Regulation Best Interest Disclosure

Scope and Terms of Our Relationship with You

Generally

Columbia Private Markets, LLC (the "Firm", "We", "Us", or "Our") is registered with the Securities and Exchange Commission (SEC) as a broker-dealer. When we act in our capacity as a broker-dealer, we are subject to the Securities Act of 1933, the Securities Exchange Act of 1934, as amended, the rules of self-regulatory organizations, such as the Financial Industry Regulatory Authority, Inc. (FINRA), and applicable state laws.

Limited Services

We provide a limited set of services related to mutual fund and private placement investments only. Such services are limited to making recommendations regarding and serving as selling and/or placement agent for mutual fund and private placement products and transactions. We offer both affiliated and unaffiliated private placement products; affiliated private placement products (i.e. private placement products in which, one of our affiliates, or our parent company have a direct or indirect economic interest) are only offered through unaffiliated registered investment advisers and unaffiliated FINRA member broker-dealers. We do not maintain accounts for our customers or handle client funds for purposes of facilitating client transactions in the mutual funds and private placements we offer. Instead, customers are required to place their purchases of mutual fund shares directly with the mutual fund company, and similarly, for private placement transactions, customers are required to work directly with the private fund's custodian to establish an account and remit their funds directly to such custodian. We may provide assistance and guidance to our customers as part of these processes.

Recommendation Standards

When our financial advisors may recommend investments to you, you are responsible for making the decision whether to purchase or sell investments, and we will only purchase or sell investments when specifically directed by you. We require our financial advisors to have a reasonable basis for any investment recommendation, taking into account the potential risks, rewards, and costs associated with a recommendation, to believe that each recommendation made to a client is in the client's best interest, and does not place the interest of the broker-dealer ahead of the interest of the client at the time the recommendation is made. In determining whether our financial advisor's recommendation is in the client's best interest, we consider the client's investment profile. The information in the client's investment profile includes, but is not limited to, the client's age, other investments, financial situation and needs, tax status, investment objectives, investment experience, investment time horizon, liquidity needs, risk tolerance, and other information that the client may disclose to us or the financial advisor in connection with a recommendation.

For affiliated private placements, you should only consider such products after discussing such products with an investment professional employed by a registered investment adviser or FINRA member broker-dealer that is not affiliated with us.

Material Limitations

Our services also do not include taking client orders, executing securities transactions, or providing general information regarding your investments.

Our financial advisors also do not monitor any of your investments after you effect a securities transaction, including those investments they recommend for you. Our financial advisors also do not make investment decisions for you or manage any of your investments, meaning we cannot buy or sell investments on your behalf. Because our financial advisors do not have discretionary investment authority, this means that we cannot buy or sell investments in your brokerage account without first obtaining your consent.

While we offer mutual funds and private placements, there are certain types of investments we do not offer. For instance, we do not offer all mutual funds from every single mutual fund company issuer, or every type of private placement. We also do not offer insurance products or college savings plans, nor do we make investment recommendations on other types of securities such as stocks or bonds. This means that our financial advisors are limited to recommending only those investments that we are authorized to offer. This is a material limitation on the securities that our financial advisors may recommend to you.

Additionally, not all of our financial advisors can offer the full range of investments we offer. For example, some of our financial advisors may not have the training or experience needed to make recommendations regarding private placements. This is a material limitation on the securities or investment strategies that your financial advisor may recommend to you, and you should discuss any such limitations with your financial advisor. In addition, you may research your financial advisor's experience and licenses on FINRA's brokercheck website at brokercheck.finra.org.

Fees and Costs

Generally

This section provides information about the material fees and costs associated with mutual fund and private placement transactions our financial advisors may recommend.

We are paid each time you make a new investment in a mutual fund or private placement we offer and recommend. This payment is typically called a "commission," but it may also be called a "sales charge" or "placement fee." This kind of payment presents a conflict for us because it creates an incentive to encourage you to trade more and make additional investments. The commission rate or amount varies depending on the investment and the size or amount of the transaction.

More information about commission and placement fee payments, including the commission schedules we use, is available on our website at www.cpmwealth.com/disclosures/placementfees.pdf.

In addition, mutual funds and private placements bear ongoing fees and expenses that are embedded into the cost of the investment holding. You pay these ongoing fees and expenses indirectly because they are factored into the cost of the investment and are subtracted from the performance return. More information about ongoing fees and expenses associated with mutual funds and private placements is contained within each product's offering documents, which you should carefully review prior to making any investment decision based on a recommendation of our financial advisors.

Set forth below and on the following pages is particularized fee and cost information regarding mutual funds and private placements.

Mutual Funds

Characteristics – Mutual funds are registered investment companies that issue redeemable securities. Mutual funds issue shares on a continual basis, and there is no secondary trading market for mutual fund shares. Mutual funds are required to sell their shares at the fund's net asset value (NAV) per share plus any applicable sales charge or load, which is described below. The fund's NAV is calculated by dividing the total value of all the fund's assets, minus any liabilities such as ongoing fees and expenses (described below), by the number of shares outstanding.

An important step to take prior to investing in mutual funds is to read the respective mutual fund's prospectus carefully. Each mutual fund prospectus contains important information that will help you make an informed decision about an investment in a mutual fund. In deciding whether to invest in a mutual fund, you should consider several different factors, including the mutual fund's past performance, investment objective, investment strategies and risks, the investment adviser responsible for the management of the mutual fund's assets, and the fees and expenses associated with the investment in a particular mutual fund.

General Fees and Costs – All mutual funds, including "no load" funds, incur transaction costs, expenses, and other fees associated with the investment. While past performance of a mutual fund is not indicative of future results, a mutual fund's long-term performance record and portfolio manager's experience and qualifications may be important factors in deciding to invest in a mutual fund. Your financial advisor can assist in obtaining a mutual fund prospectus upon your request.

You will typically pay a sales charge or load when you buy shares in a mutual fund. We receive a portion of this sales charge for our efforts and the efforts of our financial advisors in selling shares of the mutual fund.

Most mutual funds utilize multiple share classes, with differing fees and expenses for distribution and shareholder services. Common share classes available to you in a brokerage account are Class A and Class C. Each class typically has different fees and costs, and therefore fund performance results will differ as those fees and expenses reduce performance across share classes. You should also note that the amount of time you expect to hold your investment in a mutual fund plays an important role in determining which share class is most appropriate for you, and you should discuss this consideration with your financial advisor.

Fees and Costs: Share Class Distinctions – Each mutual fund company defines its own share class features, fees and costs in its prospectus. While there is no standard for defining share classes, set forth below are some common descriptions of share classes that are commonly used in our brokerage accounts.

• Class A – This share class usually carries a front-end sales charge, which is typically assessed as a percentage of your investment. This means that a sales charge is deducted from your investment each time you purchase shares in the mutual fund. Class A shares also typically have ongoing fees and expenses, which sometimes include fees commonly referred to as 12b-1 fees, and these 12b-1 fees are intended to finance distribution activities intended primarily to promote and market the mutual fund. Despite these ongoing fees and expenses, Class A shares typically have lower operating expenses compared to the other share classes of the same mutual fund that may be available to you. This means that ongoing costs will typically be lower than ongoing costs associated with other share classes of the same mutual fund that may be available to you. Many mutual funds offer "breakpoint" discounts for large investments in Class A shares, which means that the front-end sales charge decreases as the investment increases. These breakpoints are described in the mutual fund's prospectus and explained further below.
• Class C – This share class is characterized by a level asset-based sales charge that you pay annually as a percentage of your assets. It does not have a front-end sales charge like Class A shares, but it does have a contingent deferred sales charge (also known as a "CDSC") and higher ongoing operating expenses. The CDSC means that you pay a sales charge when you sell your mutual fund shares. The amount of the CDSC is typically assessed as a percentage of your investment, and it declines over time and eventually is eliminated the longer you hold your shares. Most Class C shares generally eliminate the CDSC after one year.

When considering an investment in Class A shares versus Class C shares, the length of time you expect to stay invested in the fund is the most important factor. For example, if you plan to hold a fund for 15 years, it will be cheaper to pay the upfront load and the lower ongoing expense fees over time. Whereas if the investment is only for two years, it would be less expensive to avoid the upfront load of the A share and purchase the C share with the higher annual fee.

Other share classes may be available as well, which you should discuss with your financial advisor.

Fees and Costs: Breakpoints – While it may make sense to own mutual funds from different mutual fund companies, it also may increase the total sales charges that you pay to purchase those mutual funds. Mutual fund companies often offer discounts or reduced sales charges based on the total amount you choose to invest with the mutual fund company. The investment levels needed to receive these discounts are known as "breakpoints." Mutual fund companies typically allow you to combine holdings with those of immediate family members to reach these breakpoints. The prospectus of every mutual fund describes its breakpoint policies, including how you can reach breakpoints. You can request a copy of a mutual fund's prospectus from your financial advisor.

Fees and Costs: Ongoing Fees and Expenses – In addition to the 12b-1 fees mentioned above, mutual funds typically also deduct other ongoing fees and expenses, such as management fees or servicing fees, from fund assets. These fees and expenses, sometimes referred to as the mutual fund's "expense ratio", are typically used to pay for the mutual fund's continued annual operating expenses, such as paying the mutual fund's investment manager, accounting and auditing expenses, legal expenses, and recordkeeping expenses. In addition, the ongoing fees and expenses include fees commonly referred to as 12b-1 fees, and these 12b-1 fees are intended to finance distribution activities intended primarily to result in the sale of additional shares of the mutual fund and include marketing and advertising expenses.

These ongoing fees and expenses are typically charged daily as a percentage of your assets. You pay these fees and expenses indirectly because they are deducted from your assets on an ongoing basis. These payments, as well as the conflicts of interest associated with them, are described more fully below in this Reg BI Disclosure document.

More Information – Information on a mutual fund's sales charges, ongoing fees and expenses, and overall expense ratio is available in the mutual fund's prospectus. You can request a copy of a mutual fund's prospectus from your financial advisor.

Private Placements

Characteristics – Private placements are generally private (not publicly traded) securities that are exempt from registration under federal securities laws and subject to limited regulatory oversight. They are intended to complement other portions of the investment portfolios of certain sophisticated investors and to provide opportunities for additional diversification and overall portfolio risk hedging. Private placements carry risks, including loss of your investment principal.

To avoid registration and application of certain federal securities laws, issuers of private placements often must limit eligible investors to those who fall within one or more of the following categories (who are presumed to have the necessary financial sophistication and resources to accept greater risks, and to be less in need of certain legal protections that attach to most private placements):

• Accredited Investors – for individual investors, this status generally requires that you either have (1) net worth over $1 million alone or with your spouse/spousal equivalent (excluding the value of your primary residence) or (2) earned income exceeding $200,000 (or $300,000 together with your spouse/spousal equivalent) in each of the two prior years, and reasonably expect the same in the current year.
• Qualified Clients – for individual investors, this status (which is required in order for the fund's adviser (asset manager) to receive certain performance-based compensation) generally requires that you either have (1) at least $1.1 million under the management of the specific adviser or (2) net worth of at least $2.2 million alone or with your spouse (excluding the value of your primary residence).
• Qualified Purchasers – for individual investors, this status generally requires that you own at least $5 million in certain investments.

Depending on the particular nature of any given private placement, different investor eligibility criteria may apply. Private placements have offering memoranda containing important information to help you make an informed decision about an investment in the private placement. You should read the private placement offering memorandum, and any other materials available carefully before investing. In deciding whether to invest in a private placement, you should consider several different factors, including the managing member's past performance, the issuers investment objective, investment strategies and risks, and the fees and expenses associated with an investment in the particular private placement. Your financial advisor can help you determine whether or not you are eligible to invest in certain private placements we offer.

General Fees and Costs – All private placements, including "no load" funds, incur expenses and other fees associated with the investment. When investing in a private placement, a portion of your investment is used to pay for the investment's placement agent services and activities, a portion of which we will receive for our efforts and the efforts of our financial advisors in recommending and selling the investment to you.

Fees and Costs: Ongoing Fees and Expenses – As mentioned, private placements typically also deduct other ongoing fees and expenses, such as management fees or servicing fees, from their assets. These fees and expenses are typically used to pay for the private placement's ongoing operations and stated business activities, such as paying the private fund's manager, investment adviser, accounting and auditing expenses, legal expenses, and/or recordkeeping expenses. The nature of a private placement's ongoing fees and expenses can vary from fund to fund, so you should carefully review the offering memorandum of any private placement one of our financial advisors may recommend to you.

More Information – Investing in private placements involves risks that you should carefully consider prior to investing. Your financial advisor can explain the risks, characteristics and costs to associated with these products should you wish to learn more. Additionally, your financial advisor can assist you in obtaining private placement offering memoranda and other documentation you may require or desire prior to making an investment decision.

Conflicts of Interest

We have identified certain conflicts of interest (conflicts) that relate to the recommendations we and our financial advisors make. A conflict arises when an economic benefit incentivizes either us or a financial advisor to put our interests and/or the interests of the financial advisor ahead of the interests of our clients. Some of these conflicts exist between our clients and both our Firm and financial advisors, while others exist between our clients and our Firm alone or between our clients and financial advisors alone.

The sections below disclose material facts relating to these conflicts so that you are able to make an informed decision regarding any recommendation one of our financial advisors provides you. Many of these conflicts generally exist in our industry as a whole and we have adopted policies and procedures designed to mitigate these conflicts of interest. We or your financial advisor may have conflicts of interest beyond those disclosed here. Our financial advisors will deliver additional disclosure to address any other material conflicts of interest when applicable.

Conflicts for Both Our Firm and Our Financial Advisors

Conflicts between our clients and both our Firm and financial advisors may be caused by a variety of arrangements, including the role we play in a transaction, compensation arrangements, or trading arrangements. The material facts relating to these conflicts are as follows:

Affiliated Products – In addition to unaffiliated investment products, we also recommend affiliated private placement products that are offered, managed, or sponsored by our parent company, Columbia Advisory Group, LLC ("CAG") or its affiliates. These recommendations may provide additional compensation to our firm or your financial professional compared to third-party products. This creates a financial incentive for us to recommend affiliated products, which represents a conflict of interest. Because of this conflict, we only make such recommendations and offering through other unaffiliated registered investment advisers or unaffiliated FINRA member broker-dealers.

Financial Advisor Dual-Registration – Certain financial advisors of ours may serve as investment adviser representatives ("IARs") for our investment advisory affiliate, Columbia Advisory Partners, LLC ("CAP"), which is 60% owned by our parent company, CAG. As discussed further below, our financial advisors receive a portion of the commission we receive in connection with the purchase of any product recommended by us. If your financial advisor is also an IAR of CAP, he/she may not serve as your CAP IAR if you are a CAP client; as a result, your financial advisor will not receive fee-based compensation for any investment advisory services provided to you by CAP if you are a CAP client. However, our financial advisors may recommend CAP's investment advisory services to you even though they would not be able to serve as your CAP IAR; utilizing CAP's investment advisory services would result in financial benefit to CAG and Mr. Larsen. This kind of payment presents a conflict because it creates an incentive for your financial advisor to encourage you to purchase investment advisory services from CAP.

Transaction-Based Fees – We and our financial advisors get paid when you enter an order or invest based on our recommendations. We are paid each time you buy a mutual fund or private placement through us. We pay our financial advisors a portion of the transaction-based payments that we receive. These transaction-based payments are referred to as commissions, sales charges, or placement fees. They incentivize us and your financial advisor to encourage you to conduct more mutual fund and private placement purchases.

Investment Costs for Different Investments – For any given client investment need and risk tolerance, ranging from conservative income to aggressive growth, we typically offer multiple investment types that are suitable choices. The different investment types have varying features, and the associated investment costs you pay for purchasing and holding each investment type differ as well. This incentivizes us and your financial advisor to recommend costlier investments to you to maximize the revenue we receive. It is also important to note that our firm's compensation is not investment-neutral, meaning that the percentage of the compensation for any given transaction that your financial advisor receives can vary based on the investment recommended. As a result, we and your financial advisor may have an incentive to recommend certain investments to you that result in greater compensation to us.

Investment Costs for Different Share Classes of the Same Security – As mentioned, mutual fund companies commonly offer multiple "share classes" of the same fund. Different share classes in the same fund are comprised of the same underlying basket of securities, but the classes differ based on the associated fees and compensation structures. A Fund's different share classes may include or exclude the transaction charge and some of the fees mentioned above in this section (12b-1 fees, service fees, sub-TA fees, etc.). Because each share class of the same Fund generally invests in the same portfolio of securities, an investor who holds a less expensive share class of a Fund will pay lower fees and as such, will earn higher investment returns than an investor who holds a more expensive share class of the same fund.

Clients should understand that the availability of different share classes with varying cost structures incentivizes us and their financial advisor to recommend the more expensive share classes. It is important to note, however, that where issuers have multi-share class structures, the lowest-cost share class is not always available to investors, due to high minimum investment amounts or account type requirements (e.g., a retirement account in a workplace retirement plan or an advisory account). You can find more information about the compensation paid on different share classes in the prospectus for the investment or by asking your financial advisor.

Third-Party Non-Cash Compensation – Some product vendors, money managers, or service providers make nominal gifts or provide business entertainment, such as meals, or tickets to theatrical, sporting or other events, to us or our financial advisors. Such gifts or entertainment incentivize us and our financial advisors to recommend the products of vendors who provide such non-cash compensation over the products of other vendors that do not pay us non-cash compensation or that pay us comparatively less non-cash compensation.

Material, Non-Public Information – Certain personnel in our Firm may become aware of material, non-public information from time to time regarding mutual funds or private placements we may be researching or recommending due to the nature of their responsibilities. Having access to material, non-public information incentivizes an individual to act on that information seeking to capitalize on and profit illegally from the information before it becomes public knowledge. It also incentivizes the individual to share the information with clients, friends or family so they too can profit illegally from the information.

Outside Business Activities – Some of our financial advisors engage in outside business activities. If your financial advisor engages in any outside business activities, these activities can incentivize your financial advisor to allocate time to the outside business activity that detracts from the level of service provided to you.

Employees Trading in Their Own Accounts – We permit our personnel to own the same securities owned by their clients. We also allow our personnel to engage in securities transactions on the same side of the market on the same trade date as clients as well as trade "contrary" to recommendations they are making to clients (i.e., personnel are allowed to purchase securities that they are recommending clients sell, and to sell securities that they are recommending clients purchase). In most cases, such "contrary" transactions are limited to special circumstances, such as to pay for educational, medical or unanticipated significant expenses; however, we permit such transactions in certain other situations as well. Your financial advisor has an incentive to "trade ahead" of clients when buying or selling an investment whose price fluctuates throughout the day. Buying ahead of a client trade will put upward pressure on the price so the subsequently entered client order has a higher price; the opposite is true for a sell order. When trading contrary, a financial advisor has the incentive to enter client orders before the financial advisor submits his or her order.

Customers Who Are Also Clients of an Investment Advisory Affiliate – Our Firm is owned by CAG, whose sole member is Mr. Larsen. Mr. Larsen also maintains a 60% indirect ownership interest in CAP, an SEC-registered investment adviser, through his single-member LLC, CAG, which holds a 60% direct ownership interest in CAP. This common ownership and control creates certain conflicts of interest regarding our financial advisors making recommendations to you (in the context of private placements only) if you are also a client of CAP, most notably as follows:

• Our financial advisors could have an incentive to recommend private placements with respect to customers who are also CAP clients as CAP could then take on the responsibility of conducting ongoing monitoring of such investments, for which CAP would be paid a fee for such services.
• Mr. Larsen is responsible for supervising the Firm's financial advisor's recommendations of private placements to you. Given his role as 60% indirect owner of CAP, Mr. Larsen could have an incentive to approve unaffiliated offering placements with respect to customers who are also CAP clients, as CAP could then take on the responsibility of conducting ongoing monitoring of such investments, for which CAP would be paid a fee for such services.
• Our financial advisors and Firm could have an incentive to encourage CAP personnel to participate in private placement offerings being placed by us and our financial advisors for purposes of ensuring contingencies associated with any such offerings are met.
• Pursuant to shared services agreement, our Firm relies upon CAP for certain resources and software systems, creating the potential for CAP personnel to have access to non-public information pertaining to our Firm, our customers, and/or offerings we are researching or supporting

Conflicts for Our Financial Advisors Alone

Conflicts between our clients and our financial advisors may be caused by a variety of arrangements, including compensation arrangements, client-specific arrangements, or outside business activities. The material facts relating to these conflicts are as follows:

Cash Compensation by the Firm Based on Sales Volume – The portion of gross commissions, fees, transaction-based payments, ongoing payments, and other forms of compensation we share with financial advisors in the form of cash compensation will vary but is generally in the range of 2% – 5% of the invested capital. Each month, the Firm shares a stated portion of gross commissions a financial advisor earns ranging from 40% to 90% depending on the Representatives' agreement with the Firm. It is important to note that our firm's cash compensation is not investment neutral, meaning that the percentage of the compensation for any given transaction that your financial advisor receives can vary based on the investment recommended.

This compensation structure incentivizes your financial advisor to encourage you to conduct more mutual fund and/or private placement purchases, or to conduct more transactions in certain investments with these categories, resulting in more gross commission for the financial advisor. This conflict is especially acute during the time your financial advisor works to surpass the initial gross sales threshold each year.

Third-Party Marketing and Training Payments – Many product vendors or their affiliates provide payments to cover a variety of a financial advisor's marketing and training expenses including, but not limited to: training events, vendor-hosted due diligence meetings, and client educational or social events. This incentivizes financial advisors to recommend that vendor's products over the products of other vendors that do not provide such payments or provide comparatively lower payments, even if the other vendors' comparable products have lower expenses or better performance.

How CPM Addresses These Conflicts

CPM addresses conflicts through the foregoing disclosures, as well as several other ways, including but not limited to:

• Limiting our distribution of affiliated products to placements through independent broker-dealers, registered investment advisers pursuant to specific guidance received from FINRA under FINRA Rule 1017 and Notice to Members 00-73;
• Employing training and processes to ensure our financial advisors' recommendations are in their customer's best interest based on their customers' needs and financial circumstances;
• Prohibiting sales contests, sales quotas, bonuses, and non-cash compensation that are based on the sales of certain products or certain customer-types;
• Requiring qualified and eligible Firm supervisory personnel to periodically review sales of products to assess whether such products are being disproportionately and inappropriately favored by our financial advisors;
• Requiring purchases of private placements by our Firm's personnel to receive pre-approval from our Firm's Chief Compliance Officer, as well as prohibiting non-bona fide purchases;
• Storing our data in a separate and secure instance on CPM's software platforms, and maintaining and administering access by our Firm personnel.

Additional Information

This document became effective on October 29, 2025, and it was last updated as of the date on the cover page. If we make changes that would require us to send you updated disclosures, we will send them to you consistent with your preferred delivery method.

You may request additional copies of these disclosures at any time by contacting your financial advisor or by viewing them online at www.cpmwealth.com/disclosures.