Tidemark, LLC: investment adviser

Equities Exchange Traded Funds (“ETFs”) Mutual funds Fixed Income securities Alternative investments Structured products

Because some types of investments involve certain additional degrees of risk, they will only be implemented when consistent with the client’s stated investment objectives/restrictions, tolerance for risk, liquidity and suitability. Tidemark’s investment professionals take into consideration the client’s current situation (income, tax levels, risk tolerance levels and time horizon, among others and relies on the stated objectives of the client and considers the client’s risk profile and financial status before making any recommendation. Tidemark provides individually tailored client investment strategies and recommendation services on a discretionary basis. Tidemark directs its clients to its preferred custodian, LPL Financial (“LPL”), an SEC registered investment adviser and broker-dealer. However, clients have the ability to custody their accounts with Charles Schwab or Fidelity Investments. Financial Planning & Consulting Services Tidemark provides financial planning and consulting services consistent with the client’s financial and tax status. Clients will receive a written financial plan, providing recommendations tailored to their stated financial goals and objectives. In general, the financial plan may include a comprehensive review of client investments and objectives, tax status, risk management strategies, retirements planning, insurance, college planning, or estate planning. Tidemark gathers required information through in-depth personal interviews. Information gathered includes a client’s current financial status, future goals and attitudes toward risk, Related documents supplied by the client are carefully reviewed and a written report is typically prepared. A client is under no obligation to act on Tidemark’s financial planning recommendations. Should a client choose to implement the recommendations in the plan, they are under no obligation to implement the plan through the Advisors’ Asset Management Services. Tidemark suggests the client work closely with his/her attorney, accountant or insurance agency. To the extent requested by a client, we may recommend the services of other professionals. If a client engages any recommended professional and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.

Estate Planning Services Tidemark provides Estate Planning Services through a third-party digital estate planning service for clients who have the need for estate planning review, creation of estate documents. The Adviser services will consist of education on estate planning topics and the collection of general information necessary to complete a new estate plan or review a current estate plan, as well as assisting with trust funding. The Adviser does not draft legal documents, nor does it provide any type of legal advice and/or opinion during the document preparation process. There may be instances where the client may need legal advice. The Adviser will provide recommendations to Client as to other sources of professional advice to address such matters. Tidemark does not participate in any wrap fee programs. Assets Under Management As of December 31, 2025, the following represents the amount of client assets under management by Tidemark: Type of Account

Assets Under Management

Discretionary

$458,379,695

Non-Discretionary

$4,123,561

Total:

$462,503,256

Tidemark does not require a minimum account balance. However, certain Investment Advisor Representatives may choose to impose minimum account sizes depending on client’s circumstances and needs. Tidemark retains the discretion to negotiate alternative fees on a client-by-client basis. Other Fees & Expenses In addition to our advisory fees, and where applicable, clients are required to pay other charges such as: custodial fees; brokerage commissions; transaction fees; internal fees and expenses charged by mutual funds, and exchange traded funds (“ETFs”); brokerage account maintenance fees; and other fees and taxes on brokerage accounts and securities transactions. Mutual fund companies and ETFs charge internal fees and expenses for their products. These fees and expenses are in addition to any advisory fees charged by Tidemark. Complete details of these internal fees and expenses are explained in the prospectus. Clients are strongly encouraged to read these explanations before investing any money. Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information. Financial Planning & Consulting Services Tidemark provides financial planning and consulting services as a fixed rate or hourly fee depending on the nature and complexity of the client’s situation. The fee is agreed upon at the onset of the relationship and is paid in advance. Estate Planning Services Tidemark provides Estate Planning Services at a fixed rate depending on the nature and complexity of the client’s situation. The fee is agreed upon at the onset of the relationship and is paid in advance. Termination of the Advisory Relationship A client agreement may be canceled at any time, by either party, for any reason upon receipt of written notice. Upon termination of an account, any unearned fees will be promptly refunded. In calculating a client’s reimbursement of fees, we will pro rate the reimbursement according to the number of days remaining in the billing period.

Fundamental analysis is performed on historical and present data, but with the goal of making financial forecasts. There are several possible objectives: (a) to conduct a company stock valuation and predict its probable price evolution; (b) to make a projection on its business performance; (c) to evaluate its management and make internal business decisions; (d) and/or to calculate its credit risk.; and (e) to find out the intrinsic value of the share. When the objective of the analysis is to determine what stock to buy and at what price, there are two basic methodologies investors rely upon: (a) Fundamental analysis maintains that markets may misprice a security in the short run but that the "correct" price will eventually be reached. Profits can be made by purchasing the mispriced security and then waiting for the market to recognize its "mistake" and reprice the security.; and (b) Technical analysis maintains that all information is reflected already in the price of a security. Technical analysts analyze trends and believe that sentiment changes predate and predict trend changes. Investors' emotional responses to price movements lead to recognizable price chart patterns. Technical analysts also analyze historical trends to predict future price movement. Investors can use one or both of these different but complementary methods for stock picking. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Technical Analysis A security analysis methodology for forecasting the direction of prices through the study of past market data, primarily price and volume. A fundamental principle of technical analysis is that a market's price reflects all relevant information, so their analysis looks at the history of a security's trading pattern rather than external drivers such as economic, fundamental and news events. Therefore, price action tends to repeat itself due to investors collectively tending toward patterned behavior– hence technical analysis focuses on identifiable trends and conditions. Technical analysts also widely use market indicators of many sorts, some of which are mathematical transformations of price, often including up and down volume, advance/decline data and other inputs. These indicators are used to help assess whether an asset is trending, and if it is, the probability of its direction and of continuation. Technicians also look for relationships between price/volume indices and market indicators. Technical analysis employs models and trading rules based on price and volume transformations, such as the relative strength index, moving averages, regressions, inter-market and intra-market price correlations, business cycles, stock market cycles or, classically, through recognition of

chart patterns. Technical analysis is widely used among traders and financial professionals and is very often used by active day traders, market makers and pit traders. The risk associated with this type of analysis is that analysts use subjective judgment to decide which pattern(s) a particular instrument reflects at a given time and what the interpretation of that pattern should be. Cyclical Analysis Statistical analysis of specific events occurring at a sufficient number of relatively predictable intervals that they can be forecasted into the future. Cyclical analysis asserts that cyclical forces drive price movements in the financial markets. Risks include that cycles may invert or disappear and there is no expectation that this type of analysis will pinpoint turning points, instead be used in conjunction with other methods of analysis. Charting In this type of technical analysis, our firm reviews charts of market and security activity in an attempt to identify when the market is moving up or down and to predict when how long the trend may last and when that trend might reverse. Risks for all forms of analysis. Clients should be aware that there is a material risk of loss using any investment strategy. Below is a summary of the investment strategies and those risks: Alternative Investments Hedge funds, commodity pools, Real Estate Investment Trusts (“REITs”), Business Development Companies (“BDCs”), and other alternative investments involve a high degree of risk and can be illiquid due to restrictions on transfer and lack of a secondary trading market. They can be highly leveraged, speculative and volatile, and an investor could lose all or a substantial amount of an investment. Alternative investments may lack transparency as to share price, valuation and portfolio holdings. Complex tax structures often result in delayed tax reporting. Compared to mutual funds, hedge funds and commodity pools are subject to less regulation and often charge higher fees. Alternative investment managers typically exercise broad investment discretion and may apply similar strategies across multiple investment vehicles, resulting in less diversification. Cash & Cash Equivalents Cash and cash equivalents generally refer to either United States dollars or highly liquid short- term debt instruments such as, but not limited to, treasury bills, bank CD’s and commercial papers. Generally, these assets are considered nonproductive and will be exposed to inflation risk and considerable opportunity cost risk. Credit Risk The return on fixed income investments (e.g., bonds and preferred stock) is dependent on the issuer of the security meeting its commitment to making agreed upon payments. Credit risk is the risk that the issuer does not meet that obligation. Cryptocurrency Products Digital (crypto) currency products may be an illiquid private placement or structured as a trust or exchange traded fund which pool capital together to purchase holdings of digital currencies or derivatives based on their value. Such products are extremely volatile and are suitable only as a means of diversification for investors with high-risk tolerances. Furthermore, these securities carry very high internal expense ratios, and may use derivatives to achieve leverage or exposure in lieu of direct cryptocurrency holdings. This can result in tracking error and may sell at a premium or discount to the market value of their underlying holdings. Security is also a concern for digital currency investments which make them subject to the additional risk of theft.

Equity Investments Refers to buying shares of stocks in return for receiving a future payment of dividends and capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry market conditions and general economic environments. Exchange Traded Funds (“ETFs”) ETFs are securities that track an index, a commodity, or basket of assets like an index fund, but that are traded like a stock on an exchange. ETFs can also be actively managed. ETFs experience prices changes throughout the day as they are bought and sold. Fixed Income Investments Generally, fixed income investments pay a return on a fixed schedule, though the amount of the payments can vary. This includes corporate and government debt securities, leveraged loans, high yield and investment grade debt and structured products, such as mortgage and other asset-backed securities. In general, the fixed income market is volatile, and fixed income securities carry significant interest rate risk. As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities. Fixed income securities also carry inflation risk, liquidity risk, call risk and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting, but these bonds still carry a risk of losing share price value. Risks of investing in foreign fixed income securities also include the general risks inherent in non-U.S. investing. Interest Rate Risk Fluctuations in interest rates will cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Mutual Funds Investing in mutual funds carries the risk of capital loss and thus you may loss money investing in mutual funds. All mutual funds have casts that lower investment returns. The funds can be of bond (fixed income) nature or stock (equity) nature, or a mix of multiple underlying security types. Long-Term Purchases Our firm may buy securities for your account and hold them for a relatively long time (more than a year) in anticipation that the security’s value will appreciate over a long horizon. The risk of this strategy is that our firm could miss out on potential short-term gains that could have been profitable to your account, or it’s possible that the security’s value may decline sharply before our firm make a decision to sell. Market Risk The price of a security, bond or mutual fund can drop in reaction to tangible and intangible events and conditions. External factors cause this type of risk, independent of a security’s underlying circumstances. For example, political, economic and social conditions can trigger market events. Non-U.S. Investments: Investment in non-U.S. issuers or securities principally traded outside the United States may involve certain special risks due to economic, political and legal developments, including favorable or unfavorable changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, and the imposition of withholding taxes on dividend or interest payments. Short-Term Purchases When utilizing this strategy, our firm may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). Our firm do this in an attempt to take advantage of conditions that our firm believe will soon result in a price swing in the securities our firm purchase. The potential risk associated with this investment strategy is associated with the currency or exchange rate.

Currency or exchange rate risk is a form of risk that arises from the change in price of one currency against another. The constant fluctuations in the foreign currency in which an investment is denominated vis-à-vis one's home currency may add risk to the value of a security. Currency risk is greater for shorter term investments, which do not have time to level off like longer term foreign investments. Structured Products Structured products are designed to facilitate highly customized risk-return objectives. While structured products come in many different forms, they typically consist of a debt security that is structured to make interest and principal payments based upon various assets, rates or formulas. Many structured products include an embedded derivative component. Investing in structured products includes significant risks, including valuation, lack of liquidity, price, credit and market risks.

Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that clients should be prepared to bear.

Third-Party Insurance Services When clients have insurance needs that fall outside Tidemark's scope of services, we may introduce them to a trusted third-party insurance consulting firm. That firm works directly with the client to evaluate their needs, recommend appropriate coverage, and handle all paperwork and ongoing service. Clients are never obligated to use this referral; it is simply offered as a convenience. Tidemark receives compensation from the third-party insurance firm. This creates a conflict of interest as Tidemark has an incentive to recommend this service to clients. As part of Tidemark's fiduciary duty, Tidemark is committed to act in our client’s best interests at all times. Any decision to engage the insurance firm is solely at the discretion of the client.

Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior approval of certain investments made by our access persons. Our code also provides for oversight, enforcement and recordkeeping provisions. Our Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any particular access to non-public information, all employees are reminded that such information may not be used in a personal or professional capacity. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by calling us at 888-791-0197. Our firm and/or individuals associated with our firm may buy or sell for their personal accounts securities identical to or different from those recommended to our clients. In addition, any related person(s) may have an interest or position in a certain security(ies) which may also be recommended to a client. We may aggregate our employee trades with client transactions where possible and when compliant with our duty to seek best execution for our clients. In these instances, participating clients will receive an average share price and transaction costs will be shared equally and on a pro-rata basis. In the instances where there is a partial fill of a particular batched order, we will allocate all purchases pro-rata with each account paying the average price (or some other method that is fair and equitable). Our employee accounts may be included in the pro-rata allocation. As these situations represent actual or potential conflicts of interest to our clients, we have established policies and procedures for implementing our firm’s Code of Ethics, to help ensure our firm complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest.

Factors we consider when recommending a custodian include their ability to hold the investments we use to implement our investment strategies and each custodian’s financial strength, reputation, execution, pricing and service among other relevant factors. The client has the ability to select which custodian they will use.

We work primarily with them for administrative convenience and also because they offer good value to our Clients for the transaction costs and other costs incurred. Factors in Selecting or Recommending Broker-Dealers Tidemark may receive support services and/or products from the third-party custodians, many of which assist Tidemark to better monitor and service program accounts maintained at the custodian and may include the following:

investment-related research pricing information and market data software and other technology that provide access to client account data compliance and/or practice management-related publications consulting services attendance at conferences, meetings, and other educational and/or social events marketing support computer software other products and services used by [Advisor] in furtherance of its investment advisory business operations

Tidemark may continue to receive the services regardless of the volume of client transactions executed with the custodian. Clients do not pay more for services as a result of this arrangement. Directed Brokerage Tidemark does not permit client directed brokerage. Trade Aggregation Tidemark will block trades where possible and when advantageous to clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts, so long as transaction costs are shared equally and on a pro-rated basis between all accounts included in any such block. Block trading may allow us to execute equity trades in a timelier, more equitable manner, at an average share price. Tidemark will typically aggregate trades among clients whose accounts can be traded at a given broker, and generally will rotate or vary the order of brokers through which it places trades for clients.

Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. In addition to the periodic statements that clients receive directly from their custodians. We also send account statements directly to our clients on a quarterly basis. We urge our clients to carefully compare the information provided on these statements to ensure that all account transactions, holdings and values are correct and current.