SVB WEALTH LLC

ITEM 1. COVER PAGE SVB WEALTH LLC WRAP FEE PROGRAM BROCHURE PART 2A OF FORM ADV, APPENDIX 1 53 STATE STREET, 28TH FLOOR BOSTON, MA 02109 Phone: 617-912-1900 firstcitizens.com/wealth Date of Brochure: March 29, 2025 the contents of This Form ADV, Part 2, Appendix 1 is the SVB Wealth LLC Wrap Fee Program Brochure (the “Brochure”), the disclosure brochure for wealth clients utilizing SVB Wealth LLC’s wrap fee program services. This Brochure provides information about the qualifications and business practices of SVB Wealth LLC (“SVBW”). If you have this brochure, please contact us at 617-912-1900 or at any questions about compliance.wealth@svb.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Registration with the SEC does not imply a certain level of skill or training. Additional information about SVBW, also is available on the SEC’s website at www.adviserinfo.sec.gov. You can view SVBW’s information on this website by searching for “SVB Wealth LLC.” SVBW’s SEC number is 801-80480 and its CRD number is 172832. SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 1 of 17  ITEM 2 - SUMMARY OF MATERIAL CHANGES This wrap fee program brochure, dated March 30, represents a material update to the wrap fee program brochure filed by SVB Wealth LLC (“SVBW”) on April 5, 2024. The following material changes were made since the most recent filing: SVBW is not enrolling new clients into its Wrap Fee Program. However, current clients in the Wrap Fee Program are permitted to rely on the Program and may add assets to their Program Account(s). SVBW discontinued its participation in soft dollar arrangements. SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 2 of 17  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 ............................................................8 ITEM 6 - PORTFOLIO MANAGER SELECTION AND EVALUATION .........................................................8 ITEM 7 - CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ............................................9 ITEM 8 - CLIENT CONTACT WITH PORTFOLIO MANAGERS ..................................................................9 ITEM 9 - ADDITIONAL INFORMATION ......................................................................................................9 Financial Information ..............................................................................................................................13 SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 3 of 17  ITEM 4 - SERVICES, FEES AND COMPENSATION SVB Wealth LLC (“SVBW” or “we” or “us”), a Massachusetts limited liability company, is an investment adviser registered with the SEC under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Registration as an investment adviser does not imply a certain level of skill or training. SVBW is a wholly owned, non-bank subsidiary of First-Citizens Bank & Trust Company (“FCB”), which in turn, is a wholly owned subsidiary of First Citizens Bancshares, Inc., a publicly traded company (NASDAQ: FCNCA). Previously, SVBW was owned by Silicon Valley Bridge Bank, N.A. (“SVBB”), a full-service Federal Deposit Insurance Corporation (“FDIC”)-operated bridge bank chartered by the Office of the Comptroller of the Currency as a national bank Before SVBB, SVBW was owned by Silicon Valley Bank (“SVB”), which was closed by the California Department of Financial Protection and Innovation. Upon the closure of SVB, the FDIC, as the appointed receiver, transferred substantially all of the assets of SVB to SVBB on March 13, 2023. As part of its advisory services, SVBW sponsors a wrap fee program (the “Wrap Fee Program”). A wrap fee program is a bundle of investment advisory services, which may include portfolio management, brokerage transactions, advisory services, and portfolio administration for which the client pays a wrap fee. Currently, SVBW is not enrolling new clients into its Wrap Fee Program. However, current clients in the Wrap Fee Program are permitted to rely on the Program and may add assets to their Program Account(s). SVBW’s advisory services, including its Wrap Fee Program services, are made available to clients primarily through its investment adviser representatives (“IARs”). Some IARs are also registered representatives of SVBW’s affiliate, First Citizens Investor Services Inc. (“FCIS”), an SEC-registered broker-dealer and a member of the Financial Industry Regulatory Authority (“FINRA”). Information about our IARs is in the Brochure Supplement, which is a separate document provided along with this Brochure. SVBW sponsors its Wrap Fee Program in partnership with an unaffiliated third-party, Betterment LLC (“Betterment”), an SEC-registered investment adviser. The Wrap Fee Program is offered to clients through an online platform (“Betterment Platform”) managed by Betterment. In providing this program, we consider potential conflicts of interest associated with client participation in the Wrap Fee Program and the broad financial needs of our clients. We offer and tailor investment solutions for our clients taking into consideration a client’s investment objectives, income, net worth, current financial information, investing time horizon, financial and/or retirement goals and risk tolerance (“Client Information”). The Wrap Fee Program relies on certain Client Information and uses Betterment’s proprietary asset allocation techniques to provide discretionary, goal-based management of the client’s personal investment portfolio, together with ancillary custody and brokerage services, for an all-inclusive wrap fee. SVBW recommends that certain eligible clients implement their investment portfolios through the Wrap Fee Program. SVBW shall not exercise any direct, day-to-day discretionary trading authority over the client’s account at Betterment but will maintain discretionary authority over the client’s investment advisory relationship with our firm and have the authority to engage Betterment for the management of the client’s account(s). We want the client to make an informed investment decision regarding the client’s use of the Wrap Fee Program. This Brochure provides important information and disclosure regarding the program, including information regarding material arrangements and potential conflicts of interest that we think the client will find informative. Each client should carefully and independently review all of the features and risks of the Wrap Fee Program, along with all of the disclosures contained in this Brochure and on the Betterment Platform, before opening an account and beginning to invest through the Wrap Fee Program, to ensure that the Wrap Fee Program is a suitable and appropriate solution for the client’s current investment needs. The Wrap Fee Program In the Wrap Fee Program, Betterment, as the sub-advisor/portfolio manager, uses strategic asset allocation SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 4 of 17  principles to invest client assets in various liquid asset classes using certain preferred ETFs as the investment assets, and other liquid cash and cash-like accounts as secondary investment assets. MTG LLC, doing business as Betterment Securities (“Betterment Securities”), is Betterment’s affiliated broker-dealer and acts as broker-dealer and custodian for client accounts in connection with the Wrap Fee Program. Betterment and Betterment Securities provide a suite of services in connection with the Wrap Fee Program, including sub- advisory, custody, and brokerage services, together with access to the Betterment Platform. Through the Betterment Platform, clients will establish, access, and manage their accounts. In addition, Betterment offers clients additional services like checking accounts and high-yield cash accounts. SVBW’s IAR will, among other things, assist the client in determining if the Wrap Fee Program is suitable and appropriate for the client’s initial and ongoing investment needs, and, if warranted and considered to be in a client’s best interest, select another sub-adviser to provide similar, automated investment advisory services to the client. The clients will provide certain of their Client Information to Betterment, which Betterment will use to generate an investment policy statement (“IPS”). Betterment’s algorithm will then recommend and build a diversified portfolio of investment products based on this information for each of client’s financial goals and account types. In general, Betterment’s asset allocations consist of varying proportions of fixed income and equity asset classes selected by Betterment. Betterment, then, manages clients’ investment portfolios on a discretionary basis, including by automatically adjusting and rebalancing investment products back to targets based on certain “drift” parameters (although clients can generally request rebalancing only in response to cash flows), while providing clients with ongoing portfolio reporting. The Wrap Fee Program also offers clients tax loss harvesting and automated asset allocation services and the option to donate appreciated securities holdings to certain qualified charities. The value provided by these optional services will vary depending on each client’s personal circumstances. Through the Betterment Platform, clients can adjust the IPS and aggregate outside financial account assets to provide further input to Betterment’s discretionary management. The Betterment Platform provides self-help tools to help clients understand their risks, access to information related to transactions and the visibility to review account performance. Clients can impose certain permitted and reasonable restrictions on Betterment’s ongoing management of Client’s assets. The Wrap Fee Program provides opportunities for clients to review their accounts including access to a periodic review conducted by the IAR assigned to their accounts, during which clients can alter their reasonable restrictions and update certain client information. At all times, clients have sole authority to liquidate and withdraw securities and cash from accounts, subject to the usual and customary settlement procedures, and except as otherwise be required for payment of fees and expenses (as described below). Clients can also, at any time, transfer additional eligible assets into accounts. SVBW initiates the closure of client accounts under a variety of circumstances described in our advisory contract. If we do so, Betterment, in its discretion, offer clients the ability to continue investing through Betterment’s direct-to-client offering under a new advisory contract. SVBW can selectively terminate investment advisory agreements with respect to client accounts and not others. As a condition of opening an account and beginning to invest through the Wrap Fee Program, clients are generally required to enter into an investment advisory agreement with SVBW, a sub-advisory agreement with Betterment and a brokerage and custody agreement with Betterment Securities. A client can stop investing through the Wrap Fee Program at any time with notice to SVBW and Betterment. The clients’ agreements with Betterment, along with Betterment’s disclosure brochure, provide specific information on how clients can terminate their advisory relationship with Betterment, along with other terms and conditions of the engagement. Following closure of a client’s account and/or termination of a client’s advisory contract with SVBW, a client will be solely responsible for monitoring all of the securities in an account and neither SVBW nor Betterment will have any continuing obligation to act or offer advice with regard to those assets. Clients should contact Betterment directly for questions regarding their sub-advisory agreement with Betterment or Betterment’s client disclosure documents. SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 5 of 17  Delegation of Authority In this Wrap Fee Program, clients grant Betterment full discretion to manage their accounts without clients’ prior notice or consent. This discretionary authority is granted to Betterment pursuant to the sub-advisory agreement with Betterment, which each client must execute as a condition of opening an account and beginning to invest through the Wrap Fee Program. Under that agreement, Betterment is solely responsible for placing all orders for purchases, sales, and redemptions in connection with investment of the assets in a clients’ accounts. This discretionary authority includes, among other things, the authority to select and change the composition of the investment products and invest and rebalance clients’ accounts consistent with their target asset allocation under the IPS, to liquidate sufficient assets to pay Wrap Fees (as defined below) or any costs or expenses of the Wrap Fee Program, and to carry out the actions necessary to fulfilling Betterment’s fiduciary responsibilities under the Wrap Fee Program, in each case, without clients’ prior notice or consent. Separately, pursuant to the SVBW investment advisory agreement, clients grant SVBW, among other things, discretionary authority as client’s primary investment advisor and relationship contact for the Wrap Fee Program, to add and terminate the sub- advisory relationship with Betterment and to reallocate clients’ assets to another custodian and/or platform provider. While SVBW will in that capacity be available to answer ongoing questions regarding the Wrap Fee Program or clients’ accounts, neither SVBW nor its IARs exercise discretionary investment management authority over the assets held in client accounts under the Wrap Fee Program. Fiduciary Relationship; Impact on Other Client Agreements Investment advisory services such as the Wrap Fee Program create a fiduciary relationship with clients under applicable law. This means that we must act in our clients’ best interest, and carefully manage any perceived or actual conflict of interest that arise in relation to our advisory services. Please note that although we act as the client’s fiduciary investment adviser in providing the Wrap Fee Program to the client, this does not change any other relationship the client has with SVBW. Fees And Expenses The Wrap Fee Program charges clients an all-inclusive wrap fee (the “Wrap Fee”) equal to 0.40% of the value of the assets in a client’s account calculated on an annualized basis. Of the 0.40%, 0.25% of the Wrap Fee is received by Betterment and 0.15% is received by SVBW. Betterment shall calculate and automatically debit Wrap Fees from client accounts. SVBW does not charge its portion of the Wrap Fee directly to clients. The Wrap Fee is assessed quarterly on the last business day of the quarter using the average portfolio value of all assets of a client’s account (including cash) as of the close of each calendar day. Wrap Fee payments will also be due immediately upon account termination and prior to a withdrawal that is equal to or greater than 98% of an account’s market value at that time less the amount of accrued but unpaid Wrap Fees due. Other than as described above, Wrap Fees are not charged on the basis of a share of capital gains upon or capital appreciation of a client’s account or any portion of a client’s assets. However, in certain circumstances, the Wrap Fee Program can charge a client for special requests or other irregular services. Betterment and/or Betterment Securities will value account assets for Wrap Fee calculation purposes in accordance with its normal practices and procedures and will deduct the resulting Wrap Fees from client accounts when they become due and payable. The obligation to pay Wrap Fees limit clients’ ability to sell or otherwise liquidate securities in or to withdraw cash or securities from client accounts. It is each client’s responsibility to verify the accuracy of Wrap Fee calculations. There can be other negotiated fees for the provision of certain additional services provided by Betterment in connection with the Wrap Fee Program and the Betterment Platform. Any such fees will be paid directly by SVBW to Betterment, and clients will not separately be charged for any such fees, although the SVBW portion of the Wrap Fee can reflect some or all of the fees paid to Betterment. In determining the amount, if any, of incentive compensation for our IARs, we consider referrals to the Wrap Fee Program and the amount of Wrap Fee Program assets under management, attributed, in each case, to SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 6 of 17  an individual employee. This creates an incentive for our IARs that clients open an account and invest through the Wrap Fee Program. (See “Client Referrals and Other Compensation” under Item 9 (Additional Information) below.) We do not share in any Wrap Fees earned by Betterment or receive any additional compensation from Betterment or Betterment Securities in connection with the Wrap Fee Program. However, we and our affiliates have other business relationships with Betterment or its affiliates that result in the receipt of other forms of revenue. (See “Other Financial Industry Affiliations” under Item 9 (Additional Information) below.) The Wrap Fee represents payment for the following advisory, custodial, brokerage, technology, and associated services that SVBW and its service providers provide to you as part of the Wrap Fee Program: identification of clients for whom the Wrap Fee Program is suitable and appropriate; • • services provided by Betterment, including generation of client’s IPS, discretionary account management and maintenance of the Betterment Platform; financial account aggregation services provided by a third-party vendor; trading, execution and reconciliation services; recordkeeping and performance reporting; tax reporting; and • • market statistics, financial and other performance data; • custody and clearing charges; • • custodial statements with account activity; • account billing administration; • • periodic review of client accounts and assistance provided by SVBW IAR; • • other Betterment Platform technology. We have decided to offer the Wrap Fee Program on a “wrap” fee basis because we believe it best allows us to achieve our mission of simplifying the client’s automated investing for the client’s financial goals. For example, the Wrap Fee provides the client with the flexibility to contribute or withdraw money or assets to or from the client’s account and to make changes to the client’s IPS without incurring any additional fees. Fees and expenses can have a profound impact on an investment portfolio. Clients should consider whether the Wrap Fees are worth the services provided. The Wrap Fee can be more or less than the cost of the services included in the Wrap Fee Program if they were provided separately or from another source. The Wrap Fee is in addition to, and not in place of, any compensation that we receive from any other existing services that we provide to the client outside of the Wrap Fee Program. The client may be able to obtain automated, algorithmic investment management services that rely on an IPS similar to that used by the Wrap Fee Program for a lower fee than the Wrap Fee. While custodial fees are generally included in the Wrap Fee, fees for special requests or other irregular services, are charged separately and in addition to the Wrap Fee. All Wrap Fees paid by clients are separate and distinct from the fees and expenses charged by ETFs and mutual funds. The Wrap Fee creates an incentive for Betterment to design the asset allocation algorithms used by the Wrap Fee Program in such a way as to limit trading in Wrap Fee Program accounts because the execution costs of each trade will reduce the potential profit from the Wrap Fee. Matters Related to Custody SVBW does not have possession, or actual or constructive custody of any client assets invested through the Wrap Fee Program. Client assets are held by Betterment Securities, a qualified custodian, under the brokerage and custody agreement entered by clients directly. However, client assets for individual retirement accounts (“IRAs”) are held by Millennium Trust Company, LLC (“Millennium Trust”), a self-directed IRA custodian, pursuant to a separate custodial agreement. In either case, assets are held in clients’ names by the custodian. If clients do not wish to place assets with Betterment Securities or Millenium Trust, then clients cannot invest through the Wrap Fee Program. SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 7 of 17  Since SVBW has the ability to direct Betterment Securities to debit Wrap Fees directly from client accounts pursuant to clients’ investment advisory agreements, SVBW can be deemed by the SEC as having technical custody solely with respect to the fees we receive as revenue. However, it is Betterment Securities, not SVBW, which acts as custodian of client accounts and, in that capacity, has sole responsibility with respect to the collection of income, physical acquisition and safekeeping of the assets, investments, funds and other property held in those accounts. At least quarterly, clients will receive account statements directly from Betterment Securities. It is important for clients to carefully review their statements and to compare them to performance reports received from Betterment in order to verify their accuracy. Clients should contact SVBW directly if they believe that there is an error in any statement. ITEM 5 - ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Requirements The Wrap Fee Program was offered to new clients, typically to individuals, and certain entities with whom SVBW or its affiliates have a preexisting business relationship. However, the Wrap Program is no longer being offered. ITEM 6 - PORTFOLIO MANAGER SELECTION AND EVALUATION SVBW has advisory discretion to select the Wrap Fee Program’s sub-adviser, custodian, and other service providers, and providing assistance to clients. SVBW has selected Betterment as the Wrap Fee Program’s sole and exclusive sub-adviser. Betterment generates a client’s IPS based on certain Client Information, and provides discretionary, ongoing management of client accounts based on the resulting asset allocation and investment recommendations, subject to our oversight. Betterment also provides the Betterment Platform through which Wrap Fee Program accounts are opened and the Wrap Fee Program is provided. We believe that Betterment has the requisite expertise and capabilities to serve in these various capacities. Betterment has been in business since 2010. It employs strategic asset allocation principles to invest client assets on behalf of its direct advisory clients and third-party financial institutions (such as SVBW) with whom it has entered into agreements to offer advisory, brokerage, custodial, consulting and/or technology services. Those institutions provide input or exercise control over Betterment’s management of client accounts. However, in the case of the Wrap Fee Program, neither SVBW nor its supervised persons will act as third- party manager or otherwise exercise discretionary authority over client accounts. The performance of Wrap Fee Program accounts would differ, potentially materially, if we were to manage or exercise control over them. The client can obtain digital, goal-based investment advisory services from Betterment that are in many respects similar to the Wrap Fee Program, but in certain other respects are different. While both the Wrap Fee Program and Betterment’s direct-to-client services will rely on the same strategic asset allocation principles and utilize Betterment Securities as broker-dealer and custodian, the fees and expenses clients will pay, along with other terms and conditions applicable to accounts, can in fact differ substantially between those services. As a result, the returns of those direct-to-client services can differ, potentially significantly, from the Wrap Fee Program. information about Betterment’s advisory services is available on its website, Additional https://www.betterment.com, and on the SEC’s website, www.adviserinfo.sec.gov. SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 8 of 17  ITEM 7 - CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS When the client first opens a Wrap Fee Program account, the client will provide certain Client Information through the Betterment Platform. Some of this information will be elicited through a series of questions. Based on this information, the Betterment Platform will generate an IPS, which will be used to make ongoing investment decisions for the client’s account. The client can review and update information anytime through the Betterment Platform if it changes, and the Wrap Fee Program will provide the client with a formal opportunity to do so through our designated IARs. Betterment provides certain Client Information to SVBW that clients authorize via their sub-advisory agreement with Betterment. However, SVBW does not provide any Client Information to Betterment regarding clients even if that information is in its possession or the possession of its affiliates; clients must directly provide Betterment with all information to be used by the Wrap Fee Program through the Betterment Platform. ITEM 8 - CLIENT CONTACT WITH PORTFOLIO MANAGERS Although the algorithms that manage client accounts are overseen, monitored and updated by Betterment’s investment advisory personnel, clients participating in the Wrap Fee Program will generally not interact directly with such investment advisory personnel, except as otherwise noted in this Brochure. The client assistance provided for the Wrap Fee Program is educational and information in nature only. However, the client can contact a SVBW IAR for assistance related to the client’s account using the contact information provided on the Betterment Platform. In addition, through the Wrap Fee Program’s periodic review process, the client can indicate to a SVBW IAR on the client’s account if, as a result of changes to the client’s financial situation, investment objectives or otherwise, the Wrap Fee Program should make changes to the client’s IPS. The client can also update the client’s information through the Betterment Platform anytime the client wish, including following the client’s review of one of the Wrap Fee Program’s periodic performance reports. While a SVBW IAR is able to provide some assistance, the client should note that all support for the Wrap Fee Program will generally be provided electronically through the Betterment Platform. The client also should be aware that the Betterment Platform may not be available during market events, such as periods of significant volatility or downturns. At all times, the client is responsible for taking action if the client wants to initiate changes to the client’s account, including initiating its closure should the client determine that the Wrap Fee Program no longer suits the client’s current investment needs. ITEM 9 - ADDITIONAL INFORMATION Disciplinary Information Registered investment advisers are required to disclose all legal or disciplinary events that are material to a client’s or prospective client’s evaluation of its advisory business or the integrity of its management. As of the date of this Brochure, neither SVBW nor its management personnel have been subject to, or involved in, any legal or disciplinary events required to be disclosed in this Brochure. Other Financial Industry Affiliations SVBW is owned by First Citizens BancShares, Inc. and is affiliated with First Citizens branded entities, including FCB, First Citizens Asset Management, Inc., FCIS, First Citizens Capital Securities, LLC, First Citizens Institutional Asset Management, LLC, and SVB Asset Management, a registered investment adviser. Some of SVBW’s affiliates are registered investment advisers, registered broker-dealers, and/or licensed SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 9 of 17  insurance agencies. Some, but not all, investment adviser representatives of SVBW are also broker-dealer registered representatives of FCIS and/or insurance agents. The IAR providing advice may implement recommendations as a registered investment adviser, registered representative, or insurance agent when appropriately registered or licensed to do so. When the IAR implements the recommendations, SVBW and the IAR receive compensation for advice implemented as a registered investment adviser, registered representative, or insurance agent. Each role has a different duty to the client, for example, individuals acting as registered investment advisers have a fiduciary duty to their clients, while registered representatives and insurance agents must comply with the suitability requirements and regulation Best Interest. An inherent conflict of interest exists for IARs who are dually registered and insurance licensed. When an IAR is dually registered he/she can sell securities on a commission basis. An IAR may suggest that a client implement investment advice by purchasing products through a commission-based brokerage account in addition to or in lieu of a fee-based advisory account. This receipt of commissions creates an incentive to recommend those products for which an IAR will receive a commission in his or her separate capacity as a registered representative of a securities broker-dealer. Consequently, the objectivity of the advice rendered could be biased. Clients are under no obligation to use the services of the IAR in this separate capacity. When an IAR is licensed as an insurance agent, the IAR may sell, general disability insurance, life insurance, annuities, and other insurance products. Neither SVBW nor its IARs will receive any commissions or additional income related to the sale of any such products. Upon specific client request, IARs may introduce clients to personnel of First Citizens to discuss bank products and other services. Such introductions are not part of the investment advisory services SVBW provides to its clients. SVBW IARs and their management personnel receive a subjective annual bonus at the discretion of their supervisors but not directly related to the sales of specific products/services. First Citizens may also invest in or otherwise have an ownership interest in certain SVBW clients. Due to SVBW’s relationship with First Citizens, SVBW has an indirect financial interest in making such introductions and fostering relationships between First Citizens and its clients.1 In appropriate circumstances, SVBW will recommend that a client roll over an account held in a former employer’s retirement plan or an outside IRA to an IRA managed by SVBW. If the client elects an IRA rollover or transfer subject to SVBW’s management, the account will be subject to SVBW’s Fee per the Client Agreement. IAR’s recommendation to roll over retirement plan or IRA assets into an IRA managed by SVBW presents a conflict of interest because such a recommendation creates an incentive to recommend the rollover for the purpose of generating additional compensation rather than solely based on the client’s needs. When SVBW provides investment advice or recommendations to a client regarding their retirement plan assets, IRA account or rollover IRA, SVBW is acting as an investment advice fiduciary within the meaning of Title I of ERISA. Further, when SVBW recommends a rollover or transfer to an IRA, the client is never under any obligation to complete a rollover or transfer or to have the rollover IRA assets managed by SVBW. Betterment is a wholly owned subsidiary of Betterment Holdings, Inc., which is also the parent company of Betterment Securities. Neither Betterment nor Betterment Securities are affiliates of SVBW. However, Betterment and/or one or more of its affiliates is currently an FCB client, and from time to time have other financial relationships with FCB or its affiliates. Because of its ownership by FCB, these relationships present a conflict of interest by creating an incentive for SVBW to recommend that clients invest through the Wrap Fee Program, so as to induce Betterment to maintain (or expand) its relationship with FCB or its affiliates. This conflict is mitigated by the fact that SVBW personnel are not compensated based on the amount of banking or related business generated by Betterment and the use of objective eligibility criteria to determine if and when a client can be referred by SVBW to the Wrap Fee Program. Even so, prospective clients should be aware of 1 First Citizens also provides a variety of support services to SVBW, including human resources, information technology, facilities, finance, legal, and administrative support. SVBW does not believe such support services create a material conflict of interest with clients. SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 10 of 17  the relationship between Betterment and FCB and the conflicts this presents and should take this into consideration in making an independent determination of whether the Wrap Fee Program is a suitable and appropriate solution for their investment needs. Betterment Securities, a registered broker-dealer, member of the Securities Investor Protection Corporation and affiliate of Betterment Securities serves as broker-dealer to the Wrap Fee Program, causing the execution of securities transactions upon instruction by Betterment through Apex Clearing Corporation (“Apex”), which Betterment Securities has entered into clearing and settlement agreements. As a result, the Wrap Fee Program is subject to the trading policies and procedures established by Betterment Securities and Apex. These trading policies are described in detail in the Betterment Wrap Fee Brochure, in particular, the client should understand and consider that the appointment of Betterment Securities by Betterment as the sole broker for the client’s account under the Wrap Fee Program can result in disadvantages to the client as a possible result of less favorable trade executions than can be available through the use of a different broker-dealer. In addition, the client should be aware that the Wrap Fee Program can use margin borrowing on an interim basis, as provided in the Betterment Securities’ brokerage and custody agreement. Betterment makes available to SVBW various support services that may not be available to Betterment’s direct- to- client (i.e., retail) customers. Some of those services help us manage or administer our Wrap Fee Program clients’ accounts, while others help us manage and grow our business. Betterment’s support services are generally available on an unsolicited basis, meaning we do not have to request them, and at no charge to us. The following is a more detailed description of Betterment’s support services. SVBW does not receive any compensation for the recommendation of other investment advisers to its clients. Neither SVBW nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Code of Ethics SVBW has adopted an Investment Adviser Code of Ethics (the “Code of Ethics”) in accordance with Rule 204A-1 of the Advisers Act. The Code of Ethics applies to those SVBW personnel engaged in offering and/or providing investment advisory services to clients (also known as supervised persons). Among other things, the Code of Ethics requires supervised persons to comply with applicable securities laws, exhibit high ethical standards and place clients’ interests first in accordance with SVBW’s fiduciary duty to its clients. Supervised persons who fail to observe the Code of Ethics and related policies and procedures risk serious sanctions, including dismissal. The Code of Ethics also sets forth SVBW’s policies and procedures regarding personal securities transactions. These policies and procedures are designed to identify and prevent or mitigate actual conflicts of interest and to address such conflicts appropriately if they do occur. Supervised persons are required to submit periodic reports regarding personal securities transactions, holdings, and accounts. Supervised persons are required to report all securities transactions and holdings except for: U.S. government obligations; money market funds; bankers acceptances; bank CDs; 529 plans, commercial paper; high quality short-term debt instruments; shares issued by money market funds; open end mutual funds registered in the U.S. and shares issued by unit investment trusts that are exclusively invested in open-end mutual funds registered in the U.S. SVBW compliance is responsible for reviewing such employee reports. In certain instances, SVBW employees may invest in the same securities that SVBW recommends to its clients. Such transactions are reviewed on a post-trade basis and if such transactions are permitted, it is because SVBW believes that such transactions do not present a conflict of interest considering the markets and liquidity for the securities traded. The Code of Ethics also provides that supervised persons may not serve on the board of directors of any public company, including mutual fund boards of trustees, without prior approval. Employees must obtain prior written permission to serve as a trustee on a client account other than the account of a family member or to serve as SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 11 of 17  a trustee or a board member for any charity or not-for-profit entity. Our employees do, in fact, serve in these capacities on various charitable, civic and community boards. If such service is approved, it is because we have determined it does not create any conflict of interest. SVBW does not buy securities from, or sell securities to, its clients (i.e., SVBW does not engage in “principal transactions” with its clients). SVBW is not a registered broker-dealer and does not engage in “agency cross” trades between clients. SVBW will provide a copy of the Code of Ethics free of charge to any client or prospective client upon request. Review of Accounts As noted above, Betterment requests that clients review their accounts at least quarterly, while on a periodic basis, clients are invited to have their account and the associated performance reports reviewed by a SVBW IAR. Those reviews will evaluate the portfolio for consistency with the prevailing investment objectives and restrictions, and with the account’s IPS. Outside of these reviews, clients can review and update Client Information through the Betterment Platform, including any reasonable and permitted restrictions placed on client accounts, at any time clients consider appropriate, and can contact a SVBW IAR with any such review or update. Clients are encouraged to review their accounts if there are changes in their financial situation, large withdrawals or significant deposits or changes in the IPS. The Betterment Platform includes investment tools that are designed to help clients to better understand their holdings and performance information. Pursuant to the terms of clients’ sub-advisory agreement with Betterment, the Wrap Fee Program will also make available to clients periodic reports that detail account holdings, transactions and performance, market commentary and tax reporting information. As a condition of participating in the Wrap Fee Program, clients must consent to receive all such reports, account statements and other communications electronically, either through the Betterment website or by e-mail. SVBW will generally not provide reports to clients in connection with the Wrap Fee Program. Betterment continuously reviews clients’ accounts to ensure they conform to clients’ IPS; however, individual accounts are generally not actively monitored directly by investment advisory personnel. For more information about Betterment’s review process and the impact on account adjustment and rebalancing, please refer to the Betterment Wrap Fee Brochure. Client Referrals and Other Compensation FCB refers clients to SVBW and vice-versa. SVBW ensures that its services are suitable for clients referred to it by FCB. Although SVBW believes that clients value the opportunity to have access to FCB’s products and services, such referrals nevertheless present a conflict of interest because SVBW IARs have a direct financial incentive to refer clients to FCB for such banking products and services. That is, IARs receive direct payment for referring clients to FCB for banking, lending, and deposit products which is calculated and paid strictly from internal sources. In no circumstance does a client pay additional fees or expenses beyond the customary charges for the services chosen. When warranted by the totality of the client relationship, a client sometimes receives more favorable rates for the banking products/services purchased. In addition to making referrals to FCB, IARs are eligible for additional compensation based on other factors as well, including, but not limited to, achieving certain levels of production, sourcing new FCB relationships, and training new advisors. SVBW mitigates the conflicts of interest that may arise from intra-company referrals with transparency, client consent, applying the Best Interest standard, providing alternative options and robust compliance and monitoring framework. Separately, as noted in the section entitled “Fees and Compensation” within Item 4 (Services, Fees and Compensation) above, we offer more favorable Wrap Fee arrangements, including reduced or waived fees for certain clients. These arrangements create a conflict of interest for a client to maintain a certain advisory account balance or continue to invest through the Wrap Fee Program altogether, if doing so would maintain SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 12 of 17  eligibility to qualify for a preferential fee arrangement. Please refer to the section entitled “Betterment and Betterment Securities” above for disclosures on research and other benefits we can receive as a result of our relationship with Betterment in connection with the Wrap Fee Program. Financial Information SVBW is not required to include a balance sheet in this Brochure because SVBW does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. discretionary Account(s). SVBW is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to its clients. SVBW has not been the subject of a bankruptcy petition at any time during the past ten years. Wrap Fee Program Risk Factors and Related Considerations While the Wrap Fee Program attempts to optimize investment returns for clients’ risk tolerance, SVBW makes no representation or warranty that the Wrap Fee Program’s investment decisions will be successful and result in profitable investing. Investing in securities involves risk of loss that the client should understand and be prepared to bear. Further, the automated and algorithmic nature of the Wrap Fee Program and reliance on the Betterment Platform present certain additional risks. Investment performance can never be predicted or guaranteed, and the value of client accounts can fluctuate, potentially significantly, due to market conditions and other factors. Past performance is no guarantee of future results, and any historical returns, expected returns or probability projections provided by the Wrap Fee Program do not reflect the actual future performance of client accounts. When evaluating investment risk, financial loss can be viewed differently by each client and can depend on many different risk items, each of which can affect the probability of adverse consequences and the magnitude of any potential losses. The following risks are not all-inclusive, but the client should carefully consider them before opening a Wrap Fee Program account and beginning to invest. They should be considered as possibilities, with additional regard to their actual probability of occurring and the effect on the client if there is in fact an occurrence. Moreover, to the extent the Wrap Fee Program changes over time, the client can be subject to additional and different risk factors than those specified here. Inherent Limitations of Wrap Fee Program. While the Wrap Fee Program has been designed to be broadly applicable to many clients, it cannot be appropriate for all clients The Wrap Fee Program does not provide exposure to alternative asset classes, nor does it pursue esoteric investment strategies using derivatives and other financial instruments. Also, because the Wrap Fee Program is an online advisory service, it is not appropriate if clients have limited or no access to technology. Not Necessarily a Complete Investment Program. The Wrap Fee Program does not provide comprehensive financial planning or tax advice. There can be additional relevant information or other financial circumstances that the Wrap Fee Program does not consider (e.g., a client’s debt load or other financial obligations) that could inform its advice if it were provided, even if that information is otherwise available to SVBW. Use of Algorithms. The Wrap Fee Program’s IPS and ongoing investment decisions are generated entirely by proprietary algorithms developed, overseen, and monitored by Betterment’s investment advisory personnel. Algorithms are automated systems and will only be customized by Betterment within their limitations. In particular, algorithms rely on assumptions, including economic and transaction cost assumptions, that are incorrect, that do not apply to clients’ specific financial situation or that do not change even as market expectations shift, causing the resulting investment decisions to be flawed. Algorithms consider limited investment options, to the exclusion of other investment types, including entire asset classes, and generally pursue investment strategies that significantly emphasize passive investment products that are intended to mirror the performance of the broader markets. SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 13 of 17  Accurate Performance of Algorithms. The Wrap Fee Program is highly reliant on the accurate operation of Betterment’s algorithms and their underlying technology. A malfunction or failure in either can cause clients to experience investment losses, some or all of which can be significant. Additionally, the algorithms employ a number of quantitative models that involve assumptions based upon a limited number of variables that are extracted from complex financial markets or instruments that they are intended to replicate. Any one or all of these assumptions, whether supported by past experience, can prove over time to be incorrect, which can result in significant losses to clients. Modification of Wrap Fee Program and/or Betterment Platform. Betterment enhances or otherwise modifies the algorithms or other elements of the Wrap Fee Program and/or the Betterment Platform at any time. These changes, at times, have a material impact on the algorithms and/or the analysis and advice provided through the Wrap Fee Program. While these changes are intended to improve or enhance the performance, reliability or usefulness of one or more of the Wrap Fee Program or the Betterment Platform, there can be no guarantee that such changes will result in the desired improvement or enhancement. In some cases, these enhancements or modifications cause unforeseen consequences with the provision of the Wrap Fee Program that can be detrimental to clients. Use of the Wrap Fee Program and the Betterment Platform is subject to such risks. Reliance on Data. The Wrap Fee Program is highly reliant on data from third-party and other external sources. Betterment exercises discretion in determining what data to gather to implement the Wrap Fee Program’s investment strategies. Due to the automated nature of such data gathering and the fact that much of this data comes from third-party sources, not all desired and/or relevant data will be available to, or processed by, the Wrap Fee Program at all times. There is no guarantee that any specific data or type of data will be utilized by the Wrap Fee Program, nor is there any guarantee that the data actually utilized by the Wrap Fee Program will be the most accurate data available or free of errors or contamination. Tax Risks. Certain investments or investment strategies that the Wrap Fee Program deploys can result in negative tax consequences, can involve tax treatment that is not clear or be subject to recharacterization by the Internal Revenue Service (the “IRS”). The Wrap Fee Program does not provide tax advice, and all clients are advised to consult with their tax, accounting and legal advisors in this regard. In particular, tax loss harvesting. and automated asset allocation services implemented by the Wrap Fee Program should not be interpreted as tax advice, and no representation is made that the related discretionary investment decisions of the Wrap Fee Program will result in any particular tax consequences for clients. The tax consequences of tax loss harvesting, and related strategies are complex and can be challenged by the IRS, and investment decisions associated with those strategies do not perform as expected. The Wrap Fee Program was not developed to be used by, and it cannot be used by, clients to avoid tax penalties or interest. Periodic Review; Negative Consent. The Wrap Fee Program relies on a periodic review conducted by SVBW IARs to confirm that a client’s IPS or other information has not materially changed and that clients do not wish to add or alter permitted restrictions on their accounts. If clients do not respond to IARs within the specified period and/or supply updated information, the IARs will assume, under the principle of negative consent, that there are no changes to the IPS and/or other Client Information and that, as a result, no changes to the management of clients’ accounts should be made by the Wrap Fee Program. Account Withdrawals. Client withdrawals from accounts can cause the Wrap Fee Program to execute trades at then- prevailing market prices or prevent the Wrap Fee Program from executing other trades intended to rebalance clients’ investment portfolios. This can cause clients’ current asset allocation to deviate from the Wrap Fee Program’s target asset allocation, result in taxable gains or losses and undermine clients’ progress towards their goals. Account Rebalancing. When clients deposit to or withdraw money from their accounts, they are requesting that the Wrap Fee Program execute securities transactions within their account, in an amount that corresponds to the target asset allocation prescribed by their IPS. Similarly, when clients make changes to their IPS, the Wrap Fee Program will buy and sell securities to reach the desired target asset allocation. These transactions result SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 14 of 17  in tax consequences for clients. In addition, dividend and other income generated by securities held in clients’ accounts will automatically be used by the Wrap Fee Program to rebalance the account and will not necessarily be reinvested in those same securities. 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, global, political, economic, and social conditions may trigger market events. Either the stock market as a whole or the value of an individual company, could decrease in the value, resulting in a decrease in value of the investments, also referred to as systematic risk. Liquidity and Valuation Risk. High volatility and/or the lack of deep and active liquid markets for a security can prevent the Wrap Fee Program from placing trades for clients at all, or at advantageous times or prices. Some securities (including ETFs, as described below) that hold, or trade derivatives and other financial instruments can be adversely affected by liquidity issues as they manage their portfolios. While the Wrap Fee Program values the securities held in clients’ accounts based on reasonably available exchange-traded data, it can from time to time receive or rely on inaccurate or erroneous data, which can adversely affect security valuations, transaction sizes for purchases or sales and/or the resulting Wrap Fees paid by Client. Clients may not be able to sell securities in a timely manner or at a desired price, or because of a lack of demand or a lack of market. ETF and Mutual Fund Risk. The Wrap Fee Program’s investments will predominantly include ETFs but can also include mutual fund shares or other index- and non-index-related securities. These investment products are subject to the risk that they cannot effectively achieve the performance of the index, industry or other market they are intended to track, if they do intend to achieve such tracking. Securities Investment Risks. All securities and other account investments carry some level of risk, including the risk that clients can lose their entire investment. Prices of securities can be volatile and a variety of risks, including market, currency, economic, political, technological, regulatory, social and business risks, can adversely affect the value of and return on any account investments. Company and Industry Risk. When purchasing stock positions, there is always a certain level of company or industry-specific risk that is inherent in each investment and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. Fixed Income Risk. Generally, the value of fixed income securities will change inversely with changes in interest rates. As interest rates rise, the market value of such securities tends to decrease. Conversely, as interest rates fall, the market value of such securities tends to increase. This risk will typically be greater for securities based on longer-term interest rates than for securities based on shorter-term interest rates. Fixed income securities can experience a decline in income when interest rates decrease. During periods of falling interest rates, an issuer can repay principal prior to the security’s maturity (i.e., prepayment), causing the vehicle to have to reinvest in securities with a lower yield, resulting in a decline in the vehicle’s income. Additionally, fixed income securities are subject to liquidity risk, whereby a security is difficult to purchase or sell or becomes difficult to sell after being purchased. This risk has been especially pronounced in recent times due to disruptions in the global debt markets and is elevated for high-yield fixed income securities (sometimes called “junk” bonds). Non-U.S. Securities. International investments involve special risks not typically associated with trading in investments relating to markets and/or issuers solely in the U.S. Depending on the particular countries and investments involved and on the nature of the particular transactions executed outside of the U.S., these special risks include: changes in exchange rates and exchange control regulations; downgrades in sovereign credit ratings; devaluations or non- convertibility of non-U.S. currencies; failures or disruptions in central banks, banking systems, markets or financial exchanges; changes in monetary policies, interest rates or interest rate policies; political, social and economic instability; adverse diplomatic developments; investment and SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 15 of 17  repatriation restrictions; the nationalization and/or expropriation of assets; government intervention in the private sector; default by public and private issuers on their financial obligations (and limited recourse in connection with such defaults); the imposition of non-U.S. taxes; discrimination against foreign investors; less liquid markets; less information; higher transaction costs; less information regarding legal and regulatory risks; less uniform accounting and auditing standards; greater price volatility; less reliable clearance and settlement procedures; and/or less government supervision of exchanges, brokers, market intermediaries, issuers and other markets and market participants, than is generally the case in the U.S. Commodities. Commodity-linked securities (i.e., commodity- based ETFs) are adversely affected by changes in the underlying commodity value, supply and demand and governmental regulatory policies, in addition to overall market movements, taxation, terrorism, nationalization or expropriation, commodity index volatility, changes in interest rates, or factors affecting a particular industry or commodity. Trade Timing. The Wrap Fee Program will determine the timing of purchases and sales of securities for clients’ accounts in accordance with its internal trading policies and procedures, which include procedures for mitigating potential market risk. For various reasons, including market volatility, peak demand or systems upgrades or maintenance, there can be delays in the amount of time it takes trades to be processed and executed. Changes in trade timing can reduce, perhaps materially, the profit clients gain from the transaction or can cause a material loss. Management Risk. Each client portfolio is subject to management risk. This includes the risk that the Wrap Fee Program can make investment decisions that result in losses to client portfolios. For example, in some cases, certain investments are unavailable, or certain investments are not selected or sold prematurely because of market conditions or other reason, when, in retrospect, those investments could have been beneficial to the portfolio. Regulatory Change Risk. It is possible that changes in applicable laws and regulations will affect the Wrap Fee Program. These changes include; changes in investment adviser, broker-dealer or securities trading regulation; a change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities; and changes in the tax code that can affect interest income, income characterization and/or tax reporting obligations. The consequences of such changes on the liquidity and the efficient and orderly functioning of the markets in which client accounts invest cannot be predicted and can materially diminish the profitability of account investments. Reliance on Betterment and Betterment Securities. SVBW relies on Betterment and Betterment Securities for provision of the Wrap Fee Program and the Betterment Platform, ongoing account management and brokerage, custodial and technology services in connection with the Wrap Fee Program. Although SVBW generally believes that Betterment and Betterment Securities are reliable, there can be errors that are beyond SVBW ‘s control in the services they provide, and these errors can compromise the quality and integrity of the Wrap Fee Program and the Betterment Platform. Moreover, the sub-advisory agreement between SVBW and Betterment and Betterment Securities can be terminated for any reason or no reason at all with limited advance notice. Additionally, Betterment and Betterment Securities can experience operational disruptions due to unforeseen circumstances such as political events, natural disasters, or technological developments. In all of these instances, SVBW’s offering of the Wrap Fee Program can be materially compromised. Reliance on Technology. The Wrap Fee Program is dependent upon various computer and Internet-based technologies, many of which are provided by or are dependent on third parties such as data feed, data center, telecommunications, or utility providers. The successful operation of the Wrap Fee Program, and the Betterment Platform in particular, can be severely compromised by system or component failure, telecommunication failure, power loss, a software-related system crash, unauthorized system access or use (such as “hacking”), computer viruses, malware, worms and similar programs, fire or water damage, human errors in using or accessing relevant systems or various other events or circumstances. It is not possible to provide comprehensive protection against all such events, and no assurance can be given about the ability of SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 16 of 17  applicable third parties to continue providing their services. Any event that interrupts such computer and/or telecommunication systems or operations can have a material adverse effect on the Wrap Fee Program for an indefinite time period, including by preventing the Wrap Fee Program from trading, modifying, liquidating and/or monitoring clients’ investments. Such a material adverse effect can have a heightened impact on clients’ accounts given the automated and algorithmic nature of the Wrap Fee Program. Cybersecurity Risk. SVWB and Betterment are subject to cybersecurity risks, which could result in financial losses to clients, the inability to access the Betterment Platform, and/or violations of applicable privacy and other laws that adversely affect clients. SVBW FORM ADV PART 2A, APPENDIX 1 - WRAP PROGRAM BROCHURE 17 of 17 

ITEM 1. COVER PAGE SVB WEALTH LLC FIRM BROCHURE PART 2A OF FORM ADV 53 STATE STREET, 28TH FLOOR BOSTON, MA 02109 Phone: 617-912-1900 firstcitizens.com/wealth Date of Brochure: March 30, 2025 This Form ADV, Part 2 is the SVB Wealth LLC Brochure (the “Brochure”), the disclosure brochure for wealth clients utilizing SVB Wealth LLC’s advisory and portfolio management services. This Brochure provides information about the qualifications and business practices of SVB Wealth LLC (“SVBW”). If you have any questions about the contents of this Brochure, please contact us at 617-912-1900 or compliance.wealth@svb.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration with the SEC does not imply a certain level of skill or training. Additional information about SVBW is also available on the SEC’s website at www.adviserinfo.sec.gov. You can view SVBW’s information on this website by searching for “SVB Wealth LLC.” SVBW’s SEC number is 801-80480 and its CRD number is 172832. Page 1 of 21 SVBW 2025 FORM ADV PART 2A FIRM BROCHURE  ITEM 2. MATERIAL CHANGES This Brochure is dated March 30, 2025, and is the annual update to the Brochure. The following is a summary of material and/or other updates made to the Brochure since it was last updated on April 5, 2024: SVBW is not enrolling new clients into its Wrap Fee Program. However, current clients in the Wrap Fee Program are permitted to rely on the Program and may add assets to their Program Account(s). SVBW discontinued its participation in soft dollar arrangements. Page 2 of 21 SVBW 2025 FORM ADV PART 2A FIRM BROCHURE  ITEM 3 – TABLE OF CONTENTS ITEM 1. COVER PAGE ....................................................................................................................... 1 Contents ITEM 2. MATERIAL CHANGES ................................................................................................................. 2 ITEM 3 – TABLE OF CONTENTS ............................................................................................................... 3 ITEM 4 - ADVISORY BUSINESS ................................................................................................................ 5 Introduction ......................................................................................................................................... 5 Advisory Services ............................................................................................................................... 5 Wrap Fee Program .............................................................................................................................. 6 Financial Planning Services ............................................................................................................... 7 Retirement Plan Advisory Services ................................................................................................. 7 Reasonable Investment Restrictions............................................................................................... 7 ITEM 5 - FEES AND COMPENSATION ...................................................................................................... 8 ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .......................................... 10 ITEM 7 - TYPES OF CLIENTS ................................................................................................................... 10 ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................... 11 Methods of Analysis and Investment Strategies ....................................................................... 11 Risk of Loss ....................................................................................................................................... 11 ITEM 9 - DISCIPLINARY INFORMATION ................................................................................................ 14 ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................. 14 ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ............................................................................................................................................... 15 ITEM 12 - BROKERAGE PRACTICES ....................................................................................................... 16 Best Execution – How We Choose Broker Dealers .................................................................... 16 Fixed-Income Securities Transactions .......................................................................................... 17 Client Directed Brokerage ............................................................................................................... 17 Trade Aggregation & Order Handling ........................................................................................... 17 ITEM 13 - REVIEW OF ACCOUNTS......................................................................................................... 18 Reports Provided to Clients ............................................................................................................ 18 ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ............................................................... 18 Cash Allocations or Balances and Cash Sweep ......................................................................... 18 Intra-Company Referrals .................................................................................................................. 18 Referral Arrangements with Unaffiliated Third Parties............................................................. 19 Page 3 of 21  ITEM 15 - CUSTODY .............................................................................................................................. 19 ITEM 16 - INVESTMENT DISCRETION .................................................................................................... 20 ITEM 17 - VOTING CLIENT SECURITIES ................................................................................................. 20 ITEM 18 - FINANCIAL INFORMATION ................................................................................................... 21 Page 4 of 21  ITEM 4 - ADVISORY BUSINESS Introduction SVB Wealth LLC (“SVBW” or “we” or “us”), a Massachusetts limited liability company, is an investment adviser registered with the SEC under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). SVBW is a wholly owned, non-bank subsidiary of First-Citizens Bank & Trust Company (“FCB”), which in turn, is a wholly owned subsidiary of First Citizens Bancshares, Inc., a publicly traded company (NASDAQ: FCNCA). Previously, SVBW was owned by Silicon Valley Bridge Bank, N.A. (“SVBB”), a full- service Federal Deposit Insurance Corporation (“FDIC”)-operated bridge bank chartered by the Office of the Comptroller of the Currency as a national bank. Before SVBB, SVBW was owned by Silicon Valley Bank (“SVB”), which was closed by the California Department of Financial Protection and Innovation. Upon the closure of SVB, the FDIC, as the appointed receiver, transferred substantially all of the assets of SVB, including SVMW, to SVBB on March 13, 2023. This Brochure describes the investment advisory services offered by SVBW. SVBW’s advisory services are made available to clients primarily through its investment adviser representatives (“IARs”). IARs are individual employees of SVBW that provide investment advice to clients. Some IARs are also registered representatives of First Citizens Investor Services, Inc (“FCIS”), an SEC- registered broker-dealer and a member of the Financial Industry Regulatory Authority (“FINRA”). Information about our IARs is in the Brochure Supplement, which is a separate document provided along with this Brochure. As of December 31, 2024, SVBW had the following regulatory assets under management: Discretionary $ 4,906,870,468 Non-Discretionary $ 76,541,527 Total $ 4,983,411,995 Advisory Services SVBW provides Wealth Management Services, Wrap Fee Program Services, Financial Planning Services, and Retirement Services. The services include portfolio management, access to certain investment strategies of affiliated and unaffiliated third-party investment managers, performance and consolidated financial reporting, and financial, wealth, retirement, and estate planning. Our investment offerings include equities, fixed-income securities, mutual funds, exchange-traded funds (“ETFs”), private funds, and derivatives. Certain offerings are subject to investment minimums and/or specific eligibility requirements. When SVBW provides its services, the IAR will: • develop an investment policy statement that guides the allocations and investment decisions made for the client’s account using the information provided by the client; • determine which, if any, third-party investment managers (“Third-Party Manager(s)”) are appropriate given the client’s investment policy statement (Third-Party Managers may include the IAR, a third party that is affiliated with SVBW, or an unaffiliated Third-Party Manager); and • monitor the Account and Third-Party Manager(s). SVBW offers its services on a discretionary and non-discretionary basis. Non-discretionary advisory services are intended for clients who want to receive ongoing investment advice for a fee but wish to retain ultimate decision-making authority over the trading activity in the accounts they Page 5 of 21  maintain with SVBW (“Account(s)”). SVBW provides ongoing and continuous investment advice and guidance to the client, and the client decides whether to implement SVBW’s investment advice and recommendations. Alternatively, discretionary services are intended for clients who want SVBW to make the investment decisions. The client grants SVBW authority to supervise and manage the Accounts with the ability and authority to determine and make changes to the investment allocations in the Account(s) and assign and monitor Third-Party Managers. Regardless of whether the Account is discretionary or non-discretionary, our investment recommendations and/or decisions are based on the client’s investment objectives, risk tolerance, financial circumstances and other information provided by the client. SVBW may recommend the allocation of a portion of a client’s investment assets among one or more affiliated or unaffiliated Third-Party Managers. SVBW maintains a disciplined research and due diligence process to identify Third-Party Managers that offer investment strategies that we believe provide opportunities not available through, or more appropriate than, investment vehicles such as ETFs or mutual funds. The Third-Party Manager shall have day-to-day responsibility for the management of the Accounts. SVBW shall continue to render investment advisory services to the client through the ongoing monitoring and review of account performance, asset allocation and client investment objectives. SVBW enters into sub-advisory agreements with the Third-Party Managers it recommends for client Accounts. This means that SVBW has discretionary authority to hire and/or fire the Investment Manager on behalf of clients and results in some operational efficiencies regarding the opening and closing of accounts as well as communicating transaction details. Some clients prefer the ability to access private investment funds. SVBW offers eligible clients access to certain unaffiliated private investment funds. SVBW shall not exercise any discretion related to a client’s decision to invest in any private fund. Rather, the decision to invest in any private fund is made by the client and is the client’s responsibility. SVBW’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client decides to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of SVBW calculating its investment advisory fee. Investments in private investment funds involve various risks, including, but not limited to, potential for complete loss of principal, liquidity constraints, and lack of transparency. Unlike liquid investments, private investment funds do not provide daily liquidity or pricing. Wealth Management Services If a client selects the Wealth Management services, the IAR will manage the Account on a discretionary or non-discretionary basis, as selected by the client. Additional fees for any Third- Party Manager(s), custodian(s) and transactions will be charged to the client in addition to the Advisory Fee. Item 5 - Fees and Compensation lists the fees charged for the Wealth Management Services. Wrap Fee Program SVBW no longer offers the Betterment wrap fee program. Existing clients are permitted to add addition funds. No new accounts are being accepted at this time. Item 5 - Fees and Compensation lists the fees charged for the Wrap Fee Program Services. request from an IAR, or at Additional information about this program is contained in the Appendix 1 Wrap Brochure, which the SEC’s website at can be obtained upon www.adviserinfo.sec.gov/IAPD. Page 6 of 21  Financial Planning Services SVBW offers financial planning to clients to formulate investment strategies and provide investment advice and education more effectively. In some circumstances, SVBW will prepare and deliver the client a written financial plan to assist with achieving individual financial goals and investment objectives. The preparation of such a plan necessitates that the client provides us with personal data such as family records, budgeting, personal liability, estate information, and additional financial information. Not all clients will engage in the financial planning process. ‐ A written financial plan can generally include any or all of the following: asset protection, tax planning, business succession, strategies for exercising stock options, cash flow, education planning, estate planning, wealth transfer, charitable gifting, long term care, disability planning, retirement planning, insurance planning, asset allocation comparisons, and risk management. The IAR may not include all topics in developing their analysis and recommendations under a written financial plan. The implementation of financial plan recommendations is entirely at the client’s discretion. SVBW, at its discretion, offers some financial planning services without charge. Complex financial plans are generally referred to FCB and will incur a fee that is negotiable in advance. Clients are under no obligation to accept or implement a financial plan from FCB. These fees are in addition to any Fees charged for other services. SVBW does not provide tax, accounting, or legal advice. SVBW suggests its clients work closely with their attorneys, accountants, or other professionals should the client(s) choose to implement any or all recommendations contained in the written plan. Implementation of the written plan may include persons who, in certain circumstances, are also employees or affiliates of SVBW. In certain circumstances, SVBW will be compensated by an affiliate or non-affiliated third-party for referrals made to address or implement recommendations made from financial planning activities. The client remains responsible for notifying SVBW of changes in financial circumstances, investment objectives, or investment restrictions. Also, we will not independently verify any information we receive from and will rely upon the accuracy and completeness of the information provided in performing our services when creating a financial plan. Item 5 - Fees and Compensation lists the fees charged for Financial Planning. Retirement Plan Advisory Services In addition, a team comprised of certain SVBW IARs known as the Retirement Plan Advisory Team (the “RPA Team”) specializes in providing counseling and advice to businesses on effective plan governance and delivery of employee retirement benefits subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). The RPA Team provides services to assist plan sponsors, plan trustees, and investment committees to meet their fiduciary responsibilities. The investment advisory services provided by the RPA Team include preparation of investment policy statements, evaluation, selection, and reporting of investments, and advising clients on education and communication with plan participants. The RPA Team counsels plan fiduciaries with its expertise in plan governance, risk assessment, and expense analysis. Item 5 - Fees and Compensation lists the fees charged for a Retirement Plan Advisory Services. Reasonable Investment Restrictions With respect to most advisory services described in this Brochure, clients may seek to impose reasonable investment restrictions on the management of their Account, including requesting, in writing, particular securities that should not be purchased for an Account. Page 7 of 21  ITEM 5 - FEES AND COMPENSATION SVBW provides services to clients on a fee basis (the “Fee”). The Fee is either an asset-based, a fixed annual fee, or a flat fee, depending on the particular services provided. In its discretion, and subject to the Fee schedules included below, SVBW may negotiate the Fee and method of billing based on a number of factors, including type and size of the Account, services provided, historical factors and/or the client’s relationship with SVBW, subject to internal guidelines. Wealth Management Services Fees The Wealth Management Service Fees are generally asset-based, expressed as an annual percentage of the assets in the account. The fees cover a range of available services including management, consulting and administrative services provided by SVBW, ongoing monitoring of investment managers, and services provided by the IAR (including periodic reviews of the Account). The Fees are set forth below in the Fee Schedules and represent the maximum standard annual rate. Wealth Management Services Accounts are charged the Fee quarterly, in advance, based on the net market value of the assets in the Account (including all cash and cash equivalents such as money market mutual funds, cash sweep funds, or other short-term instruments) on the last day of the previous quarter. In most cases, the Fee is automatically deducted from the Account. As circumstances warrant, and pursuant to the specific terms of the Client Agreement, SVBW may instead charge an asset-based fixed rate or fixed dollar investment management fee (see below). The services continue in effect until terminated by either party (i.e., the client or SVBW) by providing written notice of termination to the other party. Upon such notice, SVBW will cease making investment decisions for the client and implement any reasonable written instructions. Client’s agreement will be terminated only after any open trades have been settled. SVBW will refund any un-earned portion of its Fee. The tiered fee schedule below is assessed for each account, and SVBW does aggregate other accounts for the client (Householding) when determining the fee. Fee Schedules Account Value Annualized Fee First $1,000,000 1.25% Next $1,500,000 1.15% Next $7,500,000 0.90% Over $10,000,000 0.70% Although SVBW does not have any stated account minimums, Accounts with a portfolio value of $1,000,000 or less can pay effective fees greater than (or equal to) 1.25%. In limited circumstances and in SVBW’s sole discretion, SVBW might agree upon an engagement for a fixed annual dollar fee. The Fee is determined on a variety of factors which generally include the level and scope of the services to be provided, the client’s overall relationship with SVBW and potential for future business, and the professional providing the services. Certain legacy clients have agreements that provide a fixed annual fee for services which may be more or less than other clients are paying or will pay for receipt of the same services. Page 8 of 21  transaction fees, custodial Clients are also responsible for any other fees and expenses related to their Accounts that are payable to other entities, as applicable. Since SVBW is not a broker-dealer, SVBW does not charge for brokerage commissions, transaction fees, exchange fees, SEC fees or other related trading costs and expenses. Rather, such commissions, fees and costs will be charged directly to clients by the clients’ custodian and/or broker-dealer. Additional fees and expenses that may be directly billed or borne proportionately by the client and third parties include brokerage fees, commissions, fees, transfer taxes, odd-lot differentials, margin interest, deferred sales charges (on mutual funds or annuities), wire transfer and electronic fund processing fees, advisory fees, administrative fees charged by mutual funds and ETFs, custody fees, administration fees and all other fees charged by service providers providing services relating to client Accounts. Custodian statements may display certain transaction fees per trade, but commissions on certain statements or for certain transactions will be reflected in the net share price and not disclosed separately. In certain situations, and for certain transactions, transaction fees may be charged by the custodian to SVBW. See Item 12 Brokerage Practices for more information. For client Accounts invested with and managed by a Third-Party Manager, the client is responsible for paying the fee(s) charged by each such Third-Party Manager for an Account, as applicable. Third-Party Manager fees are separate from, and in addition to, SVBW’s Fee. Fees vary by Third-Party Manager range from 0.25% - 1.00% per annum. Wrap Fee Program Fees The Wrap Fee Program charges clients an all-inclusive Fee equal to 0.40% of the value of the assets in the Account calculated on an annualized basis. Of the 0.40%, 0.25% is received by Betterment and 0.15% is received by SVBW. Betterment calculates and automatically debits the Fee from client accounts. SVBW does not charge its portion of the wrap fee directly to clients. Additional information about Fee for the Wrap Fee Program is contained in the Appendix 1 Wrap Brochure, which can be obtained upon request from an IAR, or at the SEC’s website at www.adviserinfo.sec.gov/IAPD. Financial Planning Fees The Financial Planning Fee is typically billed either as a fixed dollar or asset-based fee, or a combination thereof, as negotiated with the client and reflected in the applicable Client Agreement. Retirement Plan Advisory Fee The Retirement Plan Advisory Fee is negotiated rate in advance of services. The Fee is either a fixed dollar fee and/or an asset-based fee not to exceed 0.50%. Additional Information Regarding Fees and Expenses Automatic Fee Deduction/Billing. When the Account assets are held with certain custodians, we will deduct the Fee directly from the Account. Otherwise, we will send an invoice to the client’s custodian, who will be authorized to deduct fees directly from the Account(s). Account statements sent directly from the custodian will show all transactions in the Account(s), including SVBW’s Fee. Clients should review their statements to confirm the accuracy of transactions, values, and fees. Mutual Fund and ETF Management Fees. Investments in mutual funds and ETFs include an embedded investment management fee paid to the investment adviser of the mutual fund or ETF. As such, client accounts with investments in mutual funds and/or ETFs will be subject to two Page 9 of 21  layers of management fees. The fees and expenses associated with each mutual fund or ETF are described in the prospectus for each such fund; clients should read these documents in detail to understand the costs associated with investments in mutual funds and/or ETFs. Mutual Fund Transaction Fees. Depending on the custodian, SVBW may be able to purchase mutual funds with no transaction fees. Note that clients who do not trade through specific custodians may not be eligible for these waived transaction fees. Fees may be imposed upon early redemption if the fund was owned prior to our management or if we sell the fund in our discretion. An explanation of the fees and expenses associated with each mutual fund is contained in that fund’s prospectus. Private Investment Fund Fees and Expenses. If client assets are allocated to an unaffiliated private investment fund, clients generally bear all fees and expenses applicable to the investment in the funds, including fixed fees, asset-based fees, performance-based fees, carried interest, incentive allocation, and other compensation, fees, expenses and transaction charges payable to third-party fund managers in consideration of their services to the funds. Additionally, clients will indirectly bear their pro rata share of other expenses incurred by the fund, which typically include administrative, custodial, transaction and organizational costs, accounting and audit, insurance, research, travel, and other costs necessary to carrying out the business of the fund and production of the fund’s net asset values. Investors should review the applicable fund governing documents to understand the nature and extent of fees to be paid in addition to SVBW’s Fee. Donor Advised Fund Fees. If client assets are allocated to a donor advised fund, the client will be responsible for paying all fees charged by the fund on those assets in addition to SVBW’s Fee. The fund will impose and arrange for the automatic deduction of its own fees from the liquidity account of each affected client. SVBW believes that its Fee is reasonable considering: (1) services provided and (2) the fees charged by other investment advisers offering similar services and programs. However, our Fee is higher than some investment advisers providing similar services or programs. ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT SVBW and its IARs do not charge or accept performance-based fees. However, from time to time, certain strategies of Third-Party Managers and/or private funds that SVBW makes available to clients may be subject to performance-based fees. ITEM 7 - TYPES OF CLIENTS SVBW’s clients include individuals, IRAs, trusts, estates, charitable organizations, foundations, family offices, banks and thrift institutions, pension, and profit-sharing plans, including plans subject to ERISA, participants in such plans, and corporations and other business entities. Certain investment offerings and/or strategies require the client to maintain a minimum amount of assets to open and invest/enroll an Account in that offering or strategy. Where applicable, SVBW may, in its discretion, waive or reduce these minimum requirements for certain clients or Accounts. These include certain proprietary separate account strategies of SVBW, strategies of Third-Party Managers, and most private fund offerings. If an Account falls below a required minimum, SVBW can terminate its services in accordance with the terms of the Client Agreement. Page 10 of 21  ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Methods of Analysis and Investment Strategies IARs may build custom allocations for clients, select from pre-built models provided by Third-Party Manager(s), or select Third-Party Managers. Investment recommendations, including model selection and Third-Party Manager selection, are based on an analysis of the Client's individual needs and are drawn from research and analysis. Our investment strategy begins with an understanding of the client's financial goals. The IAR uses demographic and financial information provided by the client to assess the client's risk profile and investment objectives in determining an appropriate allocation of securities for the client's assets. SVBW uses fundamental, quantitative, and technical analysis in evaluating securities. Fundamental analysis involves looking at economic, financial, and other qualitative and quantitative factors to measure a security’s value. We use various financial databases to screen publicly traded companies to identify a smaller universe of candidates that meet our criteria for growth, value, equity, and income (dividends). We rely on tools such as Bloomberg Professional, FactSet and BondEdge. We also use commercially available technology, financial periodicals and other publications, SEC filings, and financial statements to assist with our analysis. In certain instances, we also use outside consultants to provide expertise in particular areas or for more in- depth analysis. These views and analyses received from broker-dealers (“sell-side research”) are also considered as part of SVBW’s evaluation process. Our investment selection process for fixed-income securities is based on the specific client’s goal for liquidity and our view of the environments for interest rates and corporate and/or municipal credit. SVBW may recommend certain Third-Party Manager(s). When it does, the investment team employs a due diligence review process to select the Third-Party Managers. This initial review includes quantitative and qualitative assessments of each Third-Party Manager. SVBW’s investment team monitors Third-Party Managers for adherence to their stated investment process and regularly assesses whether risks are being responsibly managed. This process is also applied to the selection of mutual funds, ETFs, and limited partnership structures and funds. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. Investment performance cannot be predicted or guaranteed, and the value of a client’s assets will fluctuate due to market conditions and other factors. Investments are subject to various risks, including, but not limited to, economic, political, market, currency, liquidity, and cybersecurity risks and will not necessarily be profitable. Past performance of investments is not indicative of future performance. Depending on the type of service being provided, SVBW and its IARs can recommend different types of securities, including, but not limited to, mutual funds, ETFs, equities, fixed income securities, certain private funds, options, and other investment vehicles. Described below are some risks associated with investing and with some types of investments that SVBW and the IARs can recommend. For a more complete summary of material risk factors and conflicts of interest associated with the Third-Party Managers, please refer to the applicable Third-Party Manager’s Form ADV Part 2A. Clients should also review the offering materials and prospectuses produced by issuers and sponsors of investment products and other disclosure available for each relevant investment, security, or transaction to understand associated risks and costs. Page 11 of 21  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, global, political, economic, and social conditions may trigger market events. Either the stock market as a whole or the value of an individual company, could decrease in the value, resulting in a decrease in value of the investments, also referred to as systematic risk. 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. Company and Industry Risk. When purchasing stock positions, there is always a certain level of company or industry-specific risk that is inherent in each investment and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. Regulatory Risk. There have been legislative, tax, and regulatory changes and proposed changes that may apply to the activities of SVBW that may require legal, tax, and regulatory changes, including requirements to provide additional information pertaining to a client account to the Internal Revenue Service or other taxing authorities. Regulatory changes and restrictions imposed by regulators, self-regulatory organizations, and exchanges vary from country to country and may affect the value of client investments and their ability to pursue their investment strategies. Any such rules, regulations and other changes, and any uncertainty in respect of their implementation, may result in increased costs, reduced profit margins and reduced investment and trading opportunities, all of which would negatively impact performance. Fixed Income Risk. When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed income investors receive set, regular payments that face the same inflation risk, although inflation- protected products may also be available. Options Risk. Options on securities may be subject to more significant fluctuations in value than an investment in the underlying securities. Purchasing and writing put, and call options are highly specialized activities and entail greater than ordinary investment risks. ETF and Mutual Fund Risk. When investing in an ETF or mutual fund, the client will bear additional expenses based on the pro-rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. Non-U.S. Securities. International investments involve special risks not typically associated with trading in investments relating to markets and/or issuers solely in the U.S. These risks may include: changes in exchange rates and exchange control regulations; downgrades in sovereign credit ratings; devaluations or non- convertibility of non-U.S. currencies; failures or disruptions in central banks, banking systems, markets or financial exchanges; changes in monetary policies, interest rates or interest rate policies; political, social and economic instability; adverse diplomatic developments; investment and repatriation restrictions; the nationalization and/or expropriation of assets; government intervention in the private sector; default by public and private issuers on their financial obligations (and limited recourse in connection with such defaults); the imposition of non-U.S. taxes; discrimination against foreign investors; less liquid markets; less information; Page 12 of 21  higher transaction costs; less information regarding legal and regulatory risks; less uniform accounting and auditing standards; greater price volatility; less reliable clearance and settlement procedures; and/or less government supervision of exchanges, brokers, market intermediaries, issuers and other markets and market participants, than is generally the case in the United States. Liquidity Risk. Securities that are normally liquid may become difficult or impossible to sell at an acceptable price during periods of economic instability or other emergency conditions. Some securities may be infrequently or thinly traded even under normal market conditions. Certain investments including private placement vehicles are inherently illiquid and therefore involve additional risks. Derivative Instruments. Derivative instruments, such as futures, options, and swaps, are financial contracts whose value is derived from the performance of underlying assets, rates, or indices. These are widely used for hedging, speculation, and arbitrage purposes across various financial markets. Investing and engaging in derivative instruments and transactions, including commodity funds and commodity ETFs, may involve different types of risk and possibly greater levels of risk, like greater responses to market events, counterparty credit risk, illiquidity, and valuation discrepancies. Margin Accounts. Some of our investment strategies require that clients maintain a margin account. Clients who purchase securities may pay for them in full (a “cash account”) or may borrow part of the purchase price from the broker-dealer that holds his/her account (a “margin account”). Clients generally use margin to leverage their investments and increase their purchasing power. At the same time, clients who trade securities on margin incur the potential for higher losses. We will discuss the risks of using margin with each client to determine if it is appropriate for their portfolio but, in general, would like for clients to know about some of the major risks of trading on margin. Clients can lose more funds than deposited in a margin account. The broker-dealer holding the client account can force the sale of securities in the account. The broker-dealer can sell client securities without contacting the client. Clients are not entitled to an extension of time on a margin call. 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. Management Risk. The client’s investment with our firm varies with the success and failure of our investment strategies, research, analysis, and determination of portfolio securities. If our investment strategies do not produce the expected returns, the value of the investment will decrease. Cybersecurity Risk Due to the increased use of technology in our business and the financial services industry in general, SVBW is subject to cybersecurity risks potentially resulting in financial losses to clients and/or violations of applicable privacy and other laws that adversely affect clients. Client investments may also be subject to other risks specific to certain securities, which are further described in the underlying prospectus or other disclosure statement from the issuer of those securities. Clients should carefully review all available disclosures for any securities. Additionally, despite SVBW’s affiliation with FCB, client assets managed by SVBW are not bank deposits and are not insured or guaranteed by the FDIC or any other government agency entity or person and may lose value. Page 13 of 21  ITEM 9 - DISCIPLINARY INFORMATION Registered investment advisers are required to disclose all legal or disciplinary events that are material to a client’s or prospective client’s evaluation of its advisory business or the integrity of its management. As of the date of this Brochure, neither SVBW nor its management personnel have been subject to, or involved in, any legal or disciplinary events required to be disclosed in this Brochure. ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS SVBW is owned by First Citizens BancShares, Inc. and is under common ownership with the following entities: • CIT Capital Securities LLC., a Broker/Dealer • CIT Asset Management, a Registered Investment Adviser • SVB Asset Management, a Registered Investment Adviser • SVB Wealth LLC, a Registered Investment Adviser • First Citizens Asset Management, Inc., a Registered Investment Adviser • First Citizens Investor Services Inc., a Broker/Dealer, Registered Investment Adviser and Insurance Agency • Neuse Title Services, an Insurance Agency Some of SVBW’s affiliates are registered investment advisers, registered broker-dealers, and/or licensed insurance agencies. Some, but not all, investment adviser representatives of SVBW are also broker-dealer registered representatives of FCIS and/or insurance agents. The IAR providing advice may implement recommendations as a registered investment adviser, registered representative, or insurance agent when appropriately registered or licensed to do so. When the IAR implements the recommendations, the IAR receive compensation for advice implemented as a registered investment adviser, registered representative, or insurance agent. Each role has a different duty to the client, for example, individuals acting as registered investment advisers have a fiduciary duty to their clients, while registered representatives and insurance agents must comply with the suitability requirements and regulation Best Interest. An inherent conflict of interest exists for IARs who are dually registered and insurance licensed. When an IAR is dually registered he/she can sell securities on a commission basis. An IAR may suggest that a client implement investment advice by purchasing products through a commission- based brokerage account in addition to or in lieu of a fee-based advisory account. This receipt of commissions creates an incentive to recommend those products for which an IAR will receive a commission in his or her separate capacity as a registered representative of a securities broker- dealer. Consequently, the objectivity of the advice rendered could be biased. Clients are under no obligation to use the services of the IAR in this separate capacity. When an IAR is licensed as an insurance agent, the IAR may sell, general disability insurance, life insurance, annuities, and other insurance products. Neither SVBW nor its IARs will receive any commissions or additional income related to the sale of any such products. Upon specific client request, IARs may introduce clients to personnel of FCB to discuss bank products and other services. Such introductions are not part of the investment advisory services SVBW provides to its clients. SVBW IARs and their management personnel receive a subjective Page 14 of 21  annual bonus at the discretion of their supervisors but not directly related to the sales of specific products/services. First Citizens may also invest in or otherwise have an ownership interest in certain SVBW clients. Due to SVBW’s relationship with First Citizens, SVBW has an indirect financial interest in making such introductions and fostering relationships between FCB and its clients.1 In appropriate circumstances, SVBW will recommend that a client roll over an account held in a former employer’s retirement plan or an outside IRA to an IRA managed by SVBW. If the client elects an IRA rollover or transfer subject to SVBW’s management, the account will be subject to SVBW’s Fee per the Client Agreement. IAR’s recommendation to roll over retirement plan or IRA assets into an IRA managed by SVBW presents a conflict of interest because such a recommendation creates an incentive to recommend the rollover for the purpose of generating additional compensation rather than solely based on the client’s needs. When SVBW provides investment advice or recommendations to a client regarding their retirement plan assets, IRA account or rollover IRA, SVBW is acting as an investment advice fiduciary within the meaning of Title I of ERISA. Further, when SVBW recommends a rollover or transfer to an IRA, the client is never under any obligation to complete a rollover or transfer or to have the rollover IRA assets managed by SVBW. SVBW does not receive any compensation for the recommendation of other investment advisers to its clients. Neither SVBW nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, or a commodity trading advisor. ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING SVBW has adopted an Investment Adviser Code of Ethics (the “Code of Ethics”) in accordance with Rule 204A-1 of the Advisers Act. The Code of Ethics applies to those SVBW personnel engaged in offering and/or providing investment advisory services to clients (also known as supervised persons). Among other things, the Code of Ethics requires supervised persons to comply with applicable securities laws, exhibit high ethical standards and place clients’ interests first in accordance with SVBW’s fiduciary duty to its clients. Supervised persons who fail to observe the Code of Ethics and related policies and procedures risk serious sanctions, including dismissal. The Code of Ethics also sets forth SVBW’s policies and procedures regarding personal securities transactions. These policies and procedures are designed to identify and prevent or mitigate actual conflicts of interest and to address such conflicts appropriately if they do occur. Supervised persons are required to submit periodic reports regarding personal securities transactions, holdings, and accounts. Supervised persons are required to report all securities transactions and holdings except for U.S. government obligations; money market funds; bankers acceptances; bank CDs; 529 plans, commercial paper; high quality short-term debt instruments; shares issued by money market funds; open end mutual funds registered in the U.S. and shares issued by unit investment trusts that are exclusively invested in open-end mutual funds registered in the U.S. SVBW compliance is responsible for reviewing such employee reports. 1 First Citizens also provides a variety of support services to SVBW, including human resources, information technology, facilities, finance, legal, and administrative support. SVBW does not believe such support services create a material conflict of interest with clients. Page 15 of 21  In certain instances, SVBW employees may invest in the same securities that SVBW recommends to its clients. Such transactions are reviewed on a post-trade basis and if such transactions are permitted, it is because SVBW believes that such transactions do not present a conflict of interest considering the markets and liquidity for the securities traded. The Code of Ethics also provides that supervised persons may not serve on the board of directors of any public company, including mutual fund boards of trustees, without prior approval. Employees must obtain prior written permission to serve as a trustee on a client account other than the account of a family member or to serve as a trustee or a board member for any charity or not- for-profit entity. Our employees do, in fact, serve in these capacities on various charitable, civic and community boards. If such service is approved, it is because we have determined it does not create any conflict of interest. SVBW does not buy securities from, or sell securities to, its clients (i.e., SVBW does not engage in “principal transactions” with its clients). SVBW is not a registered broker-dealer and does not engage in “agency cross” trades between clients. SVBW will provide a copy of the Code of Ethics free of charge to any client or prospective client upon request. ITEM 12 - BROKERAGE PRACTICES Client assets are required to be maintained in an account with a “qualified custodian,” as defined under the Advisers Act. Clients can request to custody their Account assets with any number of unaffiliated custodians who are qualified custodians; generally, SVBW’s clients elect to use Fidelity Brokerage Services LLC (“FBS”) and its affiliated custodian National Financial Services LLC (“NFS”) or Charles Schwab & Co. (“Schwab”), each registered broker-dealers, as the qualified custodian. Clients enter into a separate agreement with the custodian(s) for these brokerage and custody services. SVBW is not affiliated with these broker dealers. These custodians hold client assets in a brokerage account and buy/sell securities upon SVBW’s instruction. SVBW is also able to execute trades for client accounts through other brokers that are not the custodian of a particular client’s Account assets. In certain circumstances, clients can request to enter into an arrangement to custody their Account assets with SVBW’s parent company, FCB. Any such client would enter into a separate agreement with FCB for custody and brokerage services, and authorized SVBW personnel have the same access/limitations with respect to client Accounts held with FCB as with an unaffiliated custodian. Although FCB is an affiliate of SVBW, any potential conflict of interest has been minimized if clients choose to custody with FCB. FCB does not charge any separate custodial fees and SVBW is not incentivized to direct clients to FCB. Best Execution – How We Choose Broker Dealers When it comes to executing transactions for client accounts, SVBW uses several different brokerage firms. SVBW utilizes independent brokers and dealers to purchase and sell securities for client accounts. In selecting brokers and dealers to effect client transactions, seek: (1) the prompt execution of client transactions while market conditions still favor the transaction and (2) the most favorable net prices reasonably obtainable taking into account the relevant circumstances. This is called “best execution”. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution. In making this assessment we consider the full range of a broker-dealer’s services, including the value of research provided, execution Page 16 of 21  capability, commission rates, and responsiveness. SVBW does not consider participation in the Fidelity Wealth Advisor Solutions® (“WAS”) program, (please see Item 14 Client Referrals and Other Compensation below) in choosing brokers and dealers to execute client transactions. Certain custodians have programs that allow us to transact in mutual fund shares and other securities without transaction charges or at nominal transaction charges. Fixed-Income Securities Transactions Fixed-income securities (i.e., bonds) are generally traded in an over-the-counter market. In this market, bond dealers place bids and make offers to buy and sell bonds on a net basis with no stated commission plus accrued interest. Any commission or net markup is implied by the difference or “spread” between the price the dealer purchases the bond for and the price the dealer sells the bond at. A new issue bond is sold to purchasers at a net price with a fixed sales credit paid to the underwriter by the issuers of the bond. Dealers identified and approved as fixed-income trading partners are listed on SVBW’s “Fixed- income Approved Dealer List.” Before SVBW selects a new fixed-income dealer, a member of the Fixed- income Department identifies the new dealer to be considered and provides due diligence material to the Chief Investment Officer for approval. Under the oversight of the investment policy committee, the Chief Investment Officer reviews this due diligence material and approves or rejects the selection of the dealer. On an ongoing basis, the fixed-income team monitors our relationships with dealers on our “Fixed-income Approved Dealer List” and documents any issues involving a particular dealer. Client Directed Brokerage Certain clients may direct SVBW to use a particular broker or dealer who has an existing relationship with or provides custodial or other services to a client. SVBW requires any directed brokerage instructions to be in writing. Directed brokerage may cost clients more money. Before choosing to enter into a directed brokerage arrangement, clients should be aware of the following disadvantages: • Directed brokerage clients may pay higher commission rates than those paid by other clients, may receive less favorable trade executions and may not obtain best execution on their transactions. • • Directed brokerage accounts may not be able to participate in aggregated or block transactions with other clients. This may preclude directed brokerage accounts from obtaining more favorable terms that might be available from aggregated transactions. If SVBW is placing orders in the same security for both directed brokerage clients and clients that do not direct, SVBW may place orders for directed brokerage clients after it has placed orders for other clients. As a registered investment adviser, we have a duty of best execution to our clients. Accordingly, we retain the right to decline client requests for directed brokerage if, in our sole discretion, we determine it would result in additional operational difficulties or violate restrictions imposed by other broker-dealers. Trade Aggregation & Order Handling SVBW can purchase or sell the same securities for several clients at approximately the same time. Consolidation of orders referred to as “aggregating orders” or “block trading,” is used by firms if believed such actions may prove favorable for the clients. Under this procedure, transactions will be averaged in price and allocated to the clients in proportion to the purchase or sale orders placed for each client's account on any given day. When SVBW chooses to aggregate Page 17 of 21  client orders, SVBW will do so following the parameters of the SEC No Action Letter, SMC Capital Inc., dated September 5, 1995. SVBW does not receive any additional compensation or remuneration because of aggregating orders. ITEM 13 - REVIEW OF ACCOUNTS We review client accounts on at least an annual basis as part of our standard advisory services, except in the limited situations when we provide (1) non-discretionary advice for assets under our advisement, or (2) financial planning services on a one-time basis, i.e., not an ongoing investment advisory relationship for which we provide continuing advice. These reviews can include, among other things, a review of overall performance of investments compared to the client’s stated objectives, a review of asset allocation changes in the portfolio, a determination of actual and expected liquidity needs of the Account, a review for cash flow reinvestment planning, and/or a comprehensive review of a client's overall asset allocation, liquidity position and performance that takes into account both client assets managed by SVBW and client assets held in private or illiquid investments with third-party custodians. Account reviews can be triggered based on certain events, including changes in a client’s liquidity needs, security offerings in the marketplace, and/or certain market events, among others. A review might also occur if the performance of a client’s Account drifts more than a certain percentage from the chosen benchmark(s) for a given Account. Changes in a client’s financial circumstances, investment objectives or other information may also trigger an investment review if IARs are apprised of such changes by their clients. Accounts are reviewed by a client’s IAR(s) responsible for managing the client’s portfolio. Reports Provided to Clients Upon request, SVBW will provide clients with quarterly reports for their Account(s) containing pertinent information related to their managed assets and the services SVBW is providing. Such quarterly reports will generally include a list of holdings and a summary of inflows and outflows, performance, and asset allocation breakdown for each Account, in addition to other relevant data. ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION Cash Allocations or Balances and Cash Sweep Certain custodians offer access to certain sponsored cash sweep options per each client’s separate custodial agreement. As discussed in Item 5, SVBW’s Fee is typically applied to all assets in a client’s Account including allocations to cash and cash equivalents, which include funds allocated to cash sweeps. Intra-Company Referrals FCB refers clients to SVBW and vice-versa. SVBW ensures that its services are in the best interest of clients referred to it by FCB. Although SVBW believes that value exists in the opportunity to have access to FCB’s products and services, such referrals nevertheless present a conflict of interest because SVBW IARs have a direct financial incentive to refer clients to FCB for such banking products and services. That is, IARs receive direct payment for referring clients to FCB for banking, lending, and deposit products which is calculated and paid strictly from internal sources. In no circumstance does a client pay additional fees or expenses beyond the customary charges for the services chosen. When warranted by the totality of the client relationship, a client sometimes receives more favorable rates for the banking products/services purchased. In addition to making referrals to FCB, IARs are eligible for additional compensation based on other factors as well, Page 18 of 21  including, but not limited to, achieving certain levels of production, sourcing new FCB relationships, and training new advisors. SVBW mitigates the conflicts of interest that may arise from intra-company referrals with transparency, client consent, applying the Best Interest standard, providing alternative options and robust compliance and monitoring framework. Referral Arrangements with Unaffiliated Third Parties From time to time, SVBW enters into agreements with certain unaffiliated third parties (“Solicitors”) to refer prospective clients to us in accordance with Rule 206(4)-1 of the Advisers Act. Under these arrangements, SVBW generally pays Solicitors when a referred prospective client becomes an investment advisory client of SVBW. SVBW generally pays the Solicitor a specified portion of the advisory fee it receives from each referred client relating to such client’s Account, pursuant to the terms of the agreement between SVBW and any such Solicitor. SVBW’s participation in WAS Program, has changed as of March 27, 2023. Although SVBW retains clients acquired through the program, SVBW has ceased active participation and will no longer receive new referrals. ITEM 15 - CUSTODY As described in Item 12, except as described below, SVBW generally does not act as custodian for Account assets, meaning that it does not directly hold or have physical possession of client funds or securities, with limited exception in trust accounts. All advisory client funds and securities are required to be held with a “qualified custodian,” as defined under the Advisers Act. Clients enter into a separate agreement with the qualified custodian for the assets in their Account(s) and are responsible for any fees or costs charged by their custodian which are separate and apart from the Fee SVBW charges to clients. In certain circumstances, SVBW is deemed to have custody for purposes of amended Rule 206(4)-2 of the Advisers Act for one or more of the following reasons: • Assets managed by SVBW can be custodied with its banking affiliate, FCB; • SVBW is authorized by its clients to debit our advisory fees directly from client Accounts; • From time to time First Citizens Bank enters into a control agreement with SVBWs clients where the assets in an advisory account are held as collateral for a First Citizens Bank loan. Under such circumstances, and as per a properly executed control agreement, First Citizens Bank would have the ability to direct SVBW to liquidate securities in a pledged advisory account and transfer funds to the Bank, depending on certain triggering events, including loan default. Under SEC rule 206 (4)-2 FCIS also has custody of these pledged assets because SVBW is not operationally independent from First Citizens Bank. • SVBW has authorization to direct payments from client Accounts held by a certain custodian. Because SVBW is deemed to have custody of the assets held in certain accounts, the SEC requires an annual surprise exam to be conducted by an unaffiliated CPA firm. Where SVBW is deemed to have custody of client Account assets, those clients receive custodial statements detailing all transactions in their applicable Accounts (including contributions and withdrawals), fees and expenses charged to the Accounts, and the value of the Accounts at both the beginning and the end of each reporting period. Additionally, the custodian will produce a year-end summary and related tax reporting documents, as applicable. Page 19 of 21  Clients should always carefully review all custodial statements for accuracy. ITEM 16 - INVESTMENT DISCRETION With respect to certain investment advisory services, SVBW accepts discretionary investment authority as delegated by clients via a limited power of attorney in the applicable Client Agreement. Discretionary authority means that SVBW may exercise investment discretion over a client’s Account to effect transactions for the client without first having to seek the client’s approval. The Client Agreement provides a power-of-attorney for the limited purpose of providing SVBW with the full authority to purchase, sell or otherwise effect transactions involving the assets in the client’s account. SVBW’s Wealth Management Agreement allows clients, in writing, to direct SVBW to purchase or sell individual securities. Additionally, clients may impose custom restrictions or limitations on their accounts, e.g., dictating certain securities or sectors to be excluded or specifying particular securities to hold. We accommodate these personalized requests to the extent that they align with the client’s overall investment strategy and SVBW’s investment capabilities. SVBW documents client-imposed restrictions to better understand, and incorporate the restrictions into the investment management process, maintaining regular communication with the client to review and adjust these constraints as necessary to align with their evolving investment goals and market conditions. Where SVBW has been delegated discretionary authority by a client, such discretionary authority extends to the following responsibilities: the amount and type of securities to be purchased or sold for a Client’s Account(s), the timing of transactions, and, as applicable, the Third-Party Manager(s) and strategy or strategies to be utilized or discontinued for a client’s Account. ITEM 17 - VOTING CLIENT SECURITIES For those Accounts where clients have delegated, and SVBW has accepted, proxy voting authority, SVBW is responsible for handling the voting of all proxies related to securities held in such client Accounts. SVBW employs a third-party proxy voting service, Broadridge Investor Communication Solutions, Inc. (“Broadridge”), to vote client proxies in accordance with one of its two adopted standard proxy voting guidelines of Glass Lewis. Clients may choose between U.S. Proxy Voting Policy Guidelines or Socially Responsible Investing Proxy Voting Guidelines. SVBW may, but is not required to, authorize Third-Party Managers to vote any proxies relating to the sub-advised assets in accordance with the Third-Party Manager’s proxy voting policy. Conflicts can arise when an external Third-Party Manager or any of their respective affiliates or employees has any financial, business, or personal relationship with the issuer of a proxy proposal for a security held in a client’s Account. In those limited instances, to avoid potential conflicts of interest, SVBW would vote proxies in accordance with one of our predetermined guidelines. In limited situations, we may consider voting under our own initiative for a particular issue, if we believe that it is in the best interest of the client. Before we reclaim proxy voting authority from Broadridge, we will determine and confirm that no potential conflict of interest exists. To obtain information regarding proxy voting standard guidelines or how specific proxies were voted, please submit a request to compliance.wealth@svb.com. Page 20 of 21  ITEM 18 - FINANCIAL INFORMATION SVBW is not required to include a balance sheet in this Brochure because SVBW does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. discretionary Account(s). SVBW is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to its clients. SVBW has not been the subject of a bankruptcy petition at any time during the past ten years. Page 21 of 21