DRAFT DEMONSTRATION — Generated for review purposes. This memo uses publicly available Form ADV data filed by Jackson Square Capital, LLC. A production ComplianceMemo is generated from your live filing.

I. Executive Summary

II. Disclosure Gap Analysis

A. Current Item 8 Language

“[The firm] utilizes fundamental analysis and technical analysis when structuring client portfolios.” The brochure further describes the evaluation of independent managers as encompassing assessment of “research capabilities” and “third-party analyses it believes are reputable” without identifying whether any such analyses are generated, screened, or augmented by AI-assisted tools.

B. Applicable Regulatory Standard

C. Examination Exposure Created by Current Disclosure

Gap 1 — Undisclosed Tool Scope: If the tru Independence or Pontera platforms incorporate AI-assisted analytics, data screening, or manager-rating functions that inform the firm's investment recommendations or manager-selection process, the current Item 8 description of “fundamental and technical analysis” does not capture those methods. This creates examination exposure under Form ADV Part 2A Item 8's requirement that all material methods of analysis be disclosed.

Gap 2 — Third-Party Research Attribution: The reference to “third-party analyses it believes are reputable” in the manager-evaluation section may encompass AI-generated research or scoring outputs without identifying them as such. Examiners have treated this type of generic attribution as insufficient where AI tools are a material component of the analytical process.

Gap 3 — Absence of AI Risk Disclosure: Item 8 requires disclosure of material risks associated with the methods used. Even if the firm's AI tool use is limited or indirect, the absence of any AI-specific risk language — covering model error, data bias, over-reliance on algorithmic outputs, and the limitations of AI-assisted due diligence — may implicate the completeness of the firm's risk disclosure to clients.

III. Recommended Item 8 Disclosure Language

Methods of Analysis — Technology-Assisted Tools. In addition to the fundamental and technical analysis described above, we utilize third-party technology platforms — including tru Independence and Pontera — in connection with portfolio administration, held-away account monitoring, and the evaluation of independent investment managers. These platforms may incorporate AI-assisted analytical tools, including data screening algorithms, portfolio analytics, and manager-evaluation models. Where AI-assisted outputs are made available through these platforms, our investment professionals review such outputs as one input among multiple sources of analysis; no investment decision is made solely on the basis of an AI-generated recommendation or score. We periodically review the analytical methodologies embedded in our technology platforms to assess their relevance and reliability.

Risks of AI-Assisted Analysis. The use of AI-assisted tools in investment analysis presents risks distinct from those associated with traditional analytical methods. AI models may reflect biases embedded in historical training data; may perform inconsistently in market environments that differ materially from the data on which they were trained; and may produce outputs that are not readily interpretable by human reviewers. AI-assisted screening or scoring tools do not guarantee the accuracy of manager evaluations or the suitability of investment recommendations. We maintain human oversight of all investment decisions and do not delegate final investment judgment to algorithmic or AI-assisted systems.

Third-Party Research. We may rely on third-party research, analyses, and data services that we believe are reputable and relevant to client portfolio management. Such research may include materials generated or augmented by AI-assisted tools operated by the research provider. We evaluate the methodology and track record of third-party research sources as part of our ongoing due diligence process, but we do not independently verify the underlying algorithms or data inputs used by third-party AI systems.

Technology Platforms and AI Tools. We have reviewed the technology platforms we use in connection with our investment advisory services, including tru Independence and Pontera. As of the date of this brochure, we have determined that our investment analysis and manager-selection process relies primarily on fundamental and technical analysis performed by our investment professionals, supplemented by third-party research and data we believe to be reputable. To the extent AI-assisted analytical functions are embedded in our technology platforms, such functions are used for administrative or operational purposes and do not form a material part of our investment decision-making process. If our use of AI-assisted tools in the investment process changes materially, we will update this disclosure accordingly.

Ongoing Review. We periodically review the technology tools available through our platform providers to assess whether AI-assisted functions have become a material component of our analytical process. This disclosure reflects that review as of the date of this brochure's most recent amendment.

IV. Attestation Record

This memo has been cryptographically anchored on Gnosis Chain. The hash above uniquely identifies this document and cannot be altered retroactively. Any modification to the memo content will produce a different hash, making tampering immediately detectable. This attestation record is available for SEC examination on request and constitutes documented evidence that this governance review was completed on July 2, 2026.