Raymond James Financial Services Advisors, Inc.

About Us Raymond James Financial Services Advisors, Inc. (“RJFSA”) is a wholly owned subsidiary of Raymond James Financial, Inc. (“RJF”), a publicly held company based in Saint Petersburg, Florida. RJFSA has been, and is currently, registered with the Securities and Exchange Commission (“SEC”) as an investment adviser since December 2008 and has provided advisory services since January 1, 2009. Registration as an investment adviser with the SEC does not imply a certain level of skill or training. RJFSA is also affiliated with Raymond James Financial Services, Inc. (“RJFS”), an introducing broker. RJFS is a registered broker-dealer, member FINRA and is a wholly owned subsidiary of RJF. IARs of RJFSA may also be registered with RJFS as registered representatives and therefore have the capacity to offer you certain broker-dealer related services that are not available through RJFSA. RJFS, as introducing broker, for the Ambassador Program accounts and the Outside Manager Platform (“OSM Platform”) accounts, where applicable, facilitates the maintenance of custody of securities positions for your account through our affiliate, Raymond James & Associates, Inc. (“RJA”), including holding securities in nominee name and crediting interest and dividends received on those securities to your account and facilitating the clearing of securities transactions through RJA. Information about these and other material affiliations is further described in the “Other Financial Industry Activities and Affiliations” section. As mentioned above, our affiliate, RJA, generally, acts as the custodian and clearing agent to client accounts introduced by us and facilitates various advisory programs through Asset Management Services (“AMS”), a division of RJA. In the Ambassador and OSM Platform accounts, which are sponsored by RJFSA, AMS establishes custodial facilities, provides clients with accounting and other administrative services, and assists OSM Managers with certain trading management activities. RJFSA investment advisor representatives (“IARs”) may also offer to you other wrap fee programs that are sponsored by RJA. These programs will be discussed in detail in the RJA Part 2A of Form ADV, Appendix 1 (“RJA Wrap Fee Program Brochure”). AMS through its Investment Committee, as described in the RJA Wrap Fee Program Brochure, also provides portfolio management services to several of the wrap fee programs available to you though your RJFSA IAR. RJA is compensated for these services by receiving a portion of the advisory fee you have agreed to pay as outlined in your account agreement. In partnership with you, your IAR assesses your investment objectives based on the information you provide initially, and on an ongoing basis, to determine which advisory programs, if any, are appropriate to recommend to you. We tailor our advisory services to your individual needs including your financial situation, needs, and objectives, and encourage you to inform your IAR as changes in your financial and personal circumstances occur so that they can provide you with appropriate advice. RJFSA IARs and branch offices may use marketing or other branch names that are held out to the public. The purpose of using a branding or marketing name is for the IAR to create a brand that is specific to the individual IAR and/or branch. Branch office owners in many cases will establish and maintain an outside entity, such as a limited liability corporation, to pay for office and other business-related expenses. On a limited basis, there are third parties that maintain an ownership interest in the branch owner’s outside entity. Should an arrangement like this exist, the branch office will make separate disclosure to you of such arrangement and any potential conflicts. RJFS and/or RJFSA, through networking agreements, maintain branch offices within various financial institution locations, such as banks, federal savings associations, and credit unions, through its Financial Institutions Division (“FID”). In many cases, your IAR is also a registered representative of RJFS and also provides services as an employee or independent contractor of the financial institution with which RJFSA is not affiliated. Your IAR’s compensation related to the advisory services they provide to you may be dependent on the type of networking arrangement that is in place between RJFS and/or RJFSA and the unaffiliated financial institution. Please see the Networking Arrangements with Financial Institutions section under Item 14 – Payment for Client Referrals below for more information. Our IARs offering advisory services are required to provide you with a current Form ADV Part 2B (“Brochure Supplement”), which includes information regarding the IAR’s education, business experience, disciplinary information, other business activities, additional compensation, and supervision. You may also obtain additional information regarding your IAR, such as licenses, employment history, their regulatory disciplinary information (if any), and whether he or she has received reportable complaints from investors from the SEC at https://www.raymondjames.com/legal-disclosures. Should you have any concerns regarding any of the information contained in your IAR’s Brochure Supplement, you are encouraged to contact our Advisory Compliance Department at 800-2488863, extension 75877. As used in this Brochure, the words “we,” “our,” “our firm,” “the Firm,” “RJFSA,” and “us” refer to RJFSA and your Investment Adviser Representative (“IAR”), and the words “you,” “your,” and “client” refer to you as either a client or prospective client of our firm.

Assets Under Management As of September 30, 2025, we had $390.043 billion in assets under management, $171.744 billion of which was managed on a discretionary basis and $218.299 billion of which was managed on a non-discretionary basis.

Types of Services RJFSA offers advisory programs sponsored by its affiliate RJA (“AMS Managed Programs”) and other advisory services which are not described in this Brochure. Depending on the services your financial advisor provides and/or the type of services or program(s) you select, you will be provided a copy of the appropriate brochure related to such advisory program. As described below, these

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brochures provide detailed information, disclosures, and potential conflicts of interest related to other advisory services, outside of our wrap fee programs, that we may provide you.

RJFSA Form ADV Part 2A – We offer financial planning and/or investment consulting services to our clients through our Wealth Advisory Services Program. Detailed information about these advisory programs and other services offered through RJFSA are available in the RJFSA Form ADV Part 2A Brochure. A copy is available, upon request, from your IAR or you may visit our public website: https://www.raymondjames.com/legal-disclosures.

RJA Form ADV 2A Appendix 1 (Wrap Fee Brochure) – Your IAR can provide certain advisory programs made available through Asset Management Services (“AMS”), a division of our affiliate RJA. Detailed information about these advisory programs offered through RJA are available in the RJA Wrap Fee Brochure. A copy is available, upon request, from your IAR or you may visit our public website: https://www.raymondjames.com/legal-disclosures.

Institutional Fiduciary Solutions (“IFS”) Form ADV Part 2A – Your IAR can offer advisory consulting services to institutional and qualified retirement plans, including program support, investment education and guidance, if selected by a client. IFS, a division of RJA, supports and maintains oversight over these activities. Details of the services provided by IFS are available in IFS Form ADV Part 2A Brochure. A copy is available, upon request, from your IAR or you may visit our public website: https://www.raymondjames.com/legal-disclosures.

Note for Non-U.S. Persons: RJFSA and RJA are U.S.-based, SEC-registered investment advisers. We do not provide products and services in or into all countries. The products and services that we can offer or provide to you, and how we interact with you, may be limited based upon where you reside or are physically located, or other jurisdictional connections related to your account (for example, country of formation and countries in which authorized persons or beneficial owners reside, in the case of an account for a legal entity). We may limit products and services, decline to open an account, and/or close an existing account based upon such jurisdictional connections.

Wrap Fee Sponsored Programs Offered The RJFSA sponsored-wrap fee programs described in this Brochure are programs in which you pay a single bundled or “wrap” asset-based fee for both advisory and brokerage services. This fee generally includes compensation paid to us and your IAR for providing advisory services under the program, RJFS as introducing broker, and to RJA as clearing broker and custodian, for its execution, clearing, custodial, and other administrative services. Advisory services within a wrap fee program may include portfolio management or advice concerning the selection of other investment advisers. Generally, securities transactions in our wrap fee programs are effected “net” (i.e., without commission), and a portion of the wrap fee is generally considered to be inclusive of commissions charges. For details on the fees you will pay under our wrap fee programs including additional expenses that can be incurred outside of the wrap fee, please refer to the “Additional Expenses” section and our fee schedules in the “Maximum Fee Schedule for the Ambassador Account Programs and OSM Dual Contract Platform” section. RJA provides support and administrative services for clients and IARs through the Ambassador Program, such as establishing custodial facilities, initiating and/or adjusting pre-existing periodic investment and disbursement/payment plans, cash disbursements, account inquiry services, billing and payment remittance support, sales and trading support, educational opportunities, and training to IARs and other account maintenance services. Unless you have requested and completed account documentation related to setting up solely a “delivery versus payment” or DVP arrangement for your Advisory Program (where your assets are held with a third-party, unaffiliated custodian), RJA or its affiliated custodian will custody advisory account assets. Maintaining custody of account assets includes holding securities in nominee name and crediting interest and dividends received by RJA to the account for securities held in the account. As custodian, RJA’s administrative services include, at least quarterly, producing a statement for you detailing Securities held in your advisory account; gains or losses; transactions; and receipt and disbursements of funds, interest, and dividends. For individual Retirement Custodial Accounts (IRAs), Raymond James Trust Company of New Hampshire is custodian and RJA is sub-custodian. RJA also provides execution and clearing services for accounts carried and/or custodied at Raymond James. In the Ambassador Program, RJFSA and your IAR provide advisory services, and your IAR advises you in either a discretionary or non-discretionary capacity on your account assets (“IAR Managed Program”). In a discretionary account, you delegate to your investment adviser the authority to decide what securities to buy or sell for your account. In a non-discretionary account, your investment adviser will provide you with advice in the form of recommendations but the decision to buy or sell securities is made by you. Your delegation of investment discretion to RJFSA will generally result in securities and other investment prospectuses (and other associated regulatory mailings) being available to RJFSA as the client for investment purposes. We will make these materials available to you upon request. RJFSA also offers the OSM Manager platform, through AMS, in which you enter into a separate contract with an outside manager. Each dual contract platform provides a discretionary manager with the OSM Manager exercising discretionary authority as described below. The chart below provides an overview of the advisory wrap fee program and dual contract platform we offer.

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Chart – Overview of Our Advisory Programs Advisory Programs

Outside Manager

Investment Adviser(s)

Type of Program

IAR and OSM

Dual Contract SMA Platform

Discretionary Authority Maintained By

OSM Manager

Use of Affiliated Subadvisors and/or Mutual Funds

Maximum Advisory Fee1

No

Refer to the 2.25% OSM RJFSA fee + Manager’s OSM Form ADV Part Manager Fee 2A

Investment Products/ Discipline

Investment Minimum2 $100K $200K (minimums vary by OSM Manager)

Margin trading available

No4

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Types of Clients We provide advisory account Programs, a dual contract platform and advisory services to a broad range of current and prospective clients, including individuals, IRAs, banks and thrift institutions, trusts, estates, charitable organizations, state and municipal government entities, pension, and profit-sharing plans, including plans subject to ERISA, investment advisers, corporations, and other business entities. Please note that if providing advisory services to an ERISA retirement plan in an AMS program, RJA and your financial advisor are not acting as the “Named Fiduciary” as defined under section 402 of the Employee Retirement Income Security Act of 1974 as amended (“ERISA”). In addition, AMS is not the third-party administrator or recordkeeper as defined by ERISA for any ERISA accounts in AMS programs. Applicable requirements for opening or maintaining an account with us are discussed in this section. Account minimums for each Program and Dual Contract Platform are disclosed in the “Overview of our Advisory Programs” chart under Item 4, above.

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Opening an Account: Account Funding and Documentation Requirements For those advisory services described in this Brochure, you will execute a program agreement(s) for the selected program(s), and/or you will execute a Master Advisory Agreement (collectively, “advisory agreement”), the terms of which will apply to each of your advisory accounts. For accounts custodied at Raymond James, your advisory agreement supplements your Master Client Agreement or other account opening documentation, which is used to establish an account at Raymond James. The terms and conditions described in the Master Advisory Agreement, once executed by you, govern all of your advisory account(s) in the programs described in this Brochure, including existing advisory accounts previously opened under a program agreement, and any advisory account you may open now or in the future. Following inception of your advisory account(s), you will promptly receive a written confirmation detailing your advisory account details and features in the form of an Advisory Feature Summary, and additional Program-specific information in the form of a Program Supplement and Account Feature Summary corresponding to each applicable advisory account Program, which is incorporated into and a part of the Master Advisory Agreement as of the opening of the respective advisory account Program. The Master Advisory Agreement is based on beneficial ownership; an additional Master Advisory Agreement will not need to be signed unless the beneficial ownership of the accounts in the request are different. An account in one of our wrap fee Programs is not considered to be effective pursuant to your respective advisory agreement(s) which could include the Master Advisory Agreement until it has been funded, all required account opening paperwork and/or documentation is submitted and accepted by us, and deemed to be in good order. For example, AMS will not generally consider an account (or the advisory agreement to be effective) until all reasonable and necessary account documentation has been submitted and processed by AMS and/or another functional area of our Firm, even though the account has otherwise been fully funded and a client-signed advisory agreement(s) or Master Advisory Agreement has been submitted or is on file, respectively. This would include accounts where necessary items such as a corporate resolution or IRA application are missing. If you have chosen to submit periodic deposits to be allocated to your account, the account investment minimum must be met at account inception. Subsequent periodic investments need to meet the periodic investment minimum dollar amount, which is $500 per investment period for American Funds and certain Freedom strategies and $1,000 per investment period required for other AMS Managed Accounts. Annual contribution limits for RJ Custodial tax qualified accounts apply. Quarterly periodic deposits are available in March, June, September & December; semi-annual periodic deposits are available in June and December. Periodic deposits may only be initiated on the 7th or 21st day of the month.

OSM Platform Accounts Funded with Securities and Other Investments: Keep/Sell Process Any securities and other investments used to fund a managed or discretionary account, or that are later deposited into the managed or discretionary account may be sold. Redemption charges and capital gains or losses depending on your cost basis in the securities and other investments may occur. You should consult your tax advisor for advice on the tax implications of those transactions. For OSM Platform accounts funded with securities and other investments, generally, the OSM Manager will determine if any of the securities and other securities will be kept or sold (“keep/sell process”). This assessment may require coordination with the OSM Manager, where applicable. This process may take several business days, based on the number of strategies and/or OSM Managers being used and the type of securities and other investments being reviewed. You should further understand that securities awaiting the keep/sell determination are not being actively managed, nor is a Fee being assessed on these securities. Occasionally, and under limited conditions, we may agree to manage an account where managed assets are held in a custodial account which also holds non-managed assets for which a readily available secondary market exists. You must obtain advance approval for this arrangement. You should also understand that we have no authority or responsibility regarding the investment, disposition, and monitoring of non-managed assets. Losses sustained in connection with the investment or disposition of non-managed assets are your sole responsibility. Per your advisory agreement(s) which could include the Master Advisory Agreement, you authorize us to liquidate the securities and other investments in your account and use the proceeds to fund an OSM Platform account, if funded with securities and other investments, if applicable. You should provide a statement of the cost basis of the securities to us so that we can provide accurate gain/loss information. AMS will typically liquidate the securities and other securities as soon as is practicably possible. The portfolio construction/deconstruction process may require several business days based on the time of day of AMS’s receipt of the instructions, the type of securities and other investments being reviewed and/or sold, and prevailing market conditions. The Manager and/or our Firm generally liquidate legacy securities and other investments immediately in the following instances: 1) when legacy securities and other investments are used to fund new, or are contributed to existing, OSM Platform accounts, 2) in connection with investment discipline changes, and 3) when you provide instructions to terminate and liquidate your OSM Platform account. AMS may coordinate these liquidations with the OSM Manager, where applicable, to limit the potential for price concessions, which may be more prevalent in debt securities traded in dealer markets. Depending on the size and characteristics of the legacy position(s) and prevailing market conditions at the time of sale, among other potential factors, certain liquidations may be delayed (and therefore, initial investing may be delayed) which may cause you to receive a buy/sale price that is less favorable than if the transaction involved a more marketable or liquid position. However, there is no assurance that we or the OSM Manager will be able to liquidate legacy securities and other investments due to a number of factors, including, but not limited to, the lot size of the legacy position (number of bonds), lack of willing buyers in the market, and a concession necessary to effect the sale transaction resulting in the bid price falling outside of the market range, among others. In these circumstances, you will be notified that the security must be held in a non-managed account in your name for you to sell at a later date.

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In those cases where the existing funding assets to be liquidated are the same holdings as currently in the model, strategy or discipline, AMS and/or the OSM Manager may retain all or a portion of like securities and other investments or purchase more positions in the same security in accordance with the OSM Manager’s investment strategy and in accordance with your investment objectives. For example, if you hold an existing position in a Fund that is currently held in your selected model, strategy, or discipline, AMS will assess whether to retain and/or liquidate a portion of the existing account to align with the overall objectives of the Fund strategy. Securities and other investments used to fund a managed account are transferred to the AMS Managed account team for liquidation to avoid you being assessed commissions on those liquidations. Loaded mutual funds purchased at RJA and transferred to an advisory account will be converted to an institutional share and excluded from fee billing. Refer to the “Non-Billable Assets” section for more information. Contributions are treated in the same manner as newly funded accounts.

Disbursement/Withdrawal Requests You may withdraw cash or securities from your advisory account upon providing verbal or written notice to us, subject to verification. Withdrawals will be taken from cash balances if cash is available. All efforts are made by AMS to process withdrawal requests in an efficient and timely manner. Investors in taxable accounts may supply us with standing instructions to send accrued income to another like-registered RJFSA account or have a check mailed to the address of record. This standing instruction option is not available for tax-qualified retirement accounts. However, both taxable accounts and tax-qualified retirement accounts may distribute the income periodically via ACH to an external financial institution. All necessary ACH, distribution paperwork and requirements apply. When cash is depleted, your AMS Managed Program advisory account is re-balanced to the target allocation. Trades resulting from the withdrawal request or rebalancing, if any, are executed at market prices. Neither RJFSA nor RJA is responsible for changes in market prices that occur between its receipt of a request to withdraw cash and trade execution. Withdrawals (periodic or otherwise) requiring a liquidation of securities and other investments affects the asset allocation and the performance, of your advisory account. You authorize us to effect withdrawals from your advisory account pursuant to your request and on your behalf, except that any withdrawal requests you submit may not reduce your account balance below the account minimum. If you withdraw assets from your advisory account prior to delivering proper notice to us, neither we nor RJA will be responsible, nor liable to you, for losses to the advisory account which may result from the need to reverse transactions in the advisory account for which those assets were to be used but were not available. The advisory account is not intended as a short-term investment vehicle. Withdrawals from your advisory account may impair the achievement of your stated investment objectives. OSM Managers are not authorized to withdraw any money (other than Fees payable by you), or securities or other investments from your advisory account, except for settlement of securities or other investments transactions, and unless otherwise permitted under your advisory agreement(s) which may include the Master Advisory Agreement or with your authorization.

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In the AMS Managed Programs described in this Brochure, your relationship is with your IAR and not directly with any of the Managers. However, if you are using the OSM Platform, you will have a separate contract directly with the OSM Manager. Please refer to your agreement with the OSM Manager or their Form ADV Part 2A for additional details about any restrictions they may place upon you for contacting and consulting with Managers. Client contact with the OSM Manager generally occurs through your IAR and/or AMS.

Your IAR collects the following information from you: name, social security/tax identification number, address, phone number, employer, occupation, date of birth, number of dependents, net worth, annual income, investment experience, retirement status, investment objective, risk tolerance, time horizon, investment restrictions and other written instructions relating to the management of

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your account. On behalf of your IAR, the Firm will share this information with your OSM Manager, where applicable so they can appropriately implement your selected investment strategy. On a quarterly basis, we will remind you in your statement to inform your IAR of any changes in your investment goals and financial situation or if you wish to impose or modify existing investment restrictions in your account. We also encourage you to review your investments with your IAR on, at least, an annual basis. In turn, we also share material changes you report to us with the Manager, where applicable.

Initial and Ongoing Review and Selection of OSM Managers OSM is a dual contract program and OSM Managers are available on the platform generally as an accommodation for pre-existing relationships that a financial advisor or client already has established prior to joining Raymond James. Therefore, while AMS will not accept all potential managers as OSM Managers, the review AMS conducts on OSM Managers is limited. Initially and periodically thereafter, AMS reviews the OSM Manager primarily focusing on strategy performance in comparison to a relevant peer group or benchmark. The periodic review is not as comprehensive as the Manager Research and Due Diligence reviews performed on certain other Managers available in the single contract programs sponsored and offered through our affiliate RJA. Please refer to the RJA Wrap Fee Program Brochure for more information, which is available, upon request, from your IAR or you may visit our public website: https://www.raymondjames.com/legal-disclosures.

IARs as Portfolio Managers When you have an IAR Discretionary Ambassador program account, your IAR has met certain criteria required by Raymond James to exercise that discretionary authority over your account. We have established guidelines for your IAR to manage a discretionary account which generally include, but are not limited to, the following:

Appropriately registered as an IAR; Five years of experience in the securities industry; Certain minimum commissions/fees earned and client assets under management in the prior twelve months; No significant customer complaints or disciplinary action against the IAR; and Additional compliance and investment management training may be required. Certain relevant industry professional designations may be applicable.

We retain the right to determine IAR qualifications for managing discretionary accounts, regardless of whether they meet all of these guidelines and also reserve the right not to offer the accounts through IARs that otherwise meet these guidelines. For more information about the conflicts of interest associated with your IAR providing advisory services and how we address those conflicts, please refer to the “IAR Compensation” section. Your IAR is subject to ongoing reviews to maintain his or her eligibility to continue offering discretionary management services to you in the Ambassador Program. These reviews, include, but are not limited to, the following:

Adherence to product guidelines Completion of applicable continuing education requirements Advisor business mix, including number of accounts and/or assets in discretion Disclosures provided on CRD report (i.e., disciplinary actions, complaints, outside business activities, etc.) Prior trading activity

For more information on conflicts of interest associated with your IAR providing advisory services and how we address those conflicts, please refer to the “IAR Compensation” section. Additionally, your IAR is assigned to a supervisor who is responsible for ongoing supervision of his or her investment advisory activities on our behalf.

Review of Performance Information For information on account reviews performed by firm personnel, please refer to the “Review of Accounts” section.

Affiliated Managers and Funds The Carillon Family of Funds and Carillon Tower Advisors (“CTA”) proprietary ETFs (collectively, “RJA-affiliated funds”) are managed by Managers affiliated with RJFSA through our parent company, RJF, as further described in this section and, therefore, are also considered RJFSA-affiliated funds. Raymond James Investment Management serves as the investment adviser to RJA-affiliated funds and Raymond James Investment Management subsidiary investment advisers, Eagle, Cougar, ClariVest, Scout Investments, Inc. (“Scout”), who also does business as Reams Asset Management (“Reams”), and Chartwell Investment Partners (“Chartwell”), act as subadvisers as applicable (see each fund’s prospectus for details). RJFSA’s affiliate, RJA, includes RJA-affiliated funds in certain of the AMS Managed Programs offered by RJA. Please refer to RJA’s Wrap Fee Program Brochure for additional information on use of affiliated Managers and funds in AMS Managed Programs. Further, because RJA-affiliated funds (as described above) are also generally available for investment, such affiliated funds can also be recommended to you or selected by your IAR in non-retirement Ambassador Non-Discretionary and Discretionary Program accounts, respectively. RJA-affiliated funds are also permitted to be purchased and held in non-retirement Freedom and Portfolio Select UMA accounts and in each case are treated as billable positions. Retirement accounts will not be permitted to invest in RJFSARaymond James Financial Services Advisors, Inc. (“RJFSA”) Wrap Fee Program Brochure

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affiliated funds, as federal regulations prohibit affiliated mutual funds from being purchased in advisory retirement accounts. While RJA-affiliated funds are not permitted to be purchased in Retirement Accounts, if held in such an advisory account (e.g., purchased when the account was a brokerage account or not a retirement account), no advisory fee will be charged on such assets (however, for accounts established through the RCS Division, an advisory fee will be assessed). Raymond James Investment Management and its affiliated Managers receive compensation from RJA-affiliated funds in the form of management fees, which are paid by investors in these funds. RJFSA does not receive additional compensation for investing in the strategies of an affiliated fund over a non-affiliated fund other than that described in each Program description of our “Overview of our Advisory Programs”, “Compensation,” “Education & Marketing Support Fees,” and “Intercompany Payments Between Affiliates” sections. For more information about compensation earned by affiliated managers in RJA’s wrap fee programs, please refer to the RJA Wrap Fee Program Brochure. A copy is available, upon request, from your IAR or you may visit our public website: https://www.raymondjames.com/legal-disclosures. However, if advice is implemented through us on behalf of these affiliates, we and our affiliates receive additional compensation as previously described and this compensation contributes to the overall profitability of our holding company, RJF. Please also refer to the “Other Financial Industry Activities and Affiliations” section for more information about our material business relationships. Certain securities and other investments may be subject to trading or hold restrictions or may be excluded from fee billing in the Ambassador Program, depending on the account type. RJF stock, bonds, or options (“RJF securities”) may be permitted to be purchased and held in Ambassador advisory accounts but will be considered ineligible for advisory fees due to the IAR’s affiliation with RJF and, potentially, the IAR’s personal holdings of RJF securities. This may create a disincentive for the IAR to recommend to a client a purchase of RJF securities or that existing RJF securities continue to be held. Managers in the OSM Platform may invest client assets in RJF securities which are eligible for billing.

Imposing Client Restrictions on Certain Securities or Types of Securities or Other Investments Pursuant to Rule 3a-4 under the Investment Company Act of 1940, we provide quarterly notification in account statements to clients who have delegated investment discretion to us or an investment Manager within our managed account programs, as applicable. You may request that we or the Manager, as applicable, sell, or avoid selling, particular securities and other investments for the purpose of realizing a capital loss or avoiding a capital gain. You may also request reasonable restrictions on the investments made in your discretionary account or may request to reasonably modify existing investment restrictions previously accepted by us or the OSM Manager, as applicable. Reasonable restrictions may include the designation of particular securities or other investments or types of securities that should not be purchased in your discretionary account (such as Company XYZ or companies involved in a particular industry) or should be sold if held in your account. If any of the restricted securities are currently held in your account, you understand that they will be sold at the time the restriction is accepted without regard to tax consequences. We or the OSM Manager, as applicable, may determine that the requested restriction is not reasonable in our sole discretion. If so, you will be notified promptly. When accommodating an investment restriction, we or the OSM Manager, as applicable, may in our sole discretion select an alternative security in lieu of the restricted security, use the funds to invest in additional shares of the non-restricted portfolio holdings, or hold the funds in your cash sweep account. We cannot accept instructions to prohibit or restrict the purchase of specific securities or types of securities or other investments held within mutual funds or ETFs purchased by your IAR or an OSM Manager, as applicable, on your behalf. The ability to accommodate restrictions will vary by OSM Manager and more information about their ability to accommodate reasonable restrictions can be found in the OSM Manager’s Form ADV Part 2. Performance of an account with restrictions will differ from, and may be lower than, the performance of an account without investment restrictions. In addition, your decision to alter the allocation of any strategy or substitute any security may result in exposure to additional (and potentially unforeseeable) risks that are inconsistent with the objective of your advisory account. Similarly, clients that impose similar investment restrictions may or may not have similar portfolios. Efforts to accommodate reasonable investment restrictions may result in us or the OSM Manager selling securities in your account at an inopportune time, possibly causing a taxable event. In addition, in the event corporate actions at an issuer, including but not limited to mergers, spin-offs, and other types of reorganizations, result in the issuance of newly traded securities (that is, new symbols or CUSIPs that replace the previously restricted symbols/CUSIPs), the restriction will not carry forward to the new securities. You must provide a new restriction request for the new securities. Should you wish to impose or modify existing restrictions, or your financial condition or investment objectives have changed, you should contact your IAR or the AMS Client Services Department at (800) 248-8863, extension 74991.

Performance Fees and Side-By-Side Management We do not manage any accounts or provide advisory services where we are compensated under a performance-based fee arrangement. In addition, we do not permit our IARs or other representatives to provide advisory services where their compensation is paid pursuant to a performance-based fee arrangement. However, one or more OSM Managers in our OSM Programs may engage in performance-based arrangements, the details of which will be described in the respective OSM Manager’s client agreement and Form ADV. In these cases, our firm and our IARs do not receive compensation based on the performance-based fee charged by the OSM Manager.

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Methods of Analysis, Investment Strategies and Risk of Loss We and our IARs recommend and offer a broad spectrum of investment products, programs, and strategies. We and our IARs may use any of several methods of investment analysis, or combination of methods, when providing services to you. We have no requirements for using a particular analysis method and IARs are provided flexibility (subject to our Firm supervision and compliance requirements) when developing their investment strategies. IARs may use, as examples, internal or external research (written research or by having conversations with various sources), local or national news, press releases, economists’ views, personal contacts, and/or model portfolios from affiliated or non-affiliated sources to formulate investment strategies tailored to your investment objectives, financial situation, and risk tolerance. Model portfolios used as a research tool may also be available. As an example, financial advisors may monitor trading decisions made by the AMS Investment Committee or our own affiliated managers (collectively; “our managers”) in strategies available in our other Managed account programs and implement a substantially similar strategy(s) in your Ambassador program account. While your financial advisor, through their own analysis, can decide to implement identical trades in your Ambassador account, performance differences can occur due to the execution timing of trades (note: such trades in your account will occur after the model trades are implemented), specific portfolio holdings or relative exposures. The variances in how your financial advisor implements the model strategies they are following will affect the performance of your Ambassador account in comparison to the actual model portfolio in one of the Managed account programs. In addition, note that compensation paid to your financial advisor may be higher in the Ambassador program than our other Managed account programs depending on your negotiated fee. Because our Managed and Ambassador program accounts are available through various affiliated entities, including other divisions of Raymond James, you could pay more or less for access to these same models based upon your negotiated fee in advisory programs available through the other entity. For information about those analyses and strategies used by OSM Managers in the OSM Program, please refer to the individual OSM Manager’s investment management agreement, Form ADV Part 2A or equivalent brochure.

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Disciplinary Information Below is a summary of our material legal and disciplinary events during the last ten years. As of the date of this Brochure, there are no such reportable events for our senior management personnel or those individuals in senior management responsible for determining the general investment advice provided to our clients. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of our Firm. Our firm operates as an investment adviser. The disciplinary reporting requirements for brokerdealers and investment advisers differ in some ways, with FINRA requiring broker-dealers to report on matters (for example, pending complaints and arbitrations) which are not required to be reported by investment advisers. The information in this report is not the only resource you can consult. You can access additional information about our Firm and our management personnel on the SEC’s website, located at https://adviserinfo.sec.gov/, as well as FINRA’s website at https://brokercheck.finra.org/. Please note that in each instance described below, the Firm entered into the various orders, consents, and settlements without admitting or denying any of the allegations. Securities and Exchange Commission (“SEC”) On March 11, 2019, the SEC issued an order regarding the conduct that RJFSA had self-reported to the SEC. Specifically, the SEC found that at times during the period of January 1, 2014 to February 16, 2018 (the “review period”), RJFSA purchased, recommended, or held for advisory clients mutual fund share classes that charged 12b-1 fees instead of lower-cost share classes of the same funds for which the clients were eligible; and RJFSA did not disclose in its Form ADV or otherwise the conflicts of interest related to (a) its associated persons’ receipt of 12b-1 fees, and/or (b) its selection of mutual fund share classes that pay such fees. The SEC found that, as a result of that conduct, RJFSA violated Sections 206(2) and 207 of the Investment Advisers Act of 1940. RJFSA neither admitted nor denied the SEC’s findings. In mid-2018, RJFSA self-reported to the SEC, pursuant to the SEC’s Share Class Selection Disclosure Initiative, conduct related to its mutual fund share class selection practices and the fees its affiliated broker, RJFS, and associated persons received pursuant to Rule 12b-1 under the Investment Company Act of 1940. As part of its settlement with the SEC, RJFSA consented to a cease-and-desist order and to pay $6,877,048.11 (representing 12b-1 fees received during the review period and reasonable interest) to affected investors. It also agreed to review and correct as necessary all relevant disclosure documents concerning mutual fund share class selection and 12b-1 fees, and certain other related undertakings as well. RJFSA notified affected investors in January 2019 of the fee credit and interest amount that they would receive which would be reflected in the affected investor’s January account statement. Affected investors with closed accounts received a check through the mail in February.

On September 17, 2019, Raymond James & Associates, Inc., Raymond James Financial Services, Inc., and Raymond James Financial Services Advisors, Inc. (collectively, “Raymond James”) settled a matter with the SEC where Raymond James had not properly conducted suitability reviews for certain advisory accounts, had inadvertently overvalued certain assets that resulted in charging excess advisory fees, did not consistently have a reasonable basis for recommending certain unit investment trust (“UIT”) transactions to brokerage customers, and failed to disclose the conflict of interest associated with earning greater compensation when recommending certain securities without providing applicable sales-load discounts to brokerage customers. The issues occurred at various time from January 2013 through May 2018, and not every account was impacted by these issues. Raymond James promptly undertook a number of remedial efforts, which included voluntarily retaining compliance consultants to comprehensively review its UIT transactions and advisory valuation practices and revising its policies and procedures regarding the supervision of advisory accounts. Without admitting or denying the SEC’s findings, Raymond James will pay restitution of $11,098,349.01 and interest of $1,072,764.80. Raymond James will also pay a civil money penalty in the amount of $3,000,000 to the SEC. On September 3rd, Raymond James sent notices of pending credits to impacted clients. Certain states have made inquiries into this matter as well.

Financial Industry Regulatory Authority (“FINRA”, the Successor to NASD) On March 2, 2017, FINRA entered findings that Raymond James violated FINRA Rule 2010 and NASD Rule 3010 by failing to establish and maintain a reasonable supervisory system and related procedures in connection with its trading in convertible

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bonds. Raymond James consented to the described sanctions and entry of findings and was censured, ordered to pay a fine in the amount of $180,000 and ordered to revise its written supervisory procedures concerning the monitoring of its trading in convertible bonds.

On December 21, 2017, FINRA entered findings that Raymond James Financial Services (RJFS) violated NASD Rules 3010 and 2110 and FINRA Rules 3110 and 2010 by failing to establish and maintain adequate supervisory systems and processes for reviewing the email communications of its personnel. The findings state that RJFS failed to: (i) implement an adequate email surveillance system, (ii) devote adequate personnel and resources to the team that reviewed emails, (iii) appropriately apply email surveillance policies at branch offices using their own email servers, and (iv) periodically test the configuration and effectiveness of the system. Without admitting or denying FINRA’s findings, RJFS consented to a censure and fine of $2,000,000 and is adopting and implementing supervisory policies to address the deficiencies.

On November 6, 2019, FINRA entered findings that RJFS, an affiliated broker-dealer, violated MSRB Rule G-27(a), (b), and (c) by failing to establish and maintain a supervisory system and establish, maintain, and enforce written supervisory procedures, reasonably designed to supervise representatives’ share-class recommendations to customers of 529 savings plans during the period of January 1, 2008, through March 31, 2017. RJFS consented, without admitting or denying the findings, to the entry of a censure and agreed to pay restitution in the estimated amount of $4,203,182 to certain 529 plan customers. As a result of RJFS’s extraordinary cooperation to FINRA’s investigation, this matter was resolved without a monetary fine.

On October 20, 2022, Raymond James Financial Services, Inc. (RJFS), the affiliated broker-dealer of RJFSA, entered into a Letter of Acceptance, Waiver, and Consent (AWC) with FINRA for not reasonably supervising two registered representatives who overcharged commissions to seven institutional customers from January 2012 through April 2018 and for not having a qualified and registered principal of RJFS approving changes made to more than 7,500 orders and such unapproved changes led to customer losses, which were reimbursed. In May 2018, RJFS reported on the representatives’ termination notices that they had resigned while under investigation by the firm. As of February 2020, RJFS has designated registered principals on its trade desks to review and authorize changes to account name and designation on orders. RJFS self-reported this matter to FINRA in February 2019. To settle both matters, RJFS consented to the imposition of a censure, an $800,000 fine, restitution of $48,574.79 plus interest, and an undertaking that within 90 days of the issuance of the AWC a senior officer and principal of RJFS will certify in writing that RJFS has completed its review of its policies, procedures and systems regarding monitoring of electronic communications and that they are reasonably designed to achieve compliance with applicable securities laws, regulations and FINRA rules.

On January 30, 2023, Raymond James and Associates, Inc. (“RJA”, a dually registered broker-dealer and investment adviser), acting in its capacity as a broker-dealer and a clearing firm for Raymond James Financial Services Advisors, Inc., entered into a Letter of Acceptance, Waiver, and Consent (AWC) with FINRA for failure to accurately disclose potential conflicts of interest related to at least 1,850,000 trade confirmations between January 2014 and May 2022. The potential conflicts included the firm’s execution capacity when it acted in a mixed capacity (i.e., agency, agency cross, principal, and/or riskless principal) or whether the trade was executed at an average price, or inaccurately disclosed or omitted its status as a market maker in the security. RJA agreed to the entry of findings and sanctions, including a censure and a fine in the amount of $300,000.

On August 29, 2024, Raymond James Financial Services, Inc. (“the Firm”), a registered broker-dealer, entered into a Letter of Acceptance, Waiver, and Consent (AWC) with FINRA for not reasonably supervising the Firm’s reporting, including timeliness of reporting, of customer complaints via FINRA Rule 4530 filings and amendments to registered representatives’ Forms U4 and U5 since at least January 2018. Additionally, from January 2012 to at least December 2017, the Firm, which self-reported the issue, did not reasonably supervise mutual fund purchases that the Firms’ representatives made directly with mutual fund companies on behalf of Firm customers; such transactions in many cases happened outside the Firm’s automated surveillance systems which were not configured to subject them to review. The Firm and FINRA conducted retrospective reviews of the direct business identified and the Firm agreed to the entry of findings and sanctions, including a censure, a fine in the amount of $1,300,000, and restitution in the amount of $85,554.94 plus interest.

On August 18, 2026, Raymond James and Associates, Inc. (RJA), acting in its capacity as a broker-dealer, entered into a Letter of Acceptance, Waiver, and Consent (AWC) with FINRA for failing to report approximately 2.56 million liquidations of dividend reinvestment program (DRIP) fractional shares executed in a principal capacity to the applicable trade reporting facilities and failing to pay the associated regulatory transaction fees from at least January 2018 through October 2024. The AWC also stated that, during the same period, RJA’s supervisory system was not reasonably designed to achieve compliance with its reporting obligations for fractional share trades. RJA consented to the entry of findings and the following sanctions: a censure, $125,000 fine, and payment of regulatory transaction fees associated with the unreported fractional share trades. RJA acts as executing broker-dealer and clearing agent for RJFSA.

New York Stock Exchange, Inc. (“NYSE”) On May 8, 2018, the NYSE determined that Raymond James failed to report positions to the Large Options Position Report (LOPR) and inaccurately reported positions in other cases. The findings stated the Raymond James LOPR reporting violations primarily resulted from its entry of an incorrect effective date when submitting certain options positions to the LOPR and its failure to properly aggregate certain of its reportable options positions. The findings also stated that the firm failed to have a reasonable supervisory system with respect to the reporting of options positions, including a review for accuracy of LOPR submissions with respect to effective dates and accounts acting in concert. Additionally, until November 2015, the firm lacked any written supervisory procedures with respect to the proper reporting of options positions, including systems of follow-up and review, and

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thereafter, failed to have adequate written supervisory procedures until January 2017. On May 8, 2018, Raymond James was censured and fined a total of $400,000, of which $200,000 was paid to NYSE ARCA, Inc. and the remaining amount was paid to NYSE American, LLC. Additionally, Raymond James submitted a written report confirming it had completed remediation of all the LOPR issues identified within 120 days of May 8, 2018.

On October 19, 2018, the NYSE determined that during the period from January 1, 2014, through August 31, 2016, Raymond James violated certain provisions of the Market Access Rule for institutional counterparties for which Raymond James provides trade execution and clearing services, namely: (1) Rule 15c3-5 of the Securities Exchange Act of 1934, by failing to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the financial and regulatory risks of its business activity; and (2) NYSE Rule 3110 and former NYSE Rule 342, by failing to establish and maintain a supervisory system reasonably designed to achieve compliance with applicable laws, rules, and regulations, in connection with its: (1) calculation and implementation of certain customer credit limits; (2) determination of certain erroneous order controls; and (3) conducting of annual reviews. Raymond James was censured and consented to a $400,000 fine.

State On June 14, 2017, the State of Massachusetts alleged RJFSA failed to register an investment adviser representative who had a place of business in Massachusetts and to ensure the investment adviser representative was properly registered with the State. The State ordered RJFSA to pay a fine of $75,000, which it paid.

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