MATERIAL CHANGES

Almost every component of this Sierra Annual Updating Amendment to the Firm Brochure has been modified, in large part to refresh the layout, language used, and approach to discussing each item. Sierra recommends that this Firm Brochure be read in its entirety as a result.

While Sierra considers the majority of the changes to not be substantive or material alterations of prior disclosures related to each Item referenced in the Table of Contents, Sierra has highlighted below a summary of those specific changes we consider to be material since the last annual update of this Brochure, dated March 28, 2023.

The following material changes were made to this Brochure effective March 26, 2024:

Item 4: Added details and disclosures related to Sierra’s advisory services provided to Private Placement Variable Annuity separate accounts.

Item 5: Provided additional disclosure related to our Advisory Fees across our advisory services offerings, including updated descriptions of additional fees and expenses as applicable.

Item 7: Updated information related to our clients and minimum household and account sizes, as well as other requirements for advisory services.

Item 8: Updated descriptions related to our methods of analysis, investment strategies, and associated risks.

Item 13: Updated description on our methods related to the review of accounts.

Item 14: Updated disclosures related to Sierra’s Promoter and Operator relationships.