MATTER, LLC

Matter Family Office ADV Brochure 03/28/2025 www.matterfamilyoffice.com ITEM 1 COVER PAGE This brochure provides information about the qualifications and business practices of Matter, LLC doing business as Matter Family Office. If you have any questions about the contents of this brochure, please contact Erin O’Neill at (303) 552-0900 or eoneill@matterfamilyoffice.com.The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Matter Family Office is also available on the internet at www.adviserinfo.sec.gov. You can view our firm’s information on this website by searching for Matter Family Office or by using the firm’s CRD number: 106806. *Registration as an investment advisor does not imply a certain level of skill or training. 7711 Bonhomme Avenue Suite 400 Clayton, MO 63105 314-862-5190 3811 Turtle Creek Suite 800 Dallas, TX 75219 214-453-5514 210 University Blvd Suite 220 Denver, CO 80206 303-552-0900 1  ITEM 2 – MATERIAL CHANGES Since the last annual update of our ADV Part 2A (“brochure”), dated March 30, 2024, Matter Family Office has made the following Material Changes. ITEM 4- Advisory Business On October 1, 2024, Matter accepted a minority investment from BW Forsyth Partners, a firm with a perpetual, long-term investment horizon and evergreen capital base. We believe this partnership will further strengthen our capabilities and enhance the value we provide. Forsyth’s investment strategy focuses on building great businesses through people and utilizes a combination of strategy deployment and a people-centric approach to culture and M&A. We expect that your day-to-day experience will remain unchanged. Our team is dedicated to serving your best interests and helping you navigate the complexities of family culture and wealth management with confidence and peace of mind. We are excited about the opportunities this partnership brings and look forward to sharing the benefits with you. Should you have any questions or require further information, please do not hesitate to reach out to your dedicated advisor team. Item 16 – Investment Discretion Matter Family Office now offers discretionary management of investment accounts. 2  ITEM 3 – TABLE OF CONTENTS ITEM 1 COVER PAGE ..................................................................................................................................... 1 ITEM 2 – MATERIAL CHANGES ...................................................................................................................... 2 ITEM 3 – TABLE OF CONTENTS...................................................................................................................... 3 ITEM 4 – ADVISORY BUSINESS ...................................................................................................................... 3 CLIENT ASSETS MANAGED BY MATTER FAMILY OFFICE ....................................................... 4 GENERAL DESCRIPTION OF PRIMARY ADVISORY SERVICES .................................................. 4 ITEM 5 – FEES AND COMPENSATION ............................................................................................................ 8 ASSETS UNDER MANAGEMENT AND FAMILY OFFICE SERVICES............................................ 8 ASSET CONSULTING GROUP, LLC ......................................................................................... 9 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 .................................... 10 USE OF PRIMARY METHOD OF ANALYSIS OR STRATEGY .................................................... 10 RISK OF LOSS ...................................................................................................................... 11 ITEM 9 – DISCIPLINARY INFORMATION ...................................................................................................... 12 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................... 12 ITEM 11 – CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS, AND PERSONAL TRADING .... 13 CODE OF ETHICS SUMMARY ............................................................................................... 13 AFFILIATE AND EMPLOYEE PERSONAL SECURITIES TRANSACTIONS DISCLOSURE ............. 14 PRIVATE INVESTMENTS ..................................................................................................... 14 ITEM 12 – BROKERAGE PRACTICES ............................................................................................................. 14 HANDLING OF TRADE ERRORS ............................................................................................ 16 BLOCK TRADING POLICY ..................................................................................................... 16 ITEM 13 – REVIEW OF ACCOUNTS .............................................................................................................. 16 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .................................................................... 17 ITEM 15 – CUSTODY .................................................................................................................................... 17 ITEM 16 – INVESTMENT DISCRETION ......................................................................................................... 18 ITEM 17 – VOTING CLIENT SECURITIES ....................................................................................................... 18 ITEM 18 – FINANCIAL INFORMATION ......................................................................................................... 19 ITEM 4 – ADVISORY BUSINESS 3  Matter LLC (“Matter Family Office”) is an investment advisor registered with the United States Securities and Exchange Commission (“SEC”) and is a Limited Liability Company formed under the laws of the State of Missouri. Matter Family Office was founded in 1990 and is owned entirely by current management, employees, or trusts controlled by employees, of the firm and as of October 1, 2024 a minority shareholder interest from a subsidiary of BW Forsyth Partners. Matter Holding Company, Inc., is the 100% owner of Matter Family Office. The Board of Managers consists of three legacy Matter employees and two Forysth designees. CLIENT ASSETS MANAGED BY MATTER FAMILY OFFICE As of December 31, 2024, Matter Family Office had direct management responsibility for $3,545,783,894 of our clients’ assets as defined by SEC requirements for inclusion. In addition, Matter Family Office considers our clients’ full net worth when developing plans and strategic recommendations, and typically reports on a fully consolidated basis. In that context, we advise on wealth in excess of $6 billion. The firm’s clients are all individuals or families; we manage no institutional funds. GENERAL DESCRIPTION OF PRIMARY ADVISORY SERVICES Matter Family Office provides fully integrated Investment Management, Wealth Planning and Coordination, and Culture and Learning services to support successful families across generations, defined as follows: Investment Management: Matter empowers families to invest with clarity and conviction. Our disciplined and transparent process draws upon: independent and proprietary research; integrated collaboration with your family and advisors; and solid investment insights from respected endowments, institutions, and single-family offices. Our philosophy helps drive this approach and is predicated on the following primary beliefs: Preserve & Protect: We place a higher priority on the preservation of capital rather than A Global View with Staying Power: Matter builds sophisticated portfolios designed to Respected Skills and Access: Our experience, scale, and independent approach provide Keep What You Get: Our exclusive focus on families ensures we balance tax and fee  on the achievement of “home run” returns that can create unintended and sizeable risk.  participate in global economic growth across all asset classes.  Matter access to today’s most respected investment managers and capital markets research.  sensitivity with the opportunity to compound performance over time. We support our families in the role of Chief Investment Officer to deliver our investment management advice. We are accountable to you for a process that creates a portfolio that is customized for your family. This involves a meaningful investment of time to ensure there is an alignment of constituents and objectives from the outset, the development of an investment portfolio that reflects this understanding, and a continual loop of communication and reporting to keep you fully informed. Generally, we focus on delivering the following specific investment services: Investment Strategy: Development of individual entity and group level investment policy  statements, and asset allocation analyses. This may include Monte Carlo simulations to provide 4  scenario analyses of different investment portfolio allocations to help families determine the most appropriate risk and return objectives that meet their needs. Asset Custody and Geography: We assist families with the selection of custody providers.  We have numerous custodians and brokers that feed into our reporting systems daily, so families do not need to be concerned with “moving” investment assets to a single platform. We also collaborate with you to ensure that your investment assets are held in the appropriate title or entity to ensure your overall wealth management and transfer objectives are met. Research: We conduct thorough research of capital markets and asset classes to identify  thematic opportunities to strategically and tactically allocate your investment assets. We provide ongoing communication of our research and findings to your family to ensure that you are fully informed on our views of your portfolio. Investment Manager Screening, Selection, Due Diligence, and Monitoring: We rely on an  open architecture approach to selecting investment solutions for your portfolio. Through a consulting relationship with Asset Consulting Group, LLC (“ACG”), a national investment consultant focusing on endowments and institutions, we provide our families with the benefit of ACG’s scale of more than $175 billion in investment assets under advisement and more than 25 research professionals. Performance Reporting/Analytics and Portfolio Accounting: We provide your families  with up-to-date and aggregated reporting on all your investment assets. This information is available to you at any time through our on-line portfolio which means you have the power to access information when it is convenient for you. Direct Private Investment Activities (Private Equity, Real Estate, etc.): Many of our  families are active in direct investing in other private businesses and real estate. Matter supports these efforts through detailed review, analysis, and assessment of the appropriateness of the investment relative to your investment objectives and needs. Wealth Planning and Coordination: Serving in a role analogous to that of a Chief Financial Officer, we support your family in the following areas depending on your family’s needs and complexities: Coordination of Administrative Activities  Cash management and money transfers  Development and oversight of family office internal controls (including existing family administrative personnel, outside accountants or vendors)  Oversight of bill pay activities, vendor selection, etc.  Annual planning and objective setting across disciplines (tax, estate, legal, accounting)  Evaluation and selection management of key advisors (CPAs, Attorneys, etc.)  Secure document storage and paper flow management (contracts, agreements, tax, and estate documents, etc.) Net Worth Reporting & Analysis  Preparation of consolidated balance sheets at family group and individual levels  Oversight and coordination of entity level accounting (trusts, foundations, direct investments, and operating businesses)  Cash flow and spending analysis  Custom reporting and analysis, as necessary Risk management and insurance adequacy assessment  Multi-Year Budgeting and Capital Sufficiency Planning & Analysis  Detailed scenario analysis of projected net worth, spending, and cash flow for family group and individuals  Budget setting and ongoing monitoring 5   Spending analysis  Project analysis – residential purchases, private aviation, direct investment activities  Coordination with family operating business executives to integrate budgeting, planning and analysis as it impacts the family Tax, Trust, Risk & Estate Coordination  Consolidation of tax documents and supporting information for annual tax preparation and compliance  Coordination of estate, wealth transfer, asset protection and risk management, and tax planning with family advisors and family operating business personnel, etc.  Processing of tax payments, including estimated payments  Administration and implementation of estate and tax planning decisions  Oversight of administrative and corporate trustee activities, including selection of third- party trust administration  Administration of charitable giving strategies and implementation, including oversight of foundation accounting and administration Family Culture & Learning: Families who are intentional about engaging all family members in the development of skills and communication around the responsibilities and opportunities that come with wealth significantly improve the odds of preserving their legacy across generations. Our approach to wealth management involves the integration of the technical aspects of a family office (investments and wealth planning & coordination) with an intensive focus on preparation and effective communication. Modern research has shown that failure of successful wealth transfer stems from poor communication and preparation within the family rather than mismanagement of the technical aspects. To help your family address these challenges, Matter provides the following services: Preparation: Preparing the rising generation for wealth is as critical as managing it. From quick tutorials to personalized discussions and materials for family members of all ages and abilities and financial skill levels, Matter helps each member of your family understand their wealth and build a solid foundation for informed decision-making together. Your Matter team members also build meaningful relationships with the young adults in your family to help prepare them for beneficiary, inheritance, and future trustee roles. Communication: Communicating effectively is the foundation of sustainable families. Matter guides your family through exercises that build good communication, promote collaboration and trust, and provide a firm foundation for effective goal setting, transition-planning, and decision- making. We help your family define the things that matter most, individually, and collectively, articulate shared values and the greater purpose of your wealth, and set goals and objectives for our work together. All this contributes to family meetings that are dynamic, purposeful, and foster multi- generational collaboration and input. Alignment: Aligning wealth plans with values and purpose increases impact. Your Matter advisors are your family’s thought partners as you navigate everything from investments and philanthropic activities to career plans. We help you see the breadth of your opportunities and create an integrated strategy that addresses the impact you want to have and the legacy you want to leave as a family. 6  Opt-in Services: Under separate agreement you can arrange for Matter to coordinate settlement of class action lawsuits electronically and hire Matter to perform bill payment services. MEETINGS AND COMMUNICATION We generally meet with you quarterly, but often more frequently as circumstances warrant. Our meetings with you are designed around executing an annual plan of objectives we create with you each year. This meeting cadence ensures the services we are providing you align with the needs of your family. Meeting agendas may include: review of your investment holdings and performance, assessment of your current estate plan with your advisors, tax planning with your CPAs, coordination of administrative activities to ensure your day-to-day wealth management needs are supported or planning for upcoming family meetings. The important point is that our meetings with you are “your” meetings and are used to provide you the opportunity to express the needs you have with respect to your wealth and family. We augment our time with you with technology platforms to provide you immediate access to your most important information such as estate documents, investment performance, etc. SPECIALIZATION Matter Family Office does not specialize in any particular type of advisory service, but prides itself on offering objective, independent advice on a range of financial issues. ADVICE LIMITED TO CERTAIN TYPES OF INVESTMENTS Fixed Income (Bonds) Large Cap Stocks Mid Cap Stocks Small Cap Stocks International Stocks Emerging Market Equity Equity Long/Short Covered Call Private Equity Master Limited Partnerships (MLPs) Real Estate Commodities Matter Family Office develops asset allocation models and provides investment management services, generally through funds with outside managers, across the following asset classes:             Individually held securities represent about 15% of our aggregate holdings and are typically related to clients’ legacy portfolio positions. Matter Family Office recommendations include both active and passive (index) managers. Matter Family Office’s primary focus is on wealth accumulation and protection, and on attempting to minimize volatility while maintaining competitive returns. ADVISORY SERVICES TAILORED TO INDIVIDUAL NEEDS OF CLIENTS Matter Family Office services are based on the individual needs of each client. Depending on the size and complexity of your family our scope of services may vary meaningfully. All engagements 7  are supported by a mutually agreed upon scope of services. We review our services with you on an annual basis to determine whether we would need to expand or contract our level of support depending on your needs. ITEM 5 – FEES AND COMPENSATION ASSETS UNDER MANAGEMENT AND FAMILY OFFICE SERVICES Typically, Family Office Services engagements are for a one-year period from the date of the agreement for services and automatically continue on a year-to-year basis. Either party may terminate the Family Office Services agreement upon 30 days’ prior notice to the other party. Fees for Family Office Services vary based on the complexity of the services to be provided and the size and complexity of the family. Additionally, the structure of the fees may vary based on the mix of services anticipated, client circumstances and preferences, and previous practices (long term clients). Matter typically receives fees in two ways: 1. A percentage of investment Assets under Management (AUM) to cover investment management services and basic wealth planning and coordination services. Fees generally range between .30 and 1.0% depending on size and complexity. Your contract with Matter will always detail your exact fee schedule, but our published fee schedule is: Amount of Assets under Management Annual Fee Rate $0 – $2,000,000.00 1.00% $2,000,000.01 – $5,000,000.00 0.70% $5,000,000.01 – $10,000,000.00 0.55% $10,000,000.01 – $25,000,000.00 0.45% $25,000,000.01 – $50,000,000.00 0.35% $50,000,000.01 & Greater 0.30%  This is a tiered fee schedule in which each tier of assets is charged a different rate under the annual Investment Management Fee schedule creating the effect of a blended fee rate used at the time of billing. Under this annual Investment Management Fee schedule, a blended rate is charged each billing period against all of the assets under management of Account.  The Investment Management fee is computed and is payable by Client on a quarterly basis in advance on the first business day of a quarter. The Investment Management fee is based on the market value of the Account on the last business day of the month that is two months prior to previous calendar quarter end. For example, for the quarter January 1, 2025 - March 31, 2025, the Investment Management fee will be based on the Account’s portfolio balance as of October 31, 2024.  For purposes of calculating Matter’s Investment Management fee, securities in the Account that are listed on a national securities exchange or on NASDAQ will be valued as determined by the qualified custodian(s) and reflected on the qualified custodian’s account statements provided by Client or made available by the qualified custodian. 8  Other securities or investments in the Account will be valued in a manner that Matter believes in good faith reflects the fair market value. Commented [EO1]: This is directly from the contract 2. A Family Office Fee retainer that covers complex wealth planning and coordination support and culture and legacy services. These fees are always custom and vary widely based on the size and complexity of the engagement and are discussed following a detailed assessment and agreement on a scope of services with your family. The annual Family Office Fee is divided by 4 and billed in quarterly installment payments which are due on the 1st day of each calendar quarter. In the event that services commence in the middle of a billing period (i.e., other than first business day of the calendar quarter), the Family Office Fee for the initial billing period will be prorated based on the number of days of service and billed in arrears at the same time as the next full billing period’s fee is billed. The annual Family Office Fee will increase automatically by 3% over the preceding annual Family Office Fee on January 1 following the execution date of this Agreement and each subsequent calendar year on January 1. Commented [EO2]: Copied directly from contract In connection with the implementation of your investment portfolio, you are provided the opportunity to designate a broker for the implementation of your investment transactions. If you do not designate a broker, then you will authorize us to select a broker on your behalf. You will be responsible for any brokerage charges in connection with any investment transactions. As a matter of practice, we ask our clients to appoint us as an agent and attorney-in-fact and to expressly authorize us to place, order, and direct investment transactions on behalf of the client. Your assets will be held at a third-party institutional custodian of your choice, or we will work with Schwab Institutional by default. Matter Family Office will normally provide consolidated investment reporting on a quarterly basis or as requested. ASSET CONSULTING GROUP, LLC Matter Family Office engages the services of Asset Consulting Group, LLC (ACG) for economic, market, and specific manager due diligence and modeling. ACG is an investment consulting firm focused on providing objective, sophisticated, detailed research, and investment advice to a select group of endowments, institutions, and large single-family offices. ACG was founded in 1989 and advises on more than $100 billion in client assets. We rely on ACG’s rigorous investment manager selection and evaluation process to ACG is a registered investment adviser that specializes in assisting pension, insurance,  and high net worth family office clients with a variety of investment consulting and money management needs. We use ACG’s in-depth capital market research, and proprietary economic and risk  management models to develop the customized investment allocations that are the basis of each client’s personal Investment Policy Statement.  identify the money managers to recommend for each sub-class of investment. ACG develops customized asset allocation models at the sub-class level, recommends  managers for each sub-class, and provides ongoing performance monitoring, review, and recommendations for rebalancing of model portfolios. Matter Family Office pays for ACG services directly; there is no additional charge to the client for the information ACG provides. 9  ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Matter Family Office does not charge or accept performance-based fees. Performance-based fees are fees based on a share of capital gains on or capital appreciation of the assets held within a client’s account. ITEM 7 – TYPES OF CLIENTS We provide services to high-net-worth families and non-high net worth individuals associated with those families. Matter Family Office does not serve institutional clients, except where an existing client has created a donor-advised fund or has gifted money to a non-profit organization or foundation. All clients are required to execute an agreement for services to establish a client arrangement with Matter Family Office. In the case where you have gifted money to a non-profit organization or foundation, if the account is in the name of the organization or foundation (e.g., an irrevocable gift), we require an advisory agreement with them directly, even though you may continue to oversee the administration of the account. MINIMUM INVESTMENT AMOUNTS REQUIRED Due to the multi-generational aspect of our families, our client portfolios vary in size. Our target minimum annual fee is $75,000. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS As stated previously, our investment philosophy is grounded in the endowment model of investment management. This philosophy prescribes an emphasis on diversification across asset class, geography, and investment style to provide a long-term return opportunity that is favorable relative to the portfolio’s implied risk. Our portfolio construction process starts with our firm’s investment committee and partnership with Asset Consulting Group (ACG). Together, we continually scrutinize capital markets research and global economic and investment data to develop a thematic foundation for our clients’ portfolios. These themes are designed to address the near term (3-5 year) opportunities and risks that we identify in the global investment landscape. To reflect these views, we first develop broad and then ultimately specific asset allocation and investment solutions to deploy capital in a manner consistent with our view of an optimal investment portfolio. Because our families have many different constraints, objectives, or points of view on investing, we customize portfolios to reflect both our firm view and your family’s specific circumstances. USE OF PRIMARY METHOD OF ANALYSIS OR STRATEGY As with any investment strategy, there are inherent risks. Matter Family Office’s primary strategy is to emphasize the reduction of volatility while maintaining competitive returns through adequate diversification across asset classes. 10  RISK OF LOSS Past performance is not indicative of future results. Therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. Clients and prospective clients should always be prepared to bear investment loss including loss of original principal. Because of the inherent risk of loss associated with investing, our firm is unable to represent, guarantee, or even imply that our services and methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. Additional risks associated when investing in securities include: Market Risk: Either the stock market as a whole, or the value of an individual company,  goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. Equity (stock) market risk: Common stocks are susceptible to general stock market  fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of their issuers change. Company Risk: When investing in stock positions, there is always a certain level of  company or industry specific risk that is inherent in each investment. This 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. Fixed Income Risk: When investing in bonds, there is the risk that 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. Options Risk: Options on securities may be subject to greater 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 you invest in an ETF or mutual fund, you will bear  additional expenses based on your pro rata share of the ETFs 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. In many cases, You will also incur brokerage costs when purchasing ETFs. Management Risk: Your investment 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. 11  ITEM 9 – DISCIPLINARY INFORMATION Matter Family Office is required to disclose all material facts regarding any legal or disciplinary events that may be material to your evaluation of us or the integrity of our management. Matter Family Office has no information applicable to this Item. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Matter Family Office is not and does not have a related company that is a (1) broker/dealer, municipal securities dealer, government securities dealer or broker, (2) other investment adviser or financial planner, (3) futures commission merchant, commodity pool operator, or commodity trading advisor, (4) banking or thrift institution, (5) accountant or accounting firm, (6) lawyer or law firm, (7) insurance company or agency, (8) pension consultant, (9) real estate broker or dealer, or (10) sponsor or syndicator of limited partnerships. Matter Family Office does have pooled investment vehicles that are related. Each of these LLCs and their conflictsis more fully disclosed below. Katherine B. Lintz and David M. Dankmyer, together as FMP Managing LLC serve as Managing Member for FMP Generation. Neither Matter Family Office nor any of its related persons are named as General Partner or have any controlling interest in any of the outside managed funds or LLCs that the LLCs listed below invest in. Matter Family Office does not receive any compensation from these LLCs other than an administrative fee for the LLC bookkeeping responsibilities. An independent auditor annually performs an annual audit of the LLC books. LLC Members may request a copy of the annual exam by contacting one of their Matter Family Office advisors. Copies of Operating Agreements of all LLCs are on file at Matter Family Office and available upon request.  FMP Generation, LLC: This entity was created to pool client funds to invest in Generation IM Global Equity Fund, LLC, an outside managed fund. The Managing Member of the LLC is FMP Managing, LLC and no one associated with Matter has any authority at Generation IM Global Equity Fund, LLC.  FMP Managing, LLC: A Missouri Limited Liability Company organized for the purpose of serving as the manager of FMP Generation, LLC. This LLC may act as manager for future Matter Family Office LLC's. Katherine B. Lintz and David Dankmyer are the Managing Members. Matter Sustainable: Matter Family Office advises the Matter Sustainable Fund, which is  managed by PPB Capital Partners (“PPB”). Matter and PPB are not affiliated.  Third-Party Money Managers: As described in Item 4 – Advisory Business and Item 5 – Fees and Compensation, Matter Family Office utilizes independent, third-party money managers to manage a majority of clients’ portfolios. As with any investment, clients always have the ability to approve or disapprove a particular manager, or to request a change of managers. 12  Matter Family Office recommendations are based on the research of its investment consulting firm, Asset Consulting Group, LLC, and its own Investment Committee vetting. When we recommend a money manager, it is because we believe they are the best choice for the particular asset class and the best fit for clients’ needs. Matter Family Office never receives a fee, commission, or any other compensatory consideration from any third-party managers. ITEM 11 – CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS, AND PERSONAL TRADING CODE OF ETHICS SUMMARY All investment advisers are required to establish, maintain, and enforce a Code of Ethics. Matter Family Office has established a Code of Ethics that applies to all its associated persons. As a fiduciary, it is Matter Family Office’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. This fiduciary duty is considered the core underlying principle for our Code of Ethics, which also covers our Insider Trading and Personal Securities Transactions Policies and Procedures. We require all our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and when changes occur, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Matter Family Office has the responsibility to make sure that the interests of all clients are placed ahead of the investment interests of Matter Family Office or its supervised persons. You will be provided with full disclosure of all material facts and potential conflicts of interest prior to any services being conducted. Matter Family Office and its supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if you wish to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. All partners, directors, consultants, and employees of Matter Family Office are bound by the following standards of behavior: 1. Act with honesty and integrity, including handling actual or apparent conflicts of interest between personal and professional relationships in an ethical manner; 2. File complete, accurate, timely, and understandable disclosure statements as required by applicable laws, rules, or policies; 3. Comply with all governing regulations and rules, including applicable federal or state laws and local ordinances, as well as applicable rules and policies of Matter Family Office; 4. Act in good faith, responsibly, and with due care, competence, and diligence, without misrepresenting material facts or allowing one’s independence of judgment to be subordinated; 13  5. Adhere to Matter Family Office investment policies, following investment committee direction, committing clients only to investments known and approved by the committee; 6. Share knowledge and maintain skills important and relevant to job requirements; 7. Respect the confidentiality of information acquired in the course of work and made confidential by law. AFFILIATE AND EMPLOYEE PERSONAL SECURITIES TRANSACTIONS DISCLOSURE Matter Family Office or its associated persons may not buy or sell for their personal accounts, investment products identical to those recommended to clients in any manner that creates a potential conflict of interest. It is the express policy of Matter Family Office that all persons associated in any manner with the firm must place the interests of our clients ahead of their own when implementing personal investments. Matter Family Office and its associated persons shall not buy or sell securities for their personal account(s) where their decision is derived, in whole or in part, by information obtained as a result of his/her employment unless the information is also available to the investing public upon reasonable inquiry. In order to minimize this conflict of interest, securities recommended by Matter Family Office are widely held and publicly traded and employee transactions are reviewed for asset classes in which a potential conflict or the appearance of a conflict could arise. PRIVATE INVESTMENTS Matter Family Office has recommended investments in several private investments. Some employees of the firm and their related parties have entered into partnership with clients to participate in the investment. There is no fee received or preferential treatment involved. The clients are aware of the principals’ participation. All transactions are reviewed annually by an independent Auditor in accordance with SEC Custody rules. ITEM 12 – BROKERAGE PRACTICES Matter Family Office has no soft dollar arrangements but may be granted access to third-party research at certain brokerage firms such as Schwab or Fidelity simply because you choose to custody your account there. Matter Family Office does not pay compensation for client referrals from any broker/dealer, or other third-party. Clients are under no obligation to act on the financial planning recommendations of Matter Family Office. If we assist or direct the implementation of any recommendations, it is our responsibility to ensure you receive the best execution possible. Matter Family Office allows you the opportunity to use the broker or dealer of your choice. We use our best efforts to ensure that reasonable commission rates are charged. Unless you indicate another preference, we will use Schwab Institutional for custody and brokerage services based on the excellent service and competitive rates we have experienced to date. For certain securities, we will test the market through its network of approved brokers for the best price, availability, and execution. Often Matter will receive research and relevant industry information at no charge from 14  the custodians we use. We do not participate in any process to direct transactions to a particular broker in return for products and/or research services received. Matter Family Office will often recommend that clients establish brokerage accounts with the Schwab Institutional division of Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker- dealer, Member SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. Although Matter Family Office will recommend that clients establish accounts at Schwab, it is the client’s decision to custody assets with Schwab. Matter Family Office is independently owned and operated and not affiliated with Schwab. Matter Family Office can recommend additional unaffiliated broker-dealers to effect fixed income transactions. Schwab provides Matter Family Office with access to its institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisors when a minimum of $10 million of their clients’ assets are custodied at Schwab Institutional. Schwab’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require significantly higher minimum initial investment. For Matter Family Office’s clients’ accounts maintained in custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab Institutional also makes available to Matter Family Office other products or services that benefit Matter Family Office but not directly benefit clients’ accounts. Many of these products and services can be used to service all or some substantial number of Matter Family Office accounts, including accounts not maintained by Schwab. Schwab’s products and services that assist Matter Family Office in managing and administering clients’ accounts include software and other technology that (i) provides access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of Matter Family Office’s fees from some of its accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Schwab Institutional also offers other services intended to help Matter Family Office manage and further develop its business enterprise. These services include: (i) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers; human capital consultants and insurance providers. Schwab Institutional will discount or waive fees it would otherwise charge for some of these services or pay all or part of the fees of a third-party providing these services to Matter Family Office. Schwab Institutional can also provide other benefits such as educational events or occasional business entertainment for Matter Family Office personnel. While as a fiduciary, Matter Family Office endeavors to act in its clients’ best interests, Matter Family Office’s recommendation that clients maintain their assets in accounts at Schwab may result in receipt of some of the foregoing products and services and other arrangements not solely on the nature 15  of cost or quality of custody and brokerage services provided by Schwab, which is a conflict of interest. HANDLING OF TRADE ERRORS Matter Family Office has implemented procedures designed to prevent trade errors; however, trade errors cannot always be avoided. Consistent with our fiduciary duty, it is the policy of Matter Family Office to correct trade errors in a manner that is in your best interest. In cases where you cause the trade error, then you will be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, you may not be able to receive any gains generated as a result of the error correction. In all situations where you do not cause the trade error, you will be made whole and any loss resulting from the trade error will be absorbed by Matter Family Office if the error was caused by the firm. If the error is caused by the broker- dealer, the broker-dealer will be responsible for covering all trade error costs. If an investment gain results from the correcting trade, the gain will remain in the client’s account unless the same error involved other client account(s) that should also receive the gains and it is not permissible for all clients to retain the gain. Matter Family Office may also confer with clients to determine if the client should forego the gain (e.g., due to tax reasons). Matter Family Office will never benefit or profit from trade errors. BLOCK TRADING POLICY Transactions implemented by Matter Family Office for your accounts are generally affected independently unless the firm is purchasing or selling the same securities for several clients at the same time. This process is referred to as aggregating orders, batch trading, or block trading and is used by the firm when such action may prove advantageous or neutral to you. When Matter Family Office aggregates client orders, the allocation of securities among client accounts will be done on a fair and equitable basis. Typically, the process of aggregating client orders is done to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among the firm’s clients in proportion to the purchase and sale orders placed for each client account on any given day. When Matter Family Office determines to aggregate client orders for the purchase or sale of securities, including securities in which Matter Family Office may invest, the firm will do so in accordance with the parameters set forth in the SEC No-Action Letter, SMC Capital, Inc. It should be noted; Matter Family Office does not receive any additional compensation or remuneration because of aggregation. ITEM 13 – REVIEW OF ACCOUNTS ACCOUNT REVIEWS AND REVIEWERS Matter Family Office assigns each client a service team, generally consisting of a Partner, a Director, Financial Consultant, Client Service Consultant, and Analyst. While formal reviews may be conducted by the team in preparation for quarterly or semi-annual meetings, the team, or individual members of the team, may also conduct informal account reviews periodically in 16  response to economic changes, market events, or a change in your individual circumstances. The level of review depends on what prompted the action, your situation, and the type and size of the investment portfolio. STATEMENTS AND REPORTS Commented [EO3]: Re-word? Ask WP& C later A detailed written plan tailored to your needs is developed after meetings and conversations with you. This plan is updated and reviewed as needed and comprehensive performance reports are produced for you. You also receive periodic summaries of investments as requested. In most instances, statements, reports, summaries of investments and other materials specific to our relationship with you are provided via a secure portal which you access directly. Commented [EO4]: Review with Lisa ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Matter Family Office does not directly or indirectly compensate any person outside of Matter for client referrals. Beginning in 2023 Matter employees only may be paid a fee for referring clients to Matter. Regardless, the only forms of compensation received from or for advisory services are the fees charged for providing investment advisory services as described at Item 5 of this brochure. Matter Family Office receives no other forms of compensation in connection with providing investment advice. From time to time, we provide educational workshops and seminars. Topics are typically general in nature but may cover a wide array of financial planning, educational, charitable, family governance, and investment related topics. We generally do not charge a fee to attend, but for some events may charge a nominal fee per attendee to pay for additional or extra expenses unique to the particular event. ITEM 15 – CUSTODY Custody, as it applies to investment advisors, has been defined by regulators as having access or control over client funds and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment advisor has the ability to access or control client funds or securities, the investment advisor is deemed to have custody and must ensure proper procedures are implemented. Matter Family Office is deemed to have custody of client funds and securities whenever Matter Family Office is given the authority to have fees deducted directly from client accounts. Additionally, Matter Family Office has custody of client funds and securities for any clients who have appointed Matter Family Office to act as the client’s agent and attorney-in-fact. If the appointment as agent and attorney-in-fact is limited to trading, then that will not be considered custody. Authorization to trade in client accounts is not deemed by regulators to be custody. Matter may be deemed to have custody for some clients with whom we enter a “bill pay” arrangement. As mentioned above, custody occurs should Matter have access or control over client funds and/or securities, in which case Matter will follow SEC required procedures to ensure these accounts are verified by an external auditor. There are pooled fund LLCs established by Matter Family Office to take advantage of various alternative investment opportunities. Since the general manager of the underlying investment is not a “Qualified Custodian” and does not provide audited statements to each of Matter Family Office’s clients invested in the LLC, Matter Family Office is required by SEC rules to have an annual audit conducted by an independent Auditor. The results of that audit are available to Matter Family 17  Office clients, and members of the LLCs. For accounts in which Matter Family Office is deemed to have custody that are accounts other than the pooled fund LLCs established by Matter Family Office to take advantage of various alternative investment opportunities, the firm has established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the way the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. Clients should carefully review those statements and are urged to compare the statements against reports received from Matter Family Office. When clients have questions about their account statements, they should contact Matter Family Office or the qualified custodian preparing the statement. ITEM 16 – INVESTMENT DISCRETION Matter Family Office offers three levels of Investment Discretion: 1. No discretion: When Matter has no discretionary authority on an investment account, the account owner or authorized agent will be contacted regarding all transactions and asked to approve the details of the recommendation: whether to buy or sell and the number of shares, units or dollar amount. With that approval, Matter Family Office will be responsible for making decisions regarding the timing of buying or selling an investment and the price at which the investment is bought or sold. Trades may or may not occur immediately, as sometimes approval is obtained prior to a particular target price being achieved, an anticipated corporate action takes place, or some other event occurs. At the same time, you need to be aware that if you are not able to be reached or are slow to respond to our request, it can have an adverse impact on the timing of trade implementations, and we may not achieve the optimal trading price. 2. Limited or partial discretion: Clients may grant Matter discretion over cash and cash equivalents only. 3. Full discretion: Client grants Matter discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for their investment account(s) in the sole discretion of Matter without first consulting with Client. Client also grants Matter the power and authority to carry out these decisions by giving instructions, on behalf of Client, to brokers and dealers and the qualified custodian(s) of the Account. Client authorizes Matter to provide a copy of this Agreement to the qualified custodian or any broker or dealer, through which transactions will be implemented on behalf of Client, as evidence of Matter’s authority under this Agreement. ITEM 17 – VOTING CLIENT SECURITIES For client accounts in which Matter Family Office has proxy voting authority, the voting procedures are one of the following: 18  1. We have engaged the services of Broadridge Investor Communication Solutions Inc. to provide an internet-based proxy voting platform. We have established voting guidelines to assure client proxies are voted properly. Client and employee proxies are voted based on the same guidelines to avoid any conflict of interest. Should you desire to direct a forthcoming vote, or want information as to how Matter has voted for you in the past, the Compliance Department at Matter can make this available to you via your service team OR 2. If your account is not eligible for proxy voting services from Broadridge Investor Communication Solution Inc., you should receive your proxies directly from your custodian or potentially a transfer agent. The Proxy Committee will determine how we should vote your proxies in accordance with applicable voting guidelines, and we will complete and vote the proxy on your behalf. Clients can request a copy of our Proxy Policy from any service team member. ITEM 18 – FINANCIAL INFORMATION We do not require or solicit prepayment of client fees, six months or more in advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. Finally, we have never been the subject of a bankruptcy petition. 19