Cumberland Investment Counsel Inc.

• A percentage of assets under your management
• Performance-based fees

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

The brochure lists different fees for different services or strategies; see the brochure for them.

Account minimum: $1,000,000

As stated in the firm's Form ADV Part 2A brochure dated August 13, 2026. Fees can differ by service and may be negotiable; the brochure is the complete statement. Read the brochure on the SEC's IAPD site

$1,405,771,456 as of October 2026, filing dated September 29, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Portfolio management for individuals and/or small businesses
• Portfolio management for pooled investment vehicles (other than investment companies)
• Portfolio management for businesses (other than small businesses) or institutional clients

Also doing business as

CONSEILLERS EN PLACEMENT CUMBERLAND, CUMBERLAND, CUMBERLAND INVESTMENT COUNSEL, CUMBERLAND PRIVATE WEALTH, PATRIMOINE PRIVE CUMBERLAND

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

1992 (34 years)

Employees

Total: 19. Performing investment advisory functions: 16.

Wrap fee program participation

No.

Custodians (Schedule D, Section 5.K(3))

Charles Schwab & Co., Inc.National Bank Financial Inc.

Custodians holding 10% or more of the firm's separately managed account assets, as filed on Form ADV (Schedule D, Section 5.K(3)). A custodian holds client assets; it does not endorse or supervise the firm. AdvisorCensus has no relationship with any custodian.

Other offices (Schedule D, Section 1.F)

1 other office, as of the October 2026 filing

Calgary, Alberta

States registered or notice-filed

Not reported.

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

1 Reports 1 disclosure item on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Regulatory matters Items 11.C to 11.G

• 11.D(2) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $930,255,823 in the October 2021 data and $1,405,771,456 in the October 2026 data, up 51%.

Total employees: 19 in October 2021 and 19 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. September 2026
   • Updated its list of owners and control persons (Schedule A).
2. January 2026
   • No longer lists the business name Patrimoine Privé Cumberland.
   • Added the business name Patrimoine Prive Cumberland.
   • Employees performing advisory functions went from 17 to 16.
   • Regulatory assets under management went from $1,272,160,433 to $1,405,771,456 (+11%).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.