Wells Fargo Advisors

Part 2A of Form ADV Firm Brochure for: Strategic Planning Services 801 - 57434 Investment Advisory Services of Wells Fargo Advisors Financial Network, LLC Revised June 2026 Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC, separate registered broker-dealers and non-bank affiliates of Wells Fargo & Company. One North Jefferson, St. Louis, MO 63103 Phone (314) 875-3000 www.wellsfargoadvisors.com This brochure provides information about the qualifications and business practices of Wells Fargo Advisors Financial Network, LLC and our Strategic Planning Services. This information should be considered before becoming a Client. If you have any questions about these services or the contents of this brochure, please contact us at the telephone number above. This information has not been approved or verified by United States Securities and Exchange Commission or by any state securities authority. Additional Information about Wells Fargo Advisors Financial Network, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. Please note that registration as an investment adviser does not imply a certain level of skill or training. The advisory services described in this brochure are not insured or otherwise protected by the U.S. Government, the Federal Deposit Insurance Corporation, the Federal Reserve Board, or any other government agency and involve risk, including the possible loss of principal. Page 1 of 16 596410 (Rev 06 - 06/26)  Summary of Material Changes This section describes the material changes to Wells Fargo Advisors Financial Network, LLC’s (“WFAFN”) Part 2A of Form ADV (“Brochure”) for the Strategic Planning Services Program since the annual version of this Brochure dated March 2026. The summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. Clients are encouraged to read this Brochure in detail and contact their Financial Advisor with any questions. References throughout this document have been updated from Fee-Based Planning Services to Strategic Planning Services, as the name of the service has been changed to Strategic Planning Services. Strategic Planning Services section of the document has been updated to describe new minimum annual income and net worth requirements for clients to participate in Strategic Planning Services and to specify that written recommendations will be provided to clients participating in the service. Fees and Compensation section of the document has been updated to include a new Fee Schedule for Strategic Planning Services. Page 2 of 16 596410 (Rev 06 - 06/26)  Table of Contents Summary of Material Changes................................................................................................................. 2 Advisory Business.................................................................................................................................... 4 Firm Description and Ownership.................................................................................................. 4 Types of Advisory Services ......................................................................................................... 4 Strategic Planning Services......................................................................................................... 4 Services Tailored to Individual Client Needs ................................................................................. 6 Portfolio Management Services ................................................................................................... 6 Assets Under Management ......................................................................................................... 6 Fees and Compensation .......................................................................................................................... 6 Performance-Based Fees and Side-By-Side Management ................................................................... 9 Types of Clients ........................................................................................................................................ 9 Methods of Analysis, Investment Strategies and Risk of Loss............................................................ 9 Disciplinary Information ..........................................................................................................................10 Other Financial Industry Activities and Affiliations ..............................................................................12 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................14 Brokerage Practices ................................................................................................................................14 Review of Accounts .................................................................................................................................15 Client Referrals and Other Compensation .............................................................................................15 Custody .....................................................................................................................................................15 Investment Discretion ..............................................................................................................................16 Voting Client Securities ...........................................................................................................................16 Financial Information ...............................................................................................................................16 Page 3 of 16 596410 (Rev 06 - 06/26)  Advisory Business Firm Description and Ownership Wells Fargo Advisors Financial Network, LLC (“WFAFN”), is a broker-dealer and investment advisory firm providing investment and other financial services to individual, corporate, and institutional clients through a network of independent contractor representatives. It is a non-bank affiliate of Wells Fargo & Company (“Wells Fargo”), a financial holding company and bank holding company founded in 1852 and publicly held company (NYSE: WFC). Wells Fargo and its Affiliates are engaged in a number of financial businesses, including retail brokerage and investment advisory services. WFAFN is affiliated with Wells Fargo Clearing Services, LLC ("WFCS"), a broker-dealer and investment adviser that also provides advisory and brokerage services as well as securities-execution and brokerage-clearance services to WFAFN, and other retail securities firms throughout the United States. WFCS and WFAFN conduct business under the trade name Wells Fargo Advisors (“WFA”) in providing advisory and brokerage services. WFAFN has entered into an agreement with WFA, a non-bank affiliate of WFAFN, pursuant to which WFA will act as sub-adviser and/or service provider to WFAFN with respect to the advisory programs and services offered by the Firm. WFA is a member of the New York Stock Exchange, Inc. ("NYSE") and the principal stock exchanges in the nation, as well as FINRA and SIPC. The terms “Client,” “you,” and “your” are used throughout this document to refer to the person(s) or organization(s) who contract with us for the Services described here. “WFAFN,” “we,” “our,” and “us” refer to WFAFN together with our Affiliates, including but not limited to, Wells Fargo and its agents with respect to any services provided by those agents. “Affiliate” means any entity that is controlled by, controls or is under common control with WFAFN. Each Affiliate is a separate legal entity, none of which is responsible for the obligations of the other. “Account” means collectively or individually any brokerage Account and/or any Advisory Program Account you have with us, including any and all funds, money, securities and/or other property you have deposited with us. “Securities and/or Other Property” means, but is not limited to, money, securities, financial instruments and commodities of every kind and nature and related contracts and options, distributions, proceeds, products and accessions of all property. Types of Advisory Services We sponsor a number of wrap fee advisory programs that are designed to help Clients meet their investment objectives and goals. They include Unified and Separately Managed Account Programs, Mutual Fund Advisory Programs, Financial Advisor-Directed Programs and Non-Discretionary Advisory Programs (“Programs”). We also offer Consulting and Financial Planning advisory services. This Disclosure Document is being provided pursuant to Section 204 of the Investment Advisers Act of 1940 and deals solely with our Strategic Planning Services. Descriptions of the services and fees for the other Programs and services we offer can be found in separate disclosure documents, copies of which are available upon request. Strategic Planning Services We offer personal planning and consulting services (“Services”) to both prospective and existing Clients under a Strategic Planning Services agreement (“Agreement”). Prior to providing this planning and consulting advice for you, your Financial Advisor (“FA”) will obtain information about you. Generally, we offer these Services to prospective or existing Clients with a minimum net worth of $500,000, inclusive of real estate and other assets you own held at other financial institutions; or minimum $250,000 annual income; and a minimum of $2,500,000 net worth for certain specialty services. The types of information we obtain from you can include, but are not limited to: • Your current financial situation, including the amount and nature of your assets and liabilities, the amounts and sources of current and anticipated income, the amounts and types of current and projected expenses (including education expenses), and insurance coverage; • Your current and long-term financial and wealth transfer goals, objectives, and desires (including retirement goals); and • Other information as relevant to your specific engagement. The scope and duration of the Services and the fees that we charge will vary based on the complexity of your financial situation and your net worth (for the determination of fees). The descriptions of Services listed below are not exhaustive and are included to illustrate the typical areas included within each Service. Page 4 of 16 596410 (Rev 06 - 06/26)  Through Strategic Planning Services, you can elect to receive advice and recommendations related to the following Services: Cash Flow Analysis Cash flow planning may include support in the budgeting process, debt management, planning around major purchases and associated financing options, home purchase and mortgage analysis, income planning, and reviewing potential tax considerations, and their potential impact(s) to goal planning. Education Planning Education planning may involve support in reviewing educational goals, developing savings strategies and evaluating funding alternatives, education around financial aid, review of student loans options, debt repayment strategies and discussion of potential tax credits. Retirement Planning Retirement planning may involve support in identifying goals, developing savings strategies, education around federal benefits, reviewing employer-based stock benefits, and evaluation of distribution strategies. Risk Planning Risk planning may involve the review of existing policies and needs for protection in case of disability, long-term care, or in case of death, as well as other types of insurance products, and assistance in understanding of employer benefit programs. Wealth Planning Wealth transfer planning may involve assistance in designing gifting strategies, reviewing potential estate and trust planning strategies, discussion of benefits related to property ownership and titling and beneficiary designation considerations. Divorce Planning Divorce planning may involve assistance with budgeting, calculating divorce payments, evaluating alimony and child support, potential tax credits or deductions, tracing of asset ownership, and future value calculations of retirement accounts and pension funds. Financial Advisors, or a member of their team, must have the Certified Divorce Financial Analyst ® (“CDFA ®”) designation to be able to offer this Service. Special Needs Analysis ® (“ChSNC ®”) Special needs planning may involve assessing current and future needs, retirement and long-term care planning, reviewing life insurance needs, discussions on availability and applicability of federal benefits, purpose of special needs trust, estate and beneficiary planning, as well as personal planning considerations for caregivers and families. Financial Advisors, or a member of their team, must have the Chartered Special Needs Consultant designation to be able to offer this Service. Sports and Entertainment Sports and entertainment planning may involve reviewing employee benefits and retirement benefits, business planning, cash flow planning, assistance in navigating sudden wealth, guidance in developing an Investment Policy Statement and navigating around unknown career time horizon. Financial Advisors, or a member of their team, must have the Sports & Entertainment Accredited Wealth Management AdvisorTM (“SE-AWMATM”) designation to be able to offer this Service. Business Owner Planning Business owner planning focuses on transition planning for business owners, which may involve reviewing and discussing key business information relevant to a client's business transition planning, market attractiveness, as well as reviewing existing buy-sell agreements. In addition, the service may provide guidance on contingency planning, reviewing and discussing transition goals and priorities, pre-sale planning, identifying and comparing the suitability of potential ownership transition options, and related financial planning (which may be charged separately). Page 5 of 16 596410 (Rev 06 - 06/26)  Our advice under this program will include written recommendations and may be delivered through meetings and other means of communication with you and may also include written reports and materials that we prepare for you. At the end of the engagement, we will send you a Client summary letter (“Client Summary Letter”). We assume no responsibility for the accuracy or completeness of the information supplied by you that is used in the production of any written materials that are provided, if any. The accuracy or completeness of this information also may affect the results and any recommendations contained in our advice under this Agreement. Any written materials we provide are prepared by us based not only on your current financial situation and goals but also our understanding of current tax and other applicable laws and regulations and our advice and recommendations are as of the date the information is delivered, without an obligation to update this information after the term of this Agreement (unless we otherwise have agreed to provide updates). Generally, our engagement with you ends upon the delivery of the Services you have selected and our delivery of the Client Summary Letter to you. Unless otherwise specifically agreed to by us, neither we nor your FA shall have duties or obligations with respect to: the implementation of our advice or recommendation and, without limiting the generality of the foregoing; monitoring or updating any plan rendered during the course of the Services; and we shall have no duty or obligation to provide investment advisory or investment management services to you that are outside the scope of the Services discussed above. Some planning tools and software are generally available to WFAFN advisory clients and prospective clients at no additional charge. These tools are not intended or expected to replicate the Services described herein. However, depending on the specific circumstances of the client or prospective client, these standard tools could be sufficient for the particular needs of the client or prospective client. Before you engage us for the Services described herein, you should discuss with your FA how these Services are expected to be of value to you. When we charge a fee for Strategic Planning Services (Services) we act in the capacity of an investment adviser. We may also provide similar services free of charge in our capacity as a broker-dealer (which may be dependent on the relationship, and the scope and complexity of those needs). In deciding whether to obtain the Services for a fee, you should consider whether you prefer to enter into a fiduciary relationship with us under the Investment Advisers Act that is governed by a written services agreement outlining the services you will receive and the duration of the engagement. Throughout this document, references to Services mean those services subject to a fee and provided to you. Services Tailored to Individual Client Needs The advisory Services described in this document are tailored to you and designed to meet your needs. They are drawn from research and analysis we believe to be appropriate to your circumstances. Portfolio Management Services We act as portfolio manager for certain wrap fee advisory Programs that we offer to Clients and collect a fee for performing that service. We do not act as a portfolio manager for the Services described in this brochure. Assets Under Management As of December 31, 2025, we manage $191,518,732,783 of Client assets on a discretionary basis and $60,732,539,201 of Client assets on a non-discretionary basis. Fees and Compensation Fees for Services are described below and will vary based on the extent, nature and complexity of the advice requested and your financial needs and are therefore subject to negotiation. As a result, fees may vary from Client to Client and from different Financial Advisors based on these and other factors. In general, these fees ordinarily can range from $0 up to $25,000 for the engagement. We may elect to waive fees, in whole or in part, in our sole discretion, including but not limited to in connection with promotional efforts or participation in other advisory programs. Not all clients may have access to the same promotions, so it is possible that similarly situated clients will pay a different advisory fee. Additionally, in certain circumstances, the fee may be negotiated at a higher rate due to additional complexity. The specific fee of any Client will be included in the Client Agreement for the contracted Services. Page 6 of 16 596410 (Rev 06 - 06/26)  Core Planning Services (may include any of the following planning topics: cash flow, education, retirement, risk, and wealth planning). Minimum $2.5 MM Net Worth Core Planning Service Total $500,000 up to $2.5 MM Net Worth or minimum $250,000 household income Up to $5,000 Up to $10,000 Specialty Planning Services (may include core services within the planning fee). Minimum $2.5 MM Net Worth $500,000 up to $2.5 MM Net Worth or minimum $250,000 household income Not applicable Up to $25,000 Business Owner Planning (Certified Exit Planning Advisor ® designation required) Not applicable Up to $25,000 Divorce Planning (Certified Divorce Planning Analyst ® designation required) Not applicable Up to $25,000 Special Needs Planning (Chartered Special Needs Constultant ® designation required) SM Not applicable Up to $25,000 Sports & Entertainment Planning (Sports & Entertainment Accredited Wealth Management Advisor TM designation required) Total Fee for Engagement Total Fee up to $5,000 Total Fee up to $25,000 ($10,000 if Core Services only) You may elect to pay the full amount of the fee at the conclusion of this agreement or elect to pay 50% with the signing of the Agreement and 50% upon completion of the Services. Our fee does not include any updates to the advice that we provide under this Agreement. Fees can be paid by debiting a non-retirement account or you can pay by check. A portion of the fees for the Services described herein is paid to our FAs. We and your FA will not provide legal or accounting advice, and the fees payable by you under the Agreement for these Services cover only the services rendered by us and do not cover fees of your specialists. In this regard, we and your FA are not responsible for drafting or providing any legal or other documentation or taking any other action relating to or arising from implementation of our advice (subject to the considerations set forth in the following paragraph). The fees described above do not cover fees and expenses (such as advisory fees, and brokerage expenses) incurred in connection with the implementation of a plan or for the implementation of our advice and recommendations under the Services. You may elect to implement our advice and recommendations in whole or in part through us but are under no obligation to do so. In the event you elect to implement, you will be provided with an appropriate disclosure document describing the nature and extent of the services provided by us, the fees charged by us for those services and other related matters. The fees charged by us in connection with the implementation of our consulting services are in addition to the fees incurred by you under this agreement for fee-based personal planning and consulting services. We share a portion of these fees—whether advisory fees or brokerage expenses and commissions—with your FA. As a result, your FA has an incentive to recommend the implementation of the plan through us and has an incentive to recommend certain products or services over others based on the compensation they receive. We intend, however, to make all recommendations independent of such compensation considerations and based solely on our obligations to consider your objectives and needs. Page 7 of 16 596410 (Rev 06 - 06/26)  Financial Advisor Compensation Financial Advisors. Financial Advisors providing service to Clients from a WFAFN branch location receive a percentage of the revenue that the Firm collects from brokerage transactions and from ongoing fees collected from investment advisory accounts. Typically, a Financial Advisor’s product or service-based payout schedule (periodically adjusted by us at our discretion) increases with production and asset levels. Therefore, Financial Advisors have an incentive to make recommendations that result in their Clients adding funds to WFAFN advisory and brokerage accounts, and in selecting products and services that generate the most revenue and profit for themselves and the Firm. As a Financial Advisor’s production and asset levels increase, in addition to the Financial Advisor’s payout schedule increasing, the Financial Advisor may qualify for recognition trips. In cases where your Financial Advisor anticipates that you will have low trading activity in your account, the Financial Advisor has an incentive to recommend that you invest account assets in an advisory account which has ongoing Program Fees versus a brokerage account which has transaction-based fees. Financial Advisors also receive compensation based on the outstanding loan balances of PCL and Securities-Based Loan Programs from Wells Fargo Bank, N.A. Please refer to the “Margin Loans and Securities-Based Loan Programs” section for additional information on compensation related to PCL and Securities-Based Loan Programs. Client Referrals to Wells Fargo Bank, N.A. Financial Advisors receive referral compensation for client referrals to Wells Fargo Bank, N.A. for trustee or investment management services. The amount of compensation earned by the Financial Advisor for the referral depends on the value of account referred and the role the Financial Advisor will have in the client relationship after the referral. Ongoing involvement in the client relationship post referral typically results in recurring payments to the Financial Advisor based on a percentage of the client fees earned by Wells Fargo Bank, N.A. Moreover, Financial Advisors receive higher compensation for transactions involving client households that maintain greater amount of assets with us. Recruitment compensation is provided to Financial Advisors who join our Firm from another financial firm. This compensation, which varies by Financial Advisor, typically has the following components: an up-front payment; and a back-end bonus arrangement based on new client assets transitioned/gathered over a three-year period. This creates an incentive for the Financial Advisor to recommend the transfer of assets to the Firm to earn this compensation despite the fact that you may not have access to the same suite of products and/or services that you had at a predecessor firm. We offer certain Financial Advisors an optional loan when joining WFAFN. If the recruited Financial Advisor voluntarily chooses the loan option, the Financial Advisor must repay the loan to WFAFN. Financial Advisors who choose a loan option are offered the choice to voluntarily have the loan repaid via an automatic deduction from pay, or they may repay the loan via check. The amount of some incentive compensation paid to the Financial Advisor in these situations is impacted by the Financial Advisor meeting certain revenue or asset levels. This arrangement provides an incentive for the financial advisor to recommend that you deposit assets or establish accounts with WFAFN and WFAFN's interests will conflict with yours. We provide noncash compensation to Financial Advisors in the form of education meetings and recognition trips. Portions of these programs are subsidized by external vendors and affiliates, such as mutual fund companies, insurance carriers, or money managers. Consequently, product providers that sponsor and/or participate in educational meetings and recognition trips gain opportunities to build relations with our Financial Advisors, which could lead to sales of such product provider’s products. This creates a conflict of interest as the Financial Advisors could be influenced to recommend such provider's products in order to participate in these educational meetings and recognition trips. Financial advisors also receive promotional items, meals, entertainment, and other noncash compensation from product providers up to $100 per year for gifts per vendor and $1,000 per year for meals per vendor. Certain Financial Advisors are primarily compensated by salary determined between themselves and the practice group that they are associated with. In addition to their salary, a component of their compensation can also be based on percentage of the revenue that the practice group collects from brokerage transactions and from ongoing fees collected from investment advisory accounts, as well as being eligible for bonuses in addition to their salary. Under this compensation arrangement, the Financial Advisor has financial incentives to make recommendations that result in the client increasing assets held with us and our affiliates remain. Contact your Financial Advisor or their supervisor if you would like further information regarding compensation. Page 8 of 16 596410 (Rev 06 - 06/26)  IRA Rollovers – Conflicts and Incentives to Transfer Assets from Employer-Sponsored Qualified Retirement Plans to WFAFN Financial Advisors have an incentive to recommend that you roll over assets from an employer-sponsored Qualified Retirement Plan ("QRP"), such as a 401(k), to an Individual Retirement Account ("IRA") with us. If you are rolling over assets, you should carefully evaluate all choices which are typically available. We have a conflict of interest in connection with a rollover of your assets into an IRA and the investment of the assets with us as opposed to leaving the assets in your former employer's plan or electing another option. The conflict arises because we will likely earn no compensation if you were to leave the assets in your former employer's plan or transfer to your new employer's plan. In addition, the costs of maintaining and investing assets in an IRA with us will generally involve higher costs than the other options available to you. While we typically offer a broader range of investment options and services than an employer-sponsored QRP, there are no guarantees that the additional investment options will outperform your employer-sponsored QRP. Fees Paid by WFAFN Financial Advisors WFAFN Financial Advisor practice groups pay ongoing Platform, Technology, Operational, and Affiliation fees to WFAFN in order to access the financial products and services that WFAFN makes available to clients. The fees assessed are based on the practice group’s aggregate assets in brokerage and advisory accounts, number of advisors in their practice, technology packages, and other operational and administrative fees. At certain asset levels the rate of the administrative platform fee (which we assess the Financial Advisor groups in order to cover costs we incur in servicing client accounts) is lower if advisory account assets meet or exceed a certain percentage of total aggregate client account assets serviced by the practice group. This results in a conflict of interest, which could incentivize the Financial Advisors that comprise the practice group to recommend advisory accounts over brokerage accounts in order to maintain lower administrative platform fee rates. Termination Either you or we may terminate this Agreement at any time prior to the completion of the Services under this Agreement by written notice to the other party at the address specified in the Agreement (or such other address as specified by either party to the other in writing). If you terminate this Agreement early, you shall remain responsible for compensating us for the Services rendered up to the time of termination. If we terminate this Agreement, you shall not be obligated to compensate us for the Services hereunder, that have not yet been rendered. Termination of this Agreement shall not affect the liabilities and obligations of the parties arising from or in connection with the Services performed prior to such termination. This agreement also automatically will terminate upon the earlier of: the completion of the agreed upon Services under this Agreement or within 6 months of acceptance and approval of this agreement by the firm. This Agreement does not automatically renew and continuation of services after termination of the Agreement requires the execution of a new Strategic Planning Services agreement. Performance-Based Fees and Side-By-Side Management We do not charge performance-based fees in any of our investment advisory Programs. We do not have any side-by-side management situations. Types of Clients We provide the advisory services described in this brochure to individuals or trusts. Methods of Analysis, Investment Strategies and Risk of Loss The advice and recommendations associated with these Services are developed by your Financial Advisor using information, materials and/or tools provided by Wells Fargo. Certain planning tools may employ simulation techniques (e.g. Monte Carlo simulations, retirement income calculators) and complex statistical analyses to illustrate or present the likelihood of possible investment and financial outcomes. These tools are used as part of the planning process and inform the process; the outputs of these tools are not intended, in and of themselves, to be viewed as nor construed as, planning and advice. The outcomes rendered from these tools are hypothetical in nature and are no guarantee of future actual investment results or future income streams. The outputs of these tools can vary with each use and over time. Page 9 of 16 596410 (Rev 06 - 06/26)  You have the option whether to implement all or a part of our planning advice through us. If you choose to implement any portion of our planning advice through one of the advisory Programs that we offer, you will be provided with an additional disclosure document describing those services. Risk of Loss If you choose to implement any portion of your plan through us, please be aware that all investments shall be at your risk exclusively, and you must understand that we do not guarantee any return on the investments recommended or advised upon. Disciplinary Information We are both a broker-dealer and investment advisory Firm. The disciplinary events listed below are related to the activities of the broker-dealer, investment adviser or predecessor firms. For more information on broker/dealer related disciplinary events you may visit: http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/ Our investment advisory disciplinary history is available by going to: https://www.adviserinfo.sec.gov/ In January 2025, WFCS and WFAFN agreed to a settlement with the SEC regarding allegations that they failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder relating to their cash sweep program, specifically, their use of a bank deposit sweep program. The order found that WFCS and WFAFN did not adopt and implement reasonably designed policies and procedures that considered the best interests of clients when evaluating and selecting which cash sweep program options to make available to clients, including during periods of rising interest rates; or addressed the duties of WFCS and WFAFN financial advisors in managing client cash in advisory accounts, in willful violation of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. WFCS and WFAFN, without admitting or denying the findings, consented to a settlement that included a cease and desist order, censure, and civil money penalty of $28 million by WFCS and $7 million by WFAFN. In August 2023, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC (collectively, the “Firm”) agreed to a settlement with the SEC regarding allegations that from at least 2002 through December 2022, the Firm and its predecessor firms overcharged approximately 10,945 accounts of advisory clients, for accounts opened through 2014, for more than $26.8 million in advisory fees and failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the overbilling in willful violation of Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7 thereunder. Specifically, from at least 2002 through 2014, certain investment adviser representatives from Wells Fargo and its predecessor firms agreed to reduce the firms' standard, pre-set advisory fee rate for certain clients at the time these clients agreed to open accounts. The representatives made handwritten or typed changes on the clients' standard investment advisory agreements that reflected the reduced fee rate. However, in certain instances, the account processing employees at Wells Fargo and its predecessor firms failed to enter the agreed-upon reduced advisory fee rate into the firms' billing systems when setting up the clients' accounts. In 2022 and 2023, the Firm corrected the advisory fees to be charged to the accounts and issued payments for the overcharged advisory fees, plus interest, to the affected accountholders. Without admitting or denying the findings, the Firm consented to a settlement that included a cease and desist order, censure and civil money penalty of $35,000,000. In December 2021, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that for more than three years beginning in November 2016, the Firm failed to store 13 million records, pertaining to 8.2 million customers, related to its anti-money laundering Customer Identification Program (CIP) in the required non-erasable and non-writable “Write Once, Read Many” (WORM) format in violation of Exchange Act Rule 17A-4(F)(2)(II)(A) and failed to notify FINRA prior to using the non-WORM compliant storage platform in violation of Exchange Act rules 17A-4(F)(3)(V) and 17A-4(F)(2)(I). Without admitting or denying the findings, the firms consented to a settlement that included a censure and fine, jointly and severally, of $2,250,000. Page 10 of 16 596410 (Rev 06 - 06/26)  On February 27, 2020, the Securities and Exchange Commission ("Commission") entered an order against Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC, following the Firms' offers of settlement. The Commission found that, from April 2012 through September 2019, the Firms recommended that many retail investment advisory clients and brokerage customers buy and hold single-inverse exchange-traded funds ("ETFs") without having adequate compliance policies and procedures and without providing financial advisors proper training and supervision of single-inverse ETFs. The Commission found that, as a result, certain investment adviser representatives and registered representatives made unsuitable recommendations to certain clients. The Commission found that the Firms willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder, failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 203(e)(6) of the Advisers Act and failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 15(b)(4)(E) of the Exchange Act. The Firms consented, without admitting or denying the findings contained in the Order, to: cease and desist from committing or causing any violations and any future violations of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder; be censured; and jointly and severally pay a civil monetary penalty in the amount of $35,000,000. In 2018, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC elected to participate in the Securities and Exchange Commission's Mutual Fund Share Class Selection Disclosure Initiative ("SCSD Initiative"). The SCSD Initiative provided investment advisers with the opportunity to voluntarily self-report to the SEC's Division of Enforcement possible securities law violations related to the adequacy of their disclosures concerning mutual fund share class selection and fees received pursuant to Rule 12b-1 under the Investment Company Act of 1940. As part of the SCSD Initiative, the Firms reviewed disclosures and activities related to mutual fund share class selection within advisory programs. At the conclusion of the SCSD Initiative, the Firms jointly and severally consented to a settlement agreement alleging violations of Sections 206(2) and Section 207 of the Investment Advisers Act of 1940 and entry of an order under which the Firms were censured, agreed to cease and desist from committing further violations, and agreed to pay disgorgement and prejudgment interest totaling $17,363,847.29. The SEC did not impose a fine or civil monetary penalty in recognition of the fact that the Firms self-reported. On December 21, 2016, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that the Firms failed to maintain approximately one million electronic brokerage records in non-erasable and non-rewritable format, which is intended to prevent the alteration or destruction of broker-dealer records stored electronically. The findings also stated that for approximately 1.5 million accounts, the Firm failed to preserve customer account form templates containing the terms and conditions related to the opening and maintenance of accounts, failed to retain certain communications and failed to notify FINRA at least 90 days prior to using new storage media to store electronic broker-dealer records. FINRA also found that the Firms failed to implement an audit system for those records, failed to provide its third party vendors full access to the storage systems, failed to implement an adequate supervisory system and failed to enforce written procedures. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,500,000. The Firms also consented to a review of its policies and procedures. On December 5, 2016, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that the Firms failed to establish, maintain and enforce reasonable supervisory systems for the use of consolidated reports generated by their registered representatives through available applications. The findings stated that these applications allowed the Firms’ representatives to manually enter information regarding customers’ external accounts, assets and liabilities into centralized table which the Firms maintained. This information would then be used to populate reports, including those that would be sent to the Firms’ customers. FINRA found that the Firms did not have systems in place to review the contents of the reports, including information about customer holdings away from the Firms. In addition, the Firms’ supervisory systems and procedures were inadequate because there was no mechanism allowing representatives to designate which reports were actually provided to customers and the system could not distinguish between draft reports and completed reports that were sent to customers, which should have been subject to the Firms’ supervisory systems designed to review customer communications. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,000,000. Page 11 of 16 596410 (Rev 06 - 06/26)  Other Financial Industry Activities and Affiliations Unless otherwise stated as the case, the investment advisory services offered and the underlying stock, bonds, mutual funds and other securities bought or sold through us are not deposits of any bank and are not insured or otherwise protected by the Federal Deposit Insurance Corporation (“FDIC”) or another government agency. They are not obligations of any bank or any affiliate of us; are not endorsed or guaranteed by Wells Fargo, WFAFN, or any bank or any affiliate of Wells Fargo; and involve investment risk including possible loss of principal. Cash balances in Client Accounts may be held in a depository product sponsored by Wells Fargo Bank, N.A. Wells Fargo Advisors Financial Network, LLC is not an FDIC-insured depository institution; FDIC deposit insurance only protects against the failure of an insured depository institution. Banking products and services provided by Wells Fargo Bank, N.A. Member FDIC. WFAFN is a national securities firm providing investment and other financial services to individual, corporate and institutional Clients. We are a registered broker-dealer and investment adviser. Accounts are carried by WFCS, a qualified custodian. WFCS is an affiliate owned indirectly by Wells Fargo. WFAFN and WFCS are members of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). WFCS may also route transactions through its affiliate, Wells Fargo Securities, LLC. Our obligations and commitments do not extend to any affiliated bank or thrift, and any such bank or thrift is not responsible for securities we sell or purchase. As a general matter, unless otherwise stated, we may be a principal or engaged in underwriting securities for which we are providing broker, advisory or other services to our Clients. We may also purchase those securities from an affiliate or sell them to an affiliate. In addition, we or our affiliates may act as an investment adviser to issuers whose securities may be sold to you. From time to time, a bank or thrift affiliated with us may lend money to an issuer of securities underwritten or privately placed by us. The prospectus or other offering documentation provided in connection with such underwriting or private placement will disclose to the extent required by applicable securities laws: (i) the existence of any material lending relationship by any affiliate of ours with such an issuer and (ii) whether the proceeds of an issuance of such securities will be used by the issuer to repay any outstanding indebtedness to any of our affiliates. We have a number of related persons who may provide investment management and related financial services to our Program Clients. The advisory services these investment advisers offer are described more fully in their Disclosure Documents and/or Form ADV, Part 2A. The identity of these related persons and summary of the products and services follows. • Wells Fargo also provides retail brokerage and investment advisory services through Wells Fargo Advisors (“WFA”). • Wells Fargo Investment Institute, Inc. ("WFII") (known prior to November 1, 2014 as Alternative Strategies Group, Inc. and before that as Wachovia Alternatives Strategies, Inc.) is a registered investment adviser and wholly owned subsidiary of Wells Fargo Bank, N.A. that provides advisory services and research to WFA and WFAFN. We and our affiliates may give advice and take action in the performance of our duties to you that differs from advice given, or the timing and nature of action taken, with respect to other Program Clients and/or Clients in other advisory Programs. Additionally, we and our affiliates, from time to time, may not be free to divulge or act upon certain information in their possession on behalf of investment banking or other Clients. Material Relationships with Allspring Wells Fargo sold the Wells Fargo Asset Management business in 2021 and the new owners renamed the business Allspring Global Investments. The Wells Fargo Asset Management business was wholly owned by Wells Fargo prior to the transaction and included the following companies: Wells Capital Management Incorporated; Wells Fargo Funds Management, LLC; Wells Fargo Asset Management (International), LLC; Wells Fargo Funds Distributor, LLC; and, Galliard Capital Management, Inc. These companies, which are no longer related persons of WFAFN, served as adviser, sub-adviser, and distributor of the Wells Fargo Funds and certain of the companies managed separately managed account strategies offered through WFAFN. Page 12 of 16 596410 (Rev 06 - 06/26)  Allspring Global Investments (“Allspring”) is the trade name used by the asset management businesses of Allspring Global Investments Holdings, LLC. This group of companies includes Allspring Funds Management, investment adviser to mutual funds within the Allspring family of funds, Allspring Funds Distributor, LLC, the principal underwriter of Allspring mutual funds, and Allspring Global Investments, LLC, a model portfolio strategy provider and an investment adviser to pooled investment vehicles and separately managed accounts. Wells Fargo has no role in the management of Allspring. However, Wells Fargo retains less than a 10% equity ownership interest in Allspring and has continued to provide certain non-advisory transition services to Allspring for a fee since the close of the sale. WFCS also receives compensation from Allspring for the distribution, administrative and operational services that we provide to the Allspring mutual funds. Although Allspring is not a related person of WFAFN, WFAFN and its related persons continue to benefit from the sales of these products to a greater extent than the sale of other third-party products in which we do not have a similar financial interest. Wells Fargo’s equity ownership in Allspring and the agreements by WFCS and its related persons to provide ongoing services to Allspring for a fee provide us with a financial incentive to continue to recommend to our clients products that are managed and distributed by Allspring, including mutual funds, sweep vehicles, and separately managed account or model portfolio strategies. WFII charges Allspring research access fees for investment research services that WFII provides to Allspring. Allspring manages the Managed DSIP, Managed DSIP II, ESG Managed DSIP, Current Equity Income, and Income Multi Asset Portfolio strategies offered through the Personalized Unified Managed Account advisory program (collectively, the “Equity Income Strategies”) utilizing information derived, in part, from certain of the research services. The research access fees are calculated based on the assets invested in the strategies, meaning that WFII earns more money when more assets are invested in the strategies. The research access fees are assessed at rates that result in WFII receiving fees that are equivalent to substantially all of the Manager fees assessed in conjunction with the Income Multi Asset Portfolio, the Current Equity Income Strategy, and the Managed DSIP strategy, and approximately half or greater of the Manager fees assessed for the Managed DSIP II strategy and the ESG Managed DSIP strategy. The fee paid to WFII is for research services WFII provides to Allspring, including: investment research that WFII provides to Allspring; and access to certain WFII research analyst teams, strategists, and associates to discuss the research and/or obtain additional research commentary on covered names, insights into sectors, etc. (collectively “Research Services”). While WFII does not provide the Research Services to other third- party Managers for utilization in managing strategies, WFII does provide the Research Services to its affiliates, WFCS and WFAFN, who in turn, may utilize the Research Services to manage strategies and who provide the investment research at no cost to WFCS and WFAFN advisory clients, WFCS and WFAFN brokerage customers, and prospective clients and customers for their individual use. As such, investors in the Equity Income Strategies are indirectly paying for investment research that others receive at no cost, and that those same investors could receive from WFCS or WFAFN for their individual use outside of the Equity Income Strategies at no cost under other circumstances. Similar investment research may be available in the marketplace at no cost or for materially lower fees than are being charged to Allspring in conjunction with the Equity Income Strategies. WFII’s receipt of a research access fee in conjunction with the Equity Income Strategies creates a material conflict of interest since it results in WFII, an affiliate of WFAFN, earning more revenue when investors follow a WFAFN recommendation to invest in the Equity Income Strategies than WFAFN, WFII or their affiliates would earn if investors followed a recommendation from WFAFN to invest in any of the other Model Manager strategies available through the Personalized UMA Program as WFAFN and its affiliates earn no comparable additional revenue for investments in other Model Manager strategies. WFAFN seeks to mitigate this conflict and its associated implications through disclosure, management of the financial incentive for financial advisors to recommend the Equity Income Strategies, and evaluation of the total costs of investing in the Equity Income Strategies relative to other Model Manager strategies. You should carefully consider the research access fee that is retained by WFII and our related conflict of interest when evaluating whether to invest in the Equity Income Strategies. The Equity Income Strategies are available through Wells Fargo Bank, N.A., including through Wealth & Investment Management Trust Services, and no research access fee is applied to assets invested in the Equity Income Strategies when the assets are custodied at Wells Fargo Bank, N.A. The research access fee is also not applied to assets invested in ERISA accounts. Page 13 of 16 596410 (Rev 06 - 06/26)  Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Our Associates are subject to a Code of Ethics that is designed to ensure our business activities are performed with the highest possible standards of ethics and business conduct, and to comply with all applicable laws, rules, and regulations that govern our businesses. Key requirements of our Code of Ethics are summarized below, and you may obtain a complete copy through your FA. • Conduct all aspects of Wells Fargo’s business activities in an honest, ethical, and legal manner, and in accordance with all applicable laws, rules, and regulations and our policies and procedures. • Provide accurate and complete information in dealings with Clients and others, including disclosure of conflicts of interest when they exist. • Prepare and maintain accurate business records. • Refrain from improper disclosure or misuse of confidential Client information and material, non-public information. Wells Fargo protects the private, personal, and proprietary information of Clients and others. • Avoid conflicts of interest in personal and business activities. • Rules specific to personal trading. Participation or Interest in Client Transactions With regards to our Strategic Planning Services, no specific investment recommendations are made and as a result, no Client transactions occur as part of these Services. You have the choice to implement all or a portion of our advice and recommendations through us, however implementation of our advice and recommendations is not a part of the contracted Services. We have certain restrictions, internal procedures and Client disclosures regarding conflicts of interest that we may have with respect to our participation or interest in Client transactions. We communicate our policies and procedures related to participation in Client transactions to our Associates through our compliance policies and procedure manuals and Program-specific policy guidelines. Personal Trading We maintain policies and procedures to mitigate conflicts of interest between transactions in our Associates’ personal investment Accounts, including Accounts of their immediate family members and transactions in our Clients’ Accounts. To ensure Associate trading requirements are observed, certain Associate trading activity is subject to pre-approval. All Associates are subject to regular review by their supervisors, independent oversight by our Compliance Department, and systemic controls that automatically restrict entry of certain orders and generate related surveillance reporting. Brokerage Practices Potential conflicts may arise between your interests and ours in executing transactions through us as a broker-dealer if you choose to implement all or part of our planning or our consulting advice through us. If you choose, at your sole discretion, to implement all or part of our planning or consulting services advice with us and execute transactions through us, we will act as a broker-dealer, not an investment adviser, unless we have otherwise agreed with you in writing. As a broker-dealer, we will execute transactions as agent or principal and will charge commissions, mark-ups, transaction fees, and/or other charges. These charges are in addition to the fees for this program. If you choose to implement our planning or consulting advice through a WFA brokerage or advisory Account, you should review the terms of the Client Agreement, Regulation Best Interest Disclosure, and if applicable Form ADV, Part 2A. These documents are provided at Account opening or upon request to your Financial Advisor. The FA who delivers the advice and recommendations under this program is a registered representative of ours and thus will receive a portion of the compensation paid to us in connection with the execution of transactions. This compensation is in addition to the compensation we and the FA receive in connection with preparing and presenting any planning or consulting services. Products recommended by us may include proprietary products of us or our affiliates. You should note that we have an incentive to recommend proprietary products because we or our affiliates earn more compensation from the sale of these products than from the sale of non-proprietary products. Page 14 of 16 596410 (Rev 06 - 06/26)  Review of Accounts The Services provided under this program is not ongoing advice. After the termination of your Agreement for the Services, you may request to continue advice and recommendations by completing a new Agreement for the Services with us and you may be subject to an additional fee. Client Referrals and Other Compensation From time to time, we initiate incentive programs for our Associates, including FAs. Incentive programs compensate our Associates and FAs for attracting new assets and Clients, referring business to our affiliates (such as referrals for banking services and accounts, mortgages, lending, trusts, or insurance services) or other FAs, promoting investment advisory services and promoting green initiatives (such as raising Client awareness of paperless options). We may also initiate programs that reward FAs who meet total production criteria, length of service requirements, participate in advanced training and improve Client service. FAs who participate in these incentive programs may be rewarded with cash and/or non-cash compensation, such as deferred compensation, bonuses, training symposiums and recognition trips. Portions of these programs may be subsidized by external vendors and/or our affiliates, such as mutual fund companies, insurance carriers, or investment advisers. Therefore, FAs and other Associates may have a financial incentive to recommend the programs and services included in these incentive programs over other available products and services we offer. We may also enter into arrangements with other persons to whom we pay compensation for referrals to our advisory Programs. This compensation is generally in the form of a percentage of the fees described in the Program contracts. The details of such arrangements and the amount of compensation will be described in a separate disclosure provided at the time of such referrals. From time to time, we compensate Associates other than FAs for referrals of possible Clients to the Programs. Our FAs, not the referring Associate, will make the actual presentation and solicitation of these services. The referral compensation takes the form of a payment to the Associate of a percentage of the fees described in the Programs contracts and results in no additional fees to you or other Clients. Wells Fargo is a full-service financial services firm with many affiliates. Wells Fargo encourages its subsidiaries to use the products and services offered by affiliated firms, when appropriate. During the course of annual business planning, business with our affiliates is included in establishing our sales goals. As a result, we may have an incentive to hire affiliate service providers for our advisory Programs. We may recommend affiliated mutual funds to Program Clients, and may hire other affiliates to provide trade execution, clearing, and platform administration services for the Programs. We intend, however, to make all recommendations independent of any such goals and based solely on our obligations to consider your objectives and needs. Advisory Earnings Sharing Arrangement Certain financial advisors have entered into an earnings sharing arrangement with a private entity that creates an incentive to recommend advisory accounts and services, including recommending that you contribute additional assets to your advisory accounts. Specifically, certain Financial Advisers have agreed to contribute a portion of their advisory earnings to the private entity, in exchange for which they will receive cash consideration and equity ownership interests in the private entity or a related entity. These cash payments and equity ownership interests, for certain Financial Advisers, are subject to a hurdle, whereby if they reach a certain earnings threshold, these incentives are increased. Separately, Financial Advisors could have an incentive to recommend advisory accounts/ trades over brokerage if they believe that, by doing so, they can receive additional equity ownership interests or other consideration from the private entity. The arrangements described above create a conflict of interest for the financial adviser, and in turn, the firm, as the result will be additional revenue. We mitigate this conflict of interest by enforcing and supervising policies and procedures that require recommendations regarding account types and in respect of the provision of advisory services to be made in the client's best interest. Custody If you elect to open an Account with us to implement all or a portion of our advice or recommendations, we will have custody of Client funds and securities for Program Accounts. Accounts are carried by WFCS, a qualified custodian. WFCS is an affiliate owned indirectly by Wells Fargo. You will receive brokerage statements directly from WFCS at least quarterly. Page 15 of 16 596410 (Rev 06 - 06/26)  Investment Discretion The Services described in this brochure do not include the management or supervision of any securities accounts; therefore, with respect to the Services described herein, we do not have discretionary management authority, nor do we have any responsibility for the management or supervision of securities accounts on either a discretionary or non-discretionary basis. Voting Client Securities We do not vote on Client securities as part of these Services. Financial Information We have no financial condition that is likely to impair our ability to meet our contractual commitments to you. Page 16 of 16 596410 (Rev 06 - 06/26)