adviser, in its sole discretion, may charge a lesser (or no) advisory fee based upon certain criteria (e.g., existing financial planning client relationship, anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with Client). Adviser’s fees for these services are negotiable depending on the specific type of investment management services to be rendered (as detailed in the advisory agreement), but generally will be calculated as a percentage of total assets under management according to the following schedule: Gross Market Value 0-$500,000 $500,001 – $1,000,000 $1,000,001 – $2,000,000 $2,000,001 - $5,000,000 Over $5,000,000 Maximum Annual Fee 2.25% 2.00% 1.75% 1.25% 1.00% Advisory fees are subject to negotiation. When negotiating fees, factors considered, but not limited to, include: (i) clients with multiple accounts; (ii) size of the account; (iii) a prior or existing relationship; and (iv) a client’s particular needs or financial characteristics. Since fees 8 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  vary, Clients with existing accounts may be charged fees not precisely matching the foregoing fee schedules or the fees paid by other Clients. CAPTRUST may give advice to one Client that may be different from the advice given to another Client. Clients should consider the value of the additional consulting services when making such comparisons. Certain combinations of custodial, consulting, and brokerage services may not be available separately or may require multiple accounts, documentation, and fees. For Clients who do not elect a “wrap-fee” account, CAPTRUST’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses incurred by the Client. Clients who elect to use CAPTRUST wrap program should refer to the CAPTRUST Wrap Fee Programs Brochure for a description of fees. Clients may incur certain charges imposed by custodians, brokers, third party investment advisors, and other third parties, such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange-traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. These charges and fees are exclusive of and in addition to CAPTRUST’s fee. CAPTRUST is independently owned and operated and not affiliated with any custodial broker-dealer. Clients choose the brokerage platform to hold their investment accounts. CAPTRUST has prime broker and/or brokerage custody agreements to provide execution, brokerage and custodial account services to CAPTRUST clients with Schwab, Pershing, and Fidelity Investments through Fidelity Brokerage Services, LLC/National Financial Services, LLC (“Fidelity”). In general, Clients use Schwab, Pershing, or Fidelity for execution and custodial services (each such provider, a “custodian”). Custodians are FINRA registered broker-dealers. Some Clients choose to use custodians other than Pershing, Fidelity, or Schwab (such as trust companies). In those cases, CAPTRUST works with the Client’s chosen custodian to manage the Client’s investments. Custodial and execution fees charged by custodians vary so that Clients may pay more or less for similar services than Clients who choose a different custodian. Adviser may recommend Clients invest in funds-of-funds. Funds-of-funds typically carry additional fees over and above the fees discussed in this section. Because hedge fund managers typically charge performance fees (over and above their management fee) and because funds-of-funds are comprised of allocations to many hedge fund managers, each manager charges its own management fee and many also charge performance fees which creates a layering effect. Consequently, Clients should be aware of these additional costs associated with investing in funds-of-funds. Each fund-of-fund discloses its own fee structure in the prospectus for that fund. In general, CAPTRUST does not receive any portion of these charges, fees and costs, however, please refer to Item 6 below for more information on the limited cases when CAPTRUST participates in performance fees. 9 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  12b-1 and Other Miscellaneous Fees Generally, CAPTRUST purchases institutional class or no-load mutual funds in investment portfolios which do not generate sales charges. Load and no-load mutual funds may pay annual distribution charges, sometimes referred to as 12b-1 fees. These 12b-1 fees come from fund assets, and therefore indirectly from Client assets. Client’s custodian may be compensated by 12b-1 fees for general promotion, advertising, and distribution in relation to Client purchases and sales of mutual fund shares in a managed account. CAPTRUST does not participate in 12b-1 fees. Other costs that may be assessed that are not part of those outlined above include fees for portfolio transactions executed away from the custodian selected by the Client, dealer mark- ups, electronic fund and wire transfers, spreads paid to market-makers, and exchange fees. Custodian may charge Client certain additional and/or minimum fees. Fixed Fee Service. Some Clients engage CAPTRUST to provide investment advisory, consultation or other ancillary services for a fixed or flat fee. Fixed fees are negotiable, but generally range from $10,000 to $250,000 on an annual basis, depending upon the level and scope of the services required. Adviser’s fixed rate is determined based on anticipated work to be done. Fixed fees will be charged quarterly in advance calculated on a per diem basis upon the signing of an agreement by the Client. Fees for Clients engaging Adviser mid- quarter will be prorated on a per diem basis. Hourly Fee Service. When performing family office and/or other ancillary services, including tax consulting and planning, accounting/tax preparation, and bill pay, CAPTRUST charges hourly fees that can range from $50 to $500 per hour depending upon the type and complexity of the ancillary services to be provided. These services and fees will be negotiated and agreed upon with the Client, prior to performing the services. Item 6: Performance-Based Fees and Side-By-Side Management In general, CAPTRUST does not charge performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a Client). Please see Item 10 – “Other Financial Industry Activities and Affiliations – Material Conflicts Regarding Private Funds” for a detailed explanation of conflicts in connection to the One Brick Select Private Credit Fund, LP and One Brick Select Private Credit Qualified Fund I, LP (collectively, the “One Brick Funds”) which invest in T. Rowe Price OHA Select Private Credit Fund (“OCredit”). Incentive fees earned by OCredit will be shared with investors in the One Brick Funds. CAPTRUST does not charge performance fees to the One Brick Funds, but indirectly participates in fees earned by OCredit. The assets in the One Brick Funds represent less than 0.006% of all Client assets. 10 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 7: Types of Clients CAPTRUST provides investment advisory services to Wealth Clients, including but not limited to, individuals, high net worth individuals, trusts, estates, charitable organizations, foundations, endowments, and corporate entities. CAPTRUST also provides advisory services to Institutional Clients including, but not limited to, 401(k) plans, 403(b) plans, pensions and profit-sharing plans, non-qualified plans, foundations, endowments, corporations. These services are disclosed separately in CAPTRUST’s Institutional Brochure. CAPTRUST generally maintains a minimum account size requirement for its Wealth Clients of $50,000 to initially establish an account. The value of this account is subject to fluctuation, and therefore there is not a minimum maintenance requirement. Adviser retains the right to waive minimum initial account sizes should Adviser feel it is necessary and appropriate. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss CAPTRUST’s investment strategy begins with an understanding of a Client’s financial goals. Adviser uses demographic and financial information provided by the Client to assess the Client’s risk profile and investment objectives when determining an appropriate plan for the Client’s assets. Investment strategies generally include long or short-term purchases of stock portfolios, mutual funds, exchange traded funds, fixed income securities, and other investment vehicles where appropriate, and may include margin transactions and options strategies. Investment strategies. CAPTRUST uses both a risk-based and outcome-based approach to asset allocation. Client portfolios will predominantly be invested in the following asset classes: US equities, international equities, fixed income, alternative investments (strategic opportunities), commodities, and real estate. CAPTRUST Financial Advisors may build custom allocations for Clients or select from pre- built models managed by the Investment Committee. Investment recommendations, including model selection, are based on an analysis of the Client’s individual needs and are drawn from research and analysis. In general, investment analysis methods may include fundamental analysis as well as quantitative and qualitative research on a given investment vehicle. Information for this analysis may be drawn from financial newspapers, magazines and databases, research materials prepared by others, annual reports, corporate filings, and prospectuses. Additional sources of information utilized by CAPTRUST include meetings and discussions with investment managers employed by investment companies, statistical summaries and analysis and such other sources CAPTRUST deems appropriate. CAPTRUST may utilize services of subadvisers and established third party research services to assist CAPTRUST with formulating asset allocation, industry and sector selection, and investment recommendations in managing the Client’s funds. Technical analysis may be used when analyzing indices and/or securities. 11 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  It is important to note that investing in securities involves certain risks that are borne by the investor. For risks associated with investment company (mutual fund) products, Clients should refer to fund prospectuses. Our investment approach constantly keeps the risk of loss in mind. These risks include, but are not limited to:  Interest rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market value to decline.  Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events.  Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.  Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities.  Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.  Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Some funds, such as interval funds, that could be utilized in select strategies employed by CAPTRUST, carry liquidity risk. In some circumstances, Clients have had to wait several quarters or longer when requesting liquidity from the manager of interval funds within select CAPTRUST asset allocated model strategies that utilize these semi- liquid instruments.  Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value.  Concentration Risk: The probability of loss due to heavy exposure to a single investment, equity or issuer. Some funds utilized in model strategies employed by CAPTRUST, carry a kind of concentration risk because Clients may own more than one fund managed by the same issuer; or Clients may be invested in several funds with similar strategies which poses a type of concentration risk. Another form of concentration risk occurs when one group of Clients comprise a large portion of a mutual fund’s total asset base, those Clients experience an additional risk over and above the risks associated with the investment’s strategy due directly to the concentration of their assets in that fund. CAPTRUST strategies may involve some or all of the types of concentration risk described here.  Other risks: CAPTRUST’s recommended strategies include the risks listed above as well as other risks that are more specifically associated with managers, strategies, funds, or instruments CAPTRUST selects or recommends. For example, some recommended managers use derivatives (e.g., options as a hedge) which pose special risks; others carry liquidity risk specific to underlying investments; additionally, some of Adviser’s 12 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  asset allocated model strategies have a particular concentration risk because Adviser may allocate a large portion of a portfolio to a single manager, or a fund complex. Some portfolios include alternative or uncommon investment strategies, or allocations to funds with limited or no prior history of operations. Each recommended manager discloses risks associated with investing in their funds separately in their respective brochures and/or prospectuses. o Although CAPTRUST acknowledges that Clients are relying on CAPTRUST to manage portfolio risk, Clients are encouraged to read managers’ disclosure brochures and prospectuses and ask questions of CAPTRUST’S Financial Advisors, Investment Committee members, or compliance team members. Please contact us at 919.870.6822 or send a message to compliance@captrust.com.  Private investment funds: Clients who are qualified to invest in private funds must acknowledge and accept the specific risk factors that are associated with investing in private funds. Private fund investments involve various risk factors, including, but not limited to, potential for complete loss of principal, illiquidity, and lack of transparency. Item 9: Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a Client or prospective Client’s evaluation of CAPTRUST or the integrity of CAPTRUST’s management. Neither CAPTRUST management nor members of CAPTRUST’s Investment Committee have any reportable disciplinary history for this Item. Each Financial Advisor who acts as a Portfolio Manager has a separate Form ADV Part 2B. Please refer to Form ADV Part 2B for personal disciplinary information for individual Financial Advisors. Item 10: Other Financial Industry Activities and Affiliations CAPTRUST is affiliated by common ownership to CapFinancial Securities, LLC (“CFS”), a FINRA broker-dealer (Member SIPC). CAPTRUST does not manage any proprietary mutual funds. CFS, as an affiliated registered broker-dealer, provides individuals and institutions with general securities investment services. Many Investment Adviser Representatives with Adviser are also registered as CFS Registered Representatives. A CAPTRUST Financial Advisor who focuses primarily on wealth advisory services generally spends less than 10% of their time on work done for Clients focused on activities consistent with the definition of broker-dealer activities. A CAPTRUST Financial Advisor whose focus is Institutional Clients will generally spend less than 1% of their time on broker-dealer activities. CAPTRUST business divisions called “1776 Advisor Group,” “Strategic Advisor Group,” and “Family Office Risk Advisors” together with several CAPTRUST Financial Advisors, are licensed to act as agent of record for Clients who own life insurance products or for retirement plans funded with group variable products. Financial Advisors may occasionally recommend fixed or variable annuities or life insurance (including Private Placement Life 13 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Insurance (“PPLI”) to their Wealth Clients when assisting them in executing their financial plan. CFS and CAPTRUST have business entity insurance licenses. Strategic Advisor Group’s primary source of revenue is life insurance commissions not involving CAPTRUST qualified retirement plan clients. As a result of certain investment-related recommendations provided to its Clients, CFS may facilitate certain securities purchases and/or sales, or insurance product purchases and/or sales on behalf of CAPTRUST Clients. Such transactions may be facilitated by CFS, in its capacity as a registered broker-dealer or insurance agent/agency (business entity). Commissions charged by CFS may be higher or lower than obtainable elsewhere. When CFS is being compensated by commissions, general promotion, advertising, and distribution fees (such as 12b-1 fees) in relation to purchases and sales of commission-based investment products or mutual fund shares, CAPTRUST does not also charge an advisory fee on those assets but includes the accounts at a 0% advisory fee. In the fourth quarter of 2024, CFG acquired the assets of four different firms: Campbell Wealth Management (CRD #152956) in Alexandria, VA, TruNorth Wealth Partners (CRD #284807) in St. Paul, MN, Wealth Covenant Group (CRD #291453) in Houston, TX., and Boston Financial Management (CRD #112360) (“BFM”) with offices in Boston, MA, Centerville, MA, and Portland, ME. CFG also acquired BFM’s wholly-owned subsidiary, Boston Fiduciary Services, LLC, which provides professional trustee and fiduciary services to individuals, businesses, and non-profit organizations. Material Conflicts Regarding Private Funds CAPTRUST provides investment recommendations and advice regarding both affiliated and non-affiliated private investment funds. CAPTRUST provides the fund’s offering materials at or prior to recommending the investment. Clients should refer to the fund’s confidential offering memorandum for applicable disclosures regarding management of the fund, its investment objective, risk factors, tax, and related factors. One Brick. CAPTRUST serves as investment advisor to One Brick Select Private Equity 2024, L.P. CAIS One Brick Select Private Equity 2024 GP LLC, an unaffiliated entity, serves as general partner. CAPTRUST also serves as investment advisor to One Brick Select Private Credit Fund, LP and One Brick Select Private Credit Qualified Fund I, LP (the “One Brick Funds”), for which PPB Capital Partners ("PPB") serves as general partner and fund administrator. The One Brick Funds invest in T. Rowe Price OHA Select Private Credit Fund (“OCredit”). OHA Private Credit Advisors LLC (“OHA Advisor”) is the investment adviser to OCredit. OCredit pays OHA Advisor an incentive fee for serving as its investment manager. As more people invest in OCredit, OHA Advisor will earn more fees. One Brick Funds will also share in those incentive fees, which creates an incentive for CAPTRUST to recommend OCredit in order to increase the potential profits eligible to be shared with investors in the One Brick Funds which include CAPTRUST Clients and employees. (Please see Item 6.). One Brick Funds pay nominal fees to PPB for fund administration as well as 10bps/year in advisory fees to CAPTRUST.  14 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Homecourt. CAPTRUST is the owner of CAPTRUST 2022 Homecourt Fund GP, LLC, a Delaware single member limited liability company, for which the sole purpose was the organization of a private fund called CAPTRUST 2022 Homecourt Fund, L.P. (“Homecourt”). Homecourt was formed as an “Access Fund” into Dyal HomeCourt US Investors LP (“Dyal”), and independent third party private limited partnership. CAPTRUST acts as the investment adviser to Homecourt. The interests were offered pursuant to an exemption from the registration requirements of the Securities Act of 1933, as amended (the “Securities Act”). Each investor must be a U.S. person that is a person with the requisite skill and expertise to adequately assess the risks of investing in the Access Fund (and indirectly investing in the Underlying Fund); an “accredited investor” as defined within the meaning of Rule 501(a) of Regulation D promulgated under the Securities Act; a “qualified purchaser” as defined under the Investment Company Act, and a “qualified client,” as defined under the U.S. Investment Advisers Act of 1940, as amended, and the rules and regulations promulgated thereunder (the “Advisers Act”). There is no public market for the interests, and no such market is expected to develop in the future. CAPTRUST’s “Management Fee Rate” is 0.10% per annum (e.g. 0.025% per quarter) for limited partners who are Clients and 1.00% per annum (e.g. 0.25% per quarter) for limited partners who are no longer Clients. MRA. CAPTRUST acts as investment adviser to a series of private funds, namely, MR Investment Fund 1 LLC, MRA Opportunities Fund 1-A, MRA Opportunities Fund 1-B, MRA Credit Strategies Fund 1-A Fund LP, and MRA Credit Strategies Fund 1-B Fund LP. SALI. CAPTRUST acts as subadvisor to three private funds, Covenant Global Equities Fund Series Interests of the SALI Multi-Series Fund II 3(c)(1), LP, Covenant Global Equities Fund Series Interests of the SALI Multi-Series Fund II, L.P., and Vega Multi-Strategy Fund Series of the SALI Multi-Series Fund, L.P., for which SALI Fund Services acts as investment advisor and fund administrator. TRUSTCORE. CAPTRUST acts as subadvisor to Trustcore Private Opportunities Fund, LP for which PPB Advisors acts as investment advisor and NAV Consulting provides fund administration. RINET. CAPTRUST and RINET Company, LLC entered into a limited (administrative) services agreement whereby CAPTRUST will assist RINET in winding down four private funds RINET manages. Item 11: Code of Ethics CAPTRUST’s Code of Ethics addresses, among other things: (i) CAPTRUST’s fiduciary obligations to its Clients, (ii) personal securities trading procedures restricting the purchase and sale, by employees for their own accounts, of specific securities; (iii) provisions relating to the confidentiality of Client information; (iv) a prohibition on insider trading; (v) limits on political contributions; and (vi) restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment. 15 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Personal transactions in securities by directors, officers, and employees of CAPTRUST who have access to nonpublic information regarding Clients’ purchase and sale of securities, are involved in making securities recommendations to Clients, or who have access to such non- public recommendations are subject to the restrictions and procedures in CAPTRUST’s Code of Ethics. All employees at CAPTRUST must acknowledge the terms of the Code of Ethics annually, or as amended. Occasionally, Adviser’s employees may recommend that Clients buy or sell the same securities or investment products that Adviser’s employees also own. CAPTRUST’s employees and persons associated with CAPTRUST are required to follow the Code of Ethics. The Code of Ethics is intended to identify and address potential conflicts of interest that might arise in the context of personal securities transactions, activities, and interests of CAPTRUST employees that might interfere or appear to interfere with making decisions in the best interest of advisory Clients. Under the Code of Ethics certain classes of securities have been designated as exempt transactions, based upon a determination that they would not materially interfere with the best interest of CAPTRUST’s Clients. In addition, the Code of Ethics requires pre-approval of specific types of transactions, and, depending on the transaction, may restrict trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as Clients, there is a possibility that employees might benefit from market activity by a Client. Employee trading is monitored under the Code of Ethics to reasonably prevent conflicts of interest between CAPTRUST and its Clients. CAPTRUST employees whose accounts are managed by CAPTRUST are included in block trading where CAPTRUST places trades for execution that include accounts of two or more clients and when CAPTRUST believes trade aggregation is appropriate and in the best interest of its Clients. (See “Block Trades” under “Brokerage Practices” below for additional information). CAPTRUST’s Clients may request a copy of the Adviser’s Code of Ethics by contacting the Compliance Department at 919.870.6822 or 800.216.0645 or by email at compliance@captrust.com. Item 12: Brokerage Practices Some CAPTRUST Financial Advisors (Investment Adviser Representatives) also affect securities transactions for Clients as registered representatives of a broker-dealer (see Item 10). Further, Adviser or its associated persons may receive compensation for such transactions, where such compensation is separate and distinct from Adviser’s compensation related to its investment advisory services. All FINRA, SEC, and other regulatory agencies disclosure requirements and policies are observed for all transactions. Wrap Fee Programs. Clients who have chosen a wrap fee arrangement when utilizing a brokerage platform should review the CAPTRUST Wrap Fee Programs Brochure, available at 16 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  https://captrust.com/important-disclosures, for a description of wrap fee programs sponsored by CAPTRUST. CAPTRUST uses risk-based and outcomes-based approaches to portfolio management. Regardless of whether a Client is in a wrap or a non-wrap account, when executing trade orders within a risk-based strategy described in Item 8, trades for accounts are blocked together at each of the three custodians if the objectives and/or instructions for the order are similar. Block Trades. CAPTRUST may aggregate, or “block” orders being placed for execution at the same time for the accounts of two or more Clients, where it believes such aggregation is appropriate and in the best interest of the Clients. All accounts within the block will receive the same execution price on each trade date. This practice may include accounts in which CAPTRUST’s affiliates and employees have an ownership interest. However, CAPTRUST is not obligated to block orders or to include any account in a blocked order if portfolio management decisions for such accounts are made separately or if CAPTRUST determines that blocking trades would be inconsistent with the Adviser’s investment management duties. These duties may include the consideration of any investment objectives, guidelines, special requests, or restrictions applicable to a particular account. All block orders placed for execution are subject to CAPTRUST’s Trade Allocation Procedures. Under these procedures, CAPTRUST will block orders where appropriate for the participating Clients and when consistent with CAPTRUST's duty to seek best execution. Prior to or contemporaneous with the entry of a blocked order, CAPTRUST will capture the pre- allocation for the blocked trade identifying Client accounts or trading groups of Client accounts participating in the blocked order detailed either in dollars, number of shares, or percent of market value for the referenced Client accounts. Based on the individual market for security, CAPTRUST may not receive complete execution on the entire volume of securities purchased or sold during a single trading session. Thus, the effect of the aggregation may operate in some circumstances to a particular Client’s disadvantage. When a blocked order is partially filled, the securities purchased or sold by the close of each business day will be allocated in a manner that is consistent with the initial pre- allocation statement and does not consistently advantage or disadvantage particular Clients or groups of Client accounts. However, adjustments to the allocation may be made to avoid de minimis allocations to Client accounts or to avoid deviations from pre-determined holding limits or other such limitations established for any account. CAPTRUST will retain records of the trade order specifying each participating account and its allocation. Although CAPTRUST generally attempts to block trades for Client accounts, aggregation may not be possible because of that Client’s specific brokerage arrangements or other factors. The majority of CAPTRUST PMA & SMA Wrap Fee accounts use Pershing as their custodian. Some Clients may select Schwab, Fidelity, or upon occasion, other financial institutions to act as custodian and broker/dealer for their accounts. When the Investment Committee, a Portfolio Manager, or Investment Strategist implements a portfolio decision or strategy ahead of or contemporaneously with similar portfolio decisions or strategies of other Clients certain factors may create less favorable execution results when compared to other Clients. Such factors may include liquidity constraints, potential market impact or the time executions occur at different custodians. While CAPTRUST makes every effort to reduce conflicts of 17 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  interest, there can be no assurance that any actual or potential conflicts of interest will not result in a particular Client or group of Clients receiving less favorable investment terms or returns from certain investments than if such conflicts of interest did not exist. For CAPTRUST Client accounts maintained by the custodians, custodians generally do not charge separately for custody services but may be compensated by account holders through commissions and other transaction-related or asset-based fees for securities trades that are executed through the custodian or that settle in accounts held by the custodian. Custodians may also make available to CAPTRUST products and services that could benefit CAPTRUST but may not benefit all Clients’ accounts. Some of these other products and services assist CAPTRUST in managing and administering Client accounts. These include software and other technology that provide access to Client account data (such as trade confirmations and account statements); the facilitation of trade execution and allocation of aggregated trade orders for multiple client accounts; research, pricing information and other market data; facilitating payment of CAPTRUST’s fees from its Clients’ accounts; and assistance with back-office functions, recordkeeping and client reporting. Many of these services generally may be used to service all or a substantial number of CAPTRUST’s accounts, including accounts not maintained at the custodian. The foregoing arrangements pose a conflict of interest to the extent they create an incentive for CAPTRUST to suggest that Clients maintain their assets in accounts at a custodian based on products and services that may become available to CAPTRUST rather than solely based on the nature, cost or quality of custody and brokerage services provided by custodian to Clients. However, CAPTRUST is constrained by fiduciary principles to act in its Clients’ best interests and will suggest a custodian to clients only when it is appropriate to do so. In addition, CAPTRUST maintains an awareness of the services provided to Clients by these custodians to confirm that Clients are well served by these partners. In general, when a trade error occurs in a managed account CAPTRUST absorbs the loss from correcting transactions and the custodian typically makes a charitable donation of any resulting profit. However, each custodian handles trade error corrections slightly differently. CAPTRUST has controls in place to limit trade errors. Some transactions that must be made by application or subscription agreement will be facilitated directly with the fund administrator, insurance company, or other legal entity responsible for effecting such transactions. While most of the Adviser’s business is done on a fee basis, an investment adviser representative may be compensated in connection to a transaction (by commission) when appointed by the client as “broker or agent of record” for a direct-to-the-fund account set up through CFS. In that case, CFS may be compensated by commissions, general promotion, advertising, and distribution fees (such as 12b-1 fees) in relation to purchases and sales of commission-based investment products or mutual fund shares in those types of accounts. There are a limited number of these non-advisory commissions-based Client accounts. CAPTRUST advises these types of accounts at a 0% advisory fee. CAPTRUST Clients utilize the brokerage platforms provided by Pershing, Fidelity, or Schwab. While CAPTRUST does have the ability to negotiate fees or commissions on behalf of Clients, 18 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  CAPTRUST does not direct brokerage to a particular venue for execution, but rather relies on Pershing, Schwab, or Fidelity to utilize their resources to select the most appropriate venue for execution. An exception to this practice involves bond trades that are directed by a CAPTRUST Financial Advisor to an executing broker dealer. Fees and commissions charged by these brokerage platforms may be higher or lower than obtainable elsewhere. Circumstances occasionally arise when the brokerage platforms must impose a separate or special handling or custodial charge for acting as custodian for an exempt security or private placement that was recommended by CAPTRUST to a CAPTRUST advisory Client. On a case-by-case basis, CAPTRUST may cover the cost of this type of fee on a “value-added” basis by having the fee directly billed to CAPTRUST rather than the Client or by reimbursing the Client. Finally, CAPTRUST participates in several referral programs offered by the custodians that benefit CAPTRUST which are identified in the detailed disclosure under Item 14 (below). Item 13: Review of Accounts Client accounts are advised by the Client’s Financial Advisor who is responsible for performing periodic reviews, consulting with their Clients, and staying abreast of changes to their Clients’ goals and objectives. Ongoing reviews of markets, sectors, and individual securities are conducted by the Investment Group. Unaffiliated mutual fund holdings and outside Investment Managers are monitored on a continuous and regular basis by the CAPTRUST Investment Group. Michael Vogelzang, Chief Investment Officer, leads the Investment Group. ADV Part 2B (attached to this Brochure) lists the members of the Investment Group who are also members of the Investment Committee or who are involved in the review process and in determining the investment advice to be given by the Adviser. In addition to monthly statements provided by the custodian of the Client’s assets, CAPTRUST prepares quarterly performance reports for Wealth Client accounts. Clients may access their quarterly performance reports electronically via CAPTRUST’s client portal. Clients should contact their Financial Advisor, or contact CAPTRUST at the contact details in Item 1, for questions about how to access their reports. CAPTRUST receives a daily download of transaction information from Pershing, Schwab, and Fidelity and has access to Wealth Client accounts through their institutional advisor platforms. Clients agree to inform CAPTRUST in writing of any material changes to the Client’s investment goals and objectives or financial situation that might affect the manner with which Client’s assets should be invested. Additionally, Clients who wish to impose reasonable restrictions on the management of their accounts may do so by contacting their Financial Advisor or CAPTRUST at the contact details in Item 1. Clients with portfolios that include private equity and/or other private investments (“private funds”) should be advised that quarterly values lag for up to 60 days following a quarter-end. Because CAPTRUST relies on the Client’s capital account statement (provided by the issuer or qualified custodian) for private fund values used for purposes of quarterly portfolio review and reporting, quarterly review reports will reflect the latest valuation date available. Consequently, a Client’s actual private fund holdings could be significantly more or less than the value reflected on their portfolio report. Unless otherwise indicated, the Client’s advisory 19 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  fee will be based upon the value reflected in CAPTRUST’s client portal . Clients may contact CAPTRUST during normal business hours to consult with CAPTRUST concerning the management of the Client’s accounts. Item 14: Client Referrals and Other Compensation Clients (or prospective Clients) who are being referred to CAPTRUST, either by means of a paid endorsement by a third-party or in connection with a paid testimonial by a current client, must be made aware of the arrangement at the time the testimonial or endorsement is disseminated in a clear and prominent manner. The disclosure of the arrangement must explain whether the testimonial was given by a current Client or investor; or if the endorsement was given by a person other than a current Client or investor; explain whether cash or non-cash compensation was provided for the testimonial or endorsement; and if applicable, include brief statement of any material conflicts of interest on the part of the person giving the testimonial or endorsement resulting from the investment adviser's relationship with such person. In cases where a referral takes place in person, these required disclosures will be delivered in writing at the time the testimonial or endorsement is being mad. CAPTRUST has entered into referral agreements with various third-party solicitors for Client referrals. For a solicitor to be compensated by CAPTRUST for referring a Client to CAPTRUST, the solicitor must be engaged by CAPTRUST under a solicitor or referral agreement (“Referral Agreement”) in compliance with Rule 206(4)-1 under the Investment Advisers Act of 1940. In general, a solicitor is compensated by a percentage of the advisory fee collected for a specified period of time (as detailed in the Referral Agreement). Clients pay no additional fee for the referral over and above CAPTRUST’s quoted advisory fee; to the contrary, the fee the Adviser earns is reduced by the amount of the compensation to the solicitor. Each Referral Agreement requires the solicitor to deliver the required disclosures either in writing or via the internet at the time of the testimonial or endorsement is made. Clients may request details regarding a particular Referral Agreement by contacting CAPTRUST at the contact details in Item 1. Schwab Advisor Network® CAPTRUST receives client referrals from Schwab through CAPTRUST’s participation in Schwab Advisor Network® (the “Service”). The Service is designed to help investors find an independent investment advisor. Schwab is a broker-dealer independent of and unaffiliated with CAPTRUST. Schwab does not supervise CAPTRUST and has no responsibility for CAPTRUST’s management of clients’ portfolios or CAPTRUST’s other advice or services. CAPTRUST pays Schwab fees to receive client referrals through the Service. CAPTRUST’s participation in the Service may raise potential conflicts of interest described below. CAPTRUST pays Schwab a participation fee on all referred Client accounts that are maintained in custody at Schwab and a non-Schwab custody fee on all accounts that are maintained at, or transferred to, another custodian. The participation fee paid by CAPTRUST is a percentage of the fees the client owes to CAPTRUST or a percentage of the value of the 20 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  assets in the Client’s account, subject to a minimum Participation Fee. CAPTRUST pays Schwab the participation fee for so long as the referred Client’s account remains in custody at Schwab. The participation fee is billed to CAPTRUST quarterly and may be increased, decreased or waived by Schwab from time to time. The participation fee is paid by CAPTRUST and not by the Client. CAPTRUST has agreed not to charge Clients referred through the Service fees or costs greater than the fees or costs CAPTRUST charges Clients with similar portfolios who were not referred through the Service. CAPTRUST generally pays Schwab a non-Schwab custody fee if custody of a referred Client’s account is not maintained by, or assets in the account are transferred from Schwab. This fee does not apply if the Client was solely responsible for the decision not to maintain custody at Schwab. The non-Schwab custody fee is a one-time payment equal to a percentage of the assets placed with a custodian other than Schwab. The non-Schwab custody fee is higher than the participation fees CAPTRUST generally would pay in a single year. Thus, CAPTRUST will have an incentive to recommend that Client accounts be held in custody at Schwab. The participation and non-Schwab custody fees will be based on assets in accounts of CAPTRUST’s Clients who were referred by Schwab and those referred Clients’ family members living in the same household. Thus, CAPTRUST will have incentives to encourage household members of Clients referred through the Service to maintain custody of their accounts and execute transactions at Schwab and to instruct Schwab to debit CAPTRUST’s fees directly from the accounts. For accounts of CAPTRUST’s Clients maintained in custody at Schwab, Schwab will not charge the Client separately for custody but will receive compensation from CAPTRUST’s Clients in the form of commission or other transaction-related compensation on securities trades executed through Schwab. Schwab also will receive a fee (generally lower than the applicable commission on trades it executes) for clearance and settlement of trades executed through broker-dealers other than Schwab. Schwab’s fees for trades executed at other broker-dealers are in addition to the other broker-dealer’s fees. Thus, CAPTRUST may have an incentive to cause trades to be executed through Schwab rather than another broker- dealer. CAPTRUST nevertheless acknowledges its duty to seek best execution of trades for Client accounts. Trades for Client accounts held in custody at Schwab may be executed through a different broker-dealer than trades for CAPTRUST’s other Clients. Thus, trades for accounts custodied at Schwab may be executed at different times and different prices than trades for other accounts that are executed at other broker-dealers. Fidelity Wealth advisor Solutions® CAPTRUST participates in the Fidelity Wealth Advisor Solutions® Program (the “WAS Program”), through which CAPTRUST receives referrals from Fidelity Personal and Workplace Advisors LLC (FPWA), a registered investment adviser and Fidelity Investments company. CAPTRUST is independent and not affiliated with FPWA or any Fidelity Investments company. FPWA does not supervise or control CAPTRUST and FPWA has no responsibility or oversight for CAPTRUST’s provision of investment management or other advisory services. Under the WAS Program, FPWA acts as a solicitor for CAPTRUST and CAPTRUST pays referral fees to FPWA for each referral received based on CAPTRUST’s assets under management attributable to each Client referred by FPWA or members of each Client’s household. The WAS Program is designed to help investors find an independent investment 21 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  advisor, and any referral from FPWA to CAPTRUST does not constitute a recommendation or endorsement by FPWA of CAPTRUST’s particular investment management services or strategies. More specifically, CAPTRUST pays the following amounts to FPWA for referrals: the sum of (i) an annual percentage of 0.10% of any and all assets in client accounts where such assets are identified as “fixed income” assets by FPWA and (ii) an annual percentage of 0.25% of all other assets held in client accounts. In addition, CAPTRUST has agreed to pay FPWA a minimum annual fee amount in connection with its participation in the WAS Program. These referral fees are paid by CAPTRUST and not the Client. To receive referrals from the WAS Program, CAPTRUST must meet certain minimum participation criteria, but CAPTRUST may have been selected for participation in the WAS Program as a result of its other business relationships with FPWA and its affiliates, including Fidelity Brokerage Services, LLC (“FBS”). As a result of its participation in the WAS Program, CAPTRUST may have a potential conflict of interest with respect to its decision to use certain affiliates of FPWA, including FBS, for execution, custody and clearing for certain client accounts, and CAPTRUST may have a potential incentive to suggest the use of FBS and its affiliates to its advisory Clients, whether or not those Clients were referred to CAPTRUST as part of the WAS Program. Under an agreement with FPWA, CAPTRUST has agreed that Adviser will not charge Clients more than the standard range of advisory fees disclosed in its Brochure to cover solicitation fees paid to FPWA as part of the WAS Program. Pursuant to these arrangements, CAPTRUST has agreed not to solicit Clients to transfer their brokerage accounts from affiliates of FPWA or establish brokerage accounts at other custodians for referred Clients other than when CAPTRUST’s fiduciary duties would so require, and CAPTRUST has agreed to pay FPWA a one-time fee equal to 0.75% of the assets in a client account that is transferred from FPWA’s affiliates to another custodian; therefore, CAPTRUST may have an incentive to suggest that referred clients and their household members maintain custody of their accounts with affiliates of FPWA. However, participation in the WAS Program does not limit CAPTRUST’s duty to select brokers on the basis of best execution. Item 15: Custody Clients should receive statements at least quarterly from the qualified custodian that holds and maintains the Client’s investment assets. CAPTRUST urges Clients to carefully review such statements and compare the official custodial records to any reports provided by CAPTRUST. CAPTRUST reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. CAPTRUST does not act as a qualified custodian for Client assets. CAPTRUST discloses in Item 9 of Form ADV Part 1 that it has custody of Clients’ funds or assets for certain reasons (e.g., where a Wealth Client has granted their CAPTRUST Financial Advisor the ability to access the Client’s assets). CAPTRUST is subject to an annual surprise custody examination by an independent certified public accounting firm. Item 16: Investment Discretion For certain CAPTRUST Clients, Adviser has the authority to determine, without obtaining specific Client consent, both the securities to be bought and sold in their accounts as well as 22 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  the amount of the securities to be bought or sold. However, this discretion must be provided at the beginning of the Adviser/Client relationship and documented in the advisory agreement. There is no particular set limit to this discretion established as part of the agreement or this Brochure. Adviser has the authority to negotiate commission rates charged by the custodians, but does not have any control over the fees charged by the custodians for the services they provide. These fee changes have a direct impact to the Client as they may be charged commissions for transactions. There is no limitation on such discretion, and the Client may pay commissions higher than those obtainable from other broker-dealers for the same products and services. Commissions and/or transaction fees charged Pershing, Fidelity, and Schwab may be higher or lower than obtainable elsewhere. Item 17: Voting Client Securities In general, CAPTRUST Clients delegate the authority to vote their proxies to CAPTRUST in their agreement. It is CAPTRUST’s aim to see that proxies are voted in the best interest of its Clients. As such, CAPTRUST has engaged Institutional Shareholder Services Inc. (“ISS”), to vote proxies on behalf of Clients who delegate proxy voting authority to CAPTRUST. ISS is an independent proxy voting service provider, which performs extensive research, and has designed and maintains a number of proxy voting guidelines. While Clients are always free to vote their own proxies, for those that delegate that responsibility to CAPTRUST, CAPTRUST generally leverages ISS Benchmark Proxy Voting Guidelines (“Guidelines”). The Guidelines are based on widely accepted good governance practices and principles, are designed to be responsive to the wide range of issues that can be raised in proxy situations, and to increase total shareholder value and risk mitigation. Additionally, Clients may revoke their delegation of proxy voting authority at any time, with written notice to CAPTRUST. The Proxy Voting Policy contains additional guidelines and methods by which conflicts of interests are addressed. Such conflict may include situations where CAPTRUST has or is seeking a Client relationship with the issuer of the security that is the subject of the proxy vote. Generally, because the Guidelines pre-establish voting positions, application should adequately address any possible conflicts of interest. SMA Accounts. Where CAPTRUST has recommended an SMA Manager, Clients delegate proxy voting authority to their SMA Manager. The SMA Manager’s proxy voting policies will be detailed in their Form ADV Part 2 brochure. To obtain a copy of CAPTRUST’s Proxy Voting Policy or for a copy of CAPTRUST’s Proxy Voting record, Clients can contact CAPTRUST at the contact details in Item 1. Alternatively, Clients may email IG.Investment.Admin@captrust.com or write to CAPTRUST “Investment Administration” to obtain the information at the address below: CAPTRUST Investment Administration 4208 Six Forks Road, Suite 1700 Raleigh, NC, 27609. 23 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645  Item 18: Financial Information Registered investment advisers are required to provide Clients with certain financial information or disclosures about CAPTRUST’s financial condition. CAPTRUST has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of any bankruptcy proceeding. CAPTRUST’s Privacy Policy and Business Continuity Plan CAPTRUST’s Privacy Policy and Business Continuity Plan can be found on the CAPTRUST internet site by navigating to:  Privacy Policy: https://www.captrust.com/privacy-policy/  Business Continuity Plan: https://www.captrust.com/business-continuity-plan/ 24 CAPTRUST Financial Advisors | 4208 Six Forks Road, Suite 1700 Raleigh, NC 27609 | captrust.com | 919.870.6822 | 800.216.0645