Overview

Headquarters
Minneapolis, MN
Average Client Assets
$2.0 million
Minimum Account Size
$25,000
SEC CRD Number
6363

Fee Structure

Primary Fee Schedule (AMERIPRISE MANAGED ACCOUNTS AND FINANCIAL PLANNING SERVICE)

MinMaxMarginal Fee Rate
$0 and above 2.00%

Minimum Annual Fee: $100

Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $20,000 2.00%
$5 million $100,000 2.00%
$10 million $200,000 2.00%
$50 million $1,000,000 2.00%
$100 million $2,000,000 2.00%

Clients

HNW Share of Firm Assets
55.79%
Total Client Accounts
2,424,045
Discretionary Accounts
1,522,835
Non-Discretionary Accounts
901,210

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection, Educational Seminars

Regulatory Filings

Additional Brochure: AMERIPRISE FINANCIAL PLANNING SERVICE - CONSULTING SERVICE SUPPLEMENT (2026-03-27)

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Consulting Services Supplement to Ameriprise Financial Planning Service Client Disclosure Brochure (Form ADV Part 2A) dated March 2026 Update dated March 2026 This is a supplement to information contained in the Brochure and replaces any previous updates. All information contained in the Brochure remains the same except the language noted below. To help you better understand this information, headings and subheadings in this supplement generally coincide with those in the Brochure. If there is any conflict between the supplement and the Disclosure Brochure, the supplement supersedes the Brochure. An additional service option, described below, is available from Ameriprise Financial Planning Service on a limited basis only through Brostrom and Berlin Wealth Management. Page 3 under the heading “Additional financial planning areas” [Add the following language] Consulting Service This service may provide information, analysis and advice in long-term business planning matters. These matters may include: Business and Entity valuation of: > Interests in sole proprietorships, general and limited partnerships, limited liability entities, S corporations and C corporations > Employee stock ownership trusts and plans > Derivative instruments and/or ownership interests such as stock options and warrants > Debt instruments and/or ownership interests such as notes, bonds and/or convertible debt. These valuations may be used by clients in support of long-term business planning, merger and acquisition transactions, and tax and regulatory filings. However, Ameriprise Financial Services and Brostrom and Berlin Wealth Management do not provide tax or legal advice or filing services. Brostrom and Berlin Wealth Management’s services can provide information related to the general tax treatment of financial services products, the general tax implications of a transaction, or of establishing a certain type of ownership or product. See the “Income tax planning” subsection of the “Additional financial planning areas” in the Disclosure Brochure. Executive compensation programs Analysis and advice that may be used by clients and their legal and tax advisers to develop and implement executive compensation programs, including programs involving the awarding of compensation based on increases in a business entity’s value and/or involving the transfer of ownership interests in a business entity. Expert witness testimony May be provided in support of the Business and Entity valuation and/or Executive compensation programs Page 8, under the heading “Fees and Compensation” [Add the following language after the last paragraph in the section] One half of the fee is payable when you select the Consulting Service option and sign the Agreement. The remainder of the fee is due when you receive the analysis and written advice. Please keep this Supplement with your copy of the Brochure, service agreement and amendment. 1356 AS (3/26)

Additional Brochure: AMERIPRISE FINANCIAL PLANNING SERVICE - DIVORCE FINANCIAL ANALYSIS SUPPLEMENT (2026-03-27)

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Divorce Financial Analysis Supplement to Ameriprise® Financial Planning Service Client Disclosure Brochure (Form ADV Part 2A) Dated March 2026 Update Dated March 2026 Divorce Financial Analysis is offered in addition to those services described in the Ameriprise® Financial Planning Service Client Disclosure Brochure (Form ADV Part 2A). Divorce Financial Analysis is available to two types of clients: Individuals and couples in divorce proceedings, or attorneys who wish to engage a financial advisor to provide Divorce Financial Analysis for use in their clients’ cases. All information contained in the Brochure remains the same with exception of the language noted below. To help you better understand this information, headings and subheadings in this update generally coincide with those in the Brochure. If there is any conflict between this update and the Brochure, the update supersedes the Brochure. Under the heading “AFPS planning goals” (On page 2, the following language replaces the existing paragraph.) Your financial advisor reviews financial data and other information related to the divorce and uses it to prepare analysis to help assess the financial impact of the divorce settlement options under consideration. Divorce Financial Analysis does not require the financial advisor to review the financial fundamentals. Under the heading “Additional financial planning areas” (On page 3, the following language supplements the existing sections) Divorce Financial Analysis — providing analysis to help assess personal finances during a divorce. With Divorce Financial Analysis, your advisor does not recommend a preferred divorce settlement option or include recommendations regarding ownership or division of assets and liabilities. Any documents, analyses and other work products, and any other statements made by a financial advisor in providing the divorce financial analysis service are not protected by privilege and may be discoverable by another party to the proceeding. Individuals considering divorce should consult with an attorney regarding such issues. The attorney, not the financial advisor, is the divorcing individual’s legal advocate during divorce proceedings. This service may include expert witness service if the financial advisor is called to provide testimony regarding the process used to prepare a divorce financial analysis and its contents. If called to testify, the financial advisor may charge you additional fees for preparation for, attendance at and participation in a divorce proceeding. Financial advisors who offer Divorce Financial Analysis are required to complete specialized training that focuses on the application of financial planning to personal finances during a divorce. Not all Ameriprise financial advisors are authorized to offer Divorce Financial Analysis. Under the heading “Initial Recommendations” (On page 3, the following language replaces the first three paragraphs) Neither Ameriprise Financial Services nor the financial advisor will recommend a preferred divorce settlement option or provide recommendations regarding ownership or division of assets and liabilities. In a Divorce Financial Analysis, the financial advisor will work with you to identify and prioritize objectives and gather and analyze information. Your financial advisor will make best efforts to perform an analysis and deliver to you an illustration of the settlement offers proposed by the divorcing individual, their spouse or their designated agent, and an illustration of the settlement option you select. The financial advisor may, upon your request, provide the following analyses as an Individual Service within Divorce Financial Analysis: • Alimony buyout analysis • Pension valuation • Facilitation of the process of preparing a QDRO (the advisor may not prepare the QDRO) Provision of any of the above as Individual Services will not include the illustration of settlement offers described in the preceding paragraph. Shortly after you sign the AFPS Agreement to receive Divorce Financial Analysis, you will receive a confirmation of services that reflects: • the AFPS fee for Divorce Financial Analysis, based on your financial advisor’s initial assessment of the complexity of the analysis required; the date your engagement began; and the final date of the engagement. • • The 180-day timeframe for providing initial recommendations referenced in the confirmation of services does not apply to Divorce Financial Analysis. If your need for Divorce Financial Analysis changes over the course of the engagement, you and your financial advisor should discuss whether your AFPS fee will need to change. Under the heading “Ongoing relationship” (On page 4, the following language replaces the existing section) Although Ameriprise Financial Planning Service is an ongoing service, Divorce Financial Analysis is not ongoing. At the completion of Divorce Financial Analysis service, you should terminate the AFPS Agreement upon final consultation or when your divorce settlement is final. See “Termination of AFPS.” If you are a divorcing individual who wishes to engage your financial advisor for financial planning after the completion of the Divorce Financial Analysis service, you may do so under the same agreement you signed to receive Divorce Financial Analysis. Talk with your advisor about this option. The AFPS Agreement that you signed to receive your Divorce Financial Analysis is effective the day that Ameriprise Financial Services processes the Agreement (“Effective Date”), which may be different than the date(s) of your AFPS Agreement signed by you and your financial advisor. Your Divorce Financial Analysis service begins on the Effective Date and ends the day you terminate it. If you do not receive Divorce Financial Analysis, you are entitled to a refund of your AFPS Fee. Please contact your financial advisor or call 800.862.7919. Under the heading “Changing your planning goals” (On page 4, this section is deleted) Under the heading “Implementation of your financial planning recommendations” (On page 4, this section is deleted) Under the heading “Fees and Compensation” (On page 7, the following language is inserted after the fifth paragraph) The AFPS fee for Divorce Financial Analysis is based on the initial assessment of the complexity of the financial issues in the divorce and the analysis needed. If the scope of the analysis changes, you and your financial advisor should discuss whether the AFPS fee for your Divorce Financial Analysis also needs to change. If you agree that the fee should increase, your financial advisor will ask you to sign a Fee Amendment to the AFPS Agreement. Under the heading “Types of Clients” (On page 12, the following paragraph replaces the existing language) Divorce Financial Analysis is designed for: (1) An individual who is negotiating a divorce settlement. (2) A married couple, in certain circumstances, who is committed to an amicable divorce settlement. (3) An attorney who wishes to engage a financial advisor to produce Divorce Financial Analysis for the attorney’s use in negotiating their clients’ cases. Divorce Financial Analysis is generally not appropriate for a client who is merely contemplating divorce or for a client whose divorce settlement is complete; financial planning is generally more appropriate for clients in those situations. Under the heading “Terms and Conditions of Your AFPS Agreement,” under the subheading “Disclosure of Interest and Capacity” (On page 52, the following new section is added at the end) Indemnification If your financial advisor is providing Expert Witness Service related to Divorce Financial Analysis, you agree to indemnify your financial advisor and hold him or her harmless against any and all claims resulting from unintentional errors or omissions made by him or her during this testimony. Please keep this update with your copy of the Brochure, service agreement and amendments. © 2026 Ameriprise Financial, Inc. All rights reserved. 94003-DFA (3/26)

Additional Brochure: AMERIPRISE FINANCIAL PLANNING SERVICE - LIMITED CONSULTING SERVICES SUPPLEMENT (2026-03-27)

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Limited Consulting Service Supplement to Ameriprise® Financial Planning Service Client Disclosure Brochure (Form ADV Part 2A) Dated March 2026 Update Dated March 2026 Limited Consulting Services are offered in addition to those services described in the Ameriprise® Financial Planning Service Client Disclosure Brochure (Form ADV Part 2A). All information contained in the Brochure remains the same with exception of the language noted below. To help you better understand this information, headings and subheadings in this update generally coincide with those in the Brochure. If there is any conflict between this update and the Brochure, the update supersedes the Brochure. Under the heading “Financial Fundamentals” (On page 2, add the following language to the end of the last paragraph.) The review of fundamentals is only provided as part of Limited Consulting (defined below) as needed. Under the heading “Additional financial planning areas” (On page 3, add the following language) Limited Consulting Services (“Limited Consulting”) - applying strategies to help you with in depth analysis or advice on a single issue for which you are requesting financial advice and for which you do not desire an ongoing AFPS engagement. For Limited Consulting, the scope of the services you receive will be agreed upon by you and your financial advisor and reflected in an engagement letter you receive from your advisor. Depending on the engagement, the advisory services you receive will be tailored to your needs and thus may not include each step of the financial planning process, such as written recommendations or review of the fundamentals of your financial situation. Neither Ameriprise Financial Services nor your financial advisor will have discretionary investment authority when providing Limited Consulting. Your financial advisor will not provide advice on assets held outside of Ameriprise Financial Services, except where we are providing you guidance related to your Outside Workplace Retirement Plan as further described in this Brochure, and is not permitted to serve as a trustee for you, as an AFPS and Consulting Service client. Under the heading “Ongoing relationship” (On page 4, add the following language) Limited Consulting is not an ongoing relationship. Your engagement will terminate upon final consultation with you or at the conclusion of the specified engagement, as noted in your engagement letter. If you desire ongoing financial planning services, an AFPS engagement may be more appropriate for you. Under the heading “Fees and Compensation” (On page 8, replace the second paragraph with the following language) Your fee for Limited Consulting is negotiable and there is no assurance that similarly situated clients will be assessed comparable fees. Your financial advisor will explain the fee and the factors considered in calculating the fee before asking you to sign the engagement letter. The fee you can expect to pay will be a quoted as a flat fee and is based on your financial advisor’s initial estimate of the total number of hours required to perform the work multiplied by the financial advisor’s hourly rate. Your financial advisor’s hourly rate is based on various factors including education, certifications and industry experience. Your advisor may work with you to adjust the initial estimate during the engagement based on the actual number of hours required to perform the work. Limited Consulting is not available as part of a consolidated advisory fee relationship offered in the Ameriprise Managed Account and Financial Planning Disclosure Brochure. Please keep this Supplement with your copy of the Brochure, service agreement and amendments. © 2026 Ameriprise Financial, Inc. All rights reserved. 94003-CSLT (03/26)

Additional Brochure: AMERIPRISE FINANCIAL PLANNING SERVICES (2026-03-27)

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About Ameriprise A tradition of commitment since 1894. A legacy of putting clients first. For more than 130 years, Ameriprise has been committed to putting our clients' needs first. Our advisors develop ongoing one-to-one relationships and take time to understand what's truly important to clients and their families. We offer a comprehensive approach to financial planning that helps our clients feel confident, connected and in control of their financial life. Ameriprise® Financial Planning Service Client Disclosure Brochure (Form ADV Part 2A) March 2026 This Brochure provides information about the qualifications and business practices of Ameriprise Financial Services, LLC. If you have any questions about the contents of this Brochure, please consult with your financial advisor or contact us at 800.862.7919 between 7 a.m. and 6 p.m. Central time. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Ameriprise Financial Services, LLC’s California insurance license number is 0684538. Additional information about Ameriprise Financial Services, LLC also is available on the SEC’s website at adviserinfo.sec.gov. Ameriprise Financial Services, LLC 70400 Ameriprise Financial Center Minneapolis, MN 55474 ameriprise.com Financial Planning | Retirement | Investments | Insurance | Banking Ameriprise Financial 70400 Ameriprise Financial Center, Minneapolis, MN 55474 This Brochure provides information about the qualifications and business practices of Ameriprise Financial Services, LLC and the Ameriprise Financial Planning Service. If you have any questions about the contents of this Brochure, please consult with your financial advisor or contact us at 800.862.7919 between 7 a.m. and 6 p.m. Central time. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Investment advisory services and products are made available through Ameriprise Financial Services, LLC, a registered investment adviser. Ameriprise Financial Services, LLC. Member FINRA and SIPC. Additional information about Ameriprise Financial Services, LLC also is available on the SEC’s website at adviserinfo.sec.gov. © 2026 Ameriprise Financial, Inc. All rights reserved 94003 AM (03/26) 8 Brochure highlights Thank you for working with Ameriprise Financial to help you meet your financial goals. For more than 130 years, we’ve earned our clients’ trust by providing them with personalized financial advice that meets their needs today and tomorrow. Please read this entire Ameriprise® Financial Planning Service Client Disclosure Brochure (“Brochure”) for more information about the following disclosure subjects At Ameriprise, you and your financial advisor begin by considering what’s most important to you. Once we understand your unique needs, your financial advisor builds a comprehensive plan that considers all aspects of your financial life — your priorities, risk tolerance and time horizon — to help you grow and preserve your wealth over your lifetime. • When you enter an Ameriprise® Financial Planning Service (“AFPS”) relationship, an Ameriprise financial advisor (“financial advisor”) will provide you with ongoing financial planning analysis and written recommendations that align with your goals and needs. See the “Advisory Business” section of this Brochure. • You will pay a financial planning fee (“AFPS fee”) when you purchase AFPS. See the “Fees and Compensation” section of this Brochure. We’re providing you with this information to explain our financial planning services in detail, so you’ll know what to expect from your financial advisor and Ameriprise and how to make the most of your financial planning relationship. It contains essential disclosures about our affiliates, how we do business, and the terms and conditions of your financial planning service agreement. Please take time to read this important information. You can also always find a current copy at ameriprise.com/disclosures, under “General Disclosures.” • AFPS is an ongoing service. Each year, you will receive written recommendations and pay a To support your financial planning services, we strive to provide an unmatched digital experience, with the ability to manage your financial life safely and securely. Our award-winning website and mobile app allow you to track your financial goals in real time and stay connected to your advisor between meetings. financial planning fee. The service will automatically renew on an annual basis until you decide to terminate the AFPS Agreement. See the “Ongoing Relationship” subsection of the “Advisory Business” section of this Brochure. • If you are not satisfied with AFPS, you may terminate your AFPS Agreement. See the “Termination of AFPS” subsection of the “Fees and Compensation” section of this Brochure. If you have questions about any of our services, including financial planning, please feel free to reach out to your financial advisor or call us directly at 800.862.7919 between 7 a.m. and 6 p.m. Central time. Thank you again for working with Ameriprise. We’re committed to providing premium solutions and services to help you achieve your financial goals so you feel confident and in control of your financial life. • If you invest in an Ameriprise investment advisory account (“Managed Account”), you will pay an ongoing asset-based fee (“Asset-based Fee”) for investment advice on the assets in those accounts and related services. This is a wrap fee and is separate from, and in addition to, any AFPS fee you pay. See the “Other advisory services” subsection of the “Advisory Business” section of this Brochure. • Deana Smythe Healy, CFP® Vice President Ameriprise Financial Services, LLC If you purchase investment products from us, Ameriprise Financial Services, our affiliates, and your financial advisor will receive revenues in addition to the financial planning fees you pay. You will incur time-of-sale expenses such as commissions or sales loads in a transaction fee-based brokerage account and any ongoing expenses associated with those products such as investment management fees on mutual funds. These fees and expenses are separate from, and in addition to, any AFPS fee you pay. See the “Other Financial Industry Activities and Affiliations” and “Client Referrals and Other Compensation” sections of this Brochure. • Ameriprise Financial Services does not monitor the day-to-day performance of your specific investments. See the “Implementation of your financial planning recommendations” subsection of the “Advisory Business” section of this Brochure. • Ameriprise Financial Services cannot guarantee future financial results. See the “Implementation of your financial planning recommendations” subsection of the “Advisory Business” section of this Brochure. • Some aspects of our business may pose conflicts of interest for us, our affiliates and our financial advisors. See the “Other Financial Industry Activities and Affiliations” and “How we get paid” sections of this Brochure. • Regulatory proceedings may have occurred affecting Ameriprise Financial Services. See the “Disciplinary Information” section of this Brochure for a detailed explanation of these and other matters. • We will notify you of material changes to this Brochure and offer you a revised copy to replace any previous version. See the “Understand that our financial planning service will continue until you terminate it” subsection of “How to make the most of your financial planning relationship” in the “Advisory Business” section of this Brochure. Brochure highlights Thank you for working with Ameriprise Financial to help you meet your financial goals. For more than 130 years, we’ve earned our clients’ trust by providing them with personalized financial advice that meets their needs today and tomorrow. Please read this entire Ameriprise® Financial Planning Service Client Disclosure Brochure (“Brochure”) for more information about the following disclosure subjects At Ameriprise, you and your financial advisor begin by considering what’s most important to you. Once we understand your unique needs, your financial advisor builds a comprehensive plan that considers all aspects of your financial life — your priorities, risk tolerance and time horizon — to help you grow and preserve your wealth over your lifetime. • When you enter an Ameriprise® Financial Planning Service (“AFPS”) relationship, an Ameriprise financial advisor (“financial advisor”) will provide you with ongoing financial planning analysis and written recommendations that align with your goals and needs. See the “Advisory Business” section of this Brochure. • You will pay a financial planning fee (“AFPS fee”) when you purchase AFPS. See the “Fees and Compensation” section of this Brochure. We’re providing you with this information to explain our financial planning services in detail, so you’ll know what to expect from your financial advisor and Ameriprise and how to make the most of your financial planning relationship. It contains essential disclosures about our affiliates, how we do business, and the terms and conditions of your financial planning service agreement. Please take time to read this important information. You can also always find a current copy at ameriprise.com/disclosures, under “General Disclosures.” • AFPS is an ongoing service. Each year, you will receive written recommendations and pay a To support your financial planning services, we strive to provide an unmatched digital experience, with the ability to manage your financial life safely and securely. Our award-winning website and mobile app allow you to track your financial goals in real time and stay connected to your advisor between meetings. financial planning fee. The service will automatically renew on an annual basis until you decide to terminate the AFPS Agreement. See the “Ongoing Relationship” subsection of the “Advisory Business” section of this Brochure. • If you are not satisfied with AFPS, you may terminate your AFPS Agreement. See the “Termination of AFPS” subsection of the “Fees and Compensation” section of this Brochure. If you have questions about any of our services, including financial planning, please feel free to reach out to your financial advisor or call us directly at 800.862.7919 between 7 a.m. and 6 p.m. Central time. Thank you again for working with Ameriprise. We’re committed to providing premium solutions and services to help you achieve your financial goals so you feel confident and in control of your financial life. • If you invest in an Ameriprise investment advisory account (“Managed Account”), you will pay an ongoing asset-based fee (“Asset-based Fee”) for investment advice on the assets in those accounts and related services. This is a wrap fee and is separate from, and in addition to, any AFPS fee you pay. See the “Other advisory services” subsection of the “Advisory Business” section of this Brochure. • Deana Smythe Healy, CFP® Vice President Ameriprise Financial Services, LLC If you purchase investment products from us, Ameriprise Financial Services, our affiliates, and your financial advisor will receive revenues in addition to the financial planning fees you pay. You will incur time-of-sale expenses such as commissions or sales loads in a transaction fee-based brokerage account and any ongoing expenses associated with those products such as investment management fees on mutual funds. These fees and expenses are separate from, and in addition to, any AFPS fee you pay. See the “Other Financial Industry Activities and Affiliations” and “Client Referrals and Other Compensation” sections of this Brochure. • Ameriprise Financial Services does not monitor the day-to-day performance of your specific investments. See the “Implementation of your financial planning recommendations” subsection of the “Advisory Business” section of this Brochure. • Ameriprise Financial Services cannot guarantee future financial results. See the “Implementation of your financial planning recommendations” subsection of the “Advisory Business” section of this Brochure. • Some aspects of our business may pose conflicts of interest for us, our affiliates and our financial advisors. See the “Other Financial Industry Activities and Affiliations” and “How we get paid” sections of this Brochure. • Regulatory proceedings may have occurred affecting Ameriprise Financial Services. See the “Disciplinary Information” section of this Brochure for a detailed explanation of these and other matters. • We will notify you of material changes to this Brochure and offer you a revised copy to replace any previous version. See the “Understand that our financial planning service will continue until you terminate it” subsection of “How to make the most of your financial planning relationship” in the “Advisory Business” section of this Brochure. Table of Contents Material Changes Annual Update How we get paid ................................................................. 18 This Brochure, dated March 2026, is filed as an annual update to Form ADV Part 2A, Appendix 1 and includes material changes that have occurred since the last annual update of our brochure in March 2025. Following is a summary of the material changes: • The “Cost Reimbursement Services and Third-Party Payments” section was updated to include the following sub-section: o Payments from Investment Providers offering SMA investment portfolios within the Signature Wealth Program. AEIS receives cost reimbursement payments for the sale of SMA investment portfolios offered within the Signature Wealth Program. AEIS receives an asset-based payment of up to 0.04% per year on Ameriprise Financial Services clients’ assets invested in the SMA investment portfolios. If an Investment Provider ceases to make such cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the firm. Cost reimbursement services and third-party payments .............................................. 18-21 Other financial relationships ................................... 21-22 Payments from other non-affiliated product companies .................................................. 23-25 Revenue sources for Ameriprise Financial Services, LLC ............................................ 25-26 Financial interest in products ....................................... 26 Economic benefits of affiliates’ products and services .............................................. 27-28 Financial advisor compensation and benefits ..... 28-35 • The “How our financial advisors get paid” section was retitled “Financial advisor compensation and benefits” and was updated in general for clarity and overall readability. You may request copies of the Brochure by writing to Ameriprise Financial Services, LLC at 2661 Ameriprise Financial Center, Minneapolis, MN 55474, or by calling 800.862.7919. Advisory Business ................................................................ 1 Ameriprise® Financial Planning Service ...................... 1-2 AFPS planning goals ..................................................... 2-3 Initial recommendations ............................................... 3-4 Ongoing relationship ........................................................ 4 Changing your planning goals ......................................... 4 Implementation of your financial planning recommendations ......................................... 4-5 How to make the most of your financial planning relationship ..................................... 6-7 Other advisory services .................................................... 7 Fees and Compensation ...................................................... 7 Sweep program and expenses ................................. 9-11 Client programs and promotions .................................. 11 Pro bono financial planning .......................................... 11 Institutional services ...................................................... 11 Termination of AFPS ...................................................... 12 Code of Ethics, Participation or Interest in Transactions and Personal Trading ................................ 35 Code of ethics ................................................................. 35 Participation or interest in client transactions ........... 35 Personal trading rules and procedures ....................... 35 Insider trading policy ...................................................... 35 Performance-Based Fees and Side-by-Side Management ............................................... 12 Brokerage Practices .......................................................... 35 Types of Clients .................................................................. 12 Review of Accounts ........................................................... 36 Client Referrals and Other Compensation ..................... 36 Methods of Analysis, Investment Strategies and Risk of Loss .............................................. 12 Methods of financial analysis ................................. 12-13 Sources of information ............................................ 13-14 Third-party research provider materials not approved for use with clients ................................. 14 Investment strategies .................................................... 14 Referral arrangements and other economic benefits ................................................ 36 Review of issuers of financial products ...................... 37 Revenue sources for RiverSource ................................ 38 Revenue sources for Columbia Management and Threadneedle ................ 38 Revenue sources for other Ameriprise Financial, Inc. companies .................... 38-40 Disciplinary Information .................................................... 14 Regulatory proceedings ........................................... 14-15 Custody ................................................................................ 40 Investment Discretion ....................................................... 40 Voting Client Securities ..................................................... 40 Financial Information ............................................ 42-51 Terms and Conditions of Your AFPS Agreement ... 52-55 Glossary ......................................................................... 56-57 Other financial industry activities and affiliations ................................................... 15 Broker-dealer ................................................................... 15 Investment company ...................................................... 16 Investment advisory firm ......................................... 16-17 Banking institution .......................................................... 17 Trust company ................................................................ 17 Insurance company ........................................................ 17 Ameriprise Financial Institutions Group (“AFIG”) .17-18 Please retain a copy of this Brochure for your records. Table of Contents Material Changes Annual Update How we get paid ................................................................. 18 This Brochure, dated March 2026, is filed as an annual update to Form ADV Part 2A, Appendix 1 and includes material changes that have occurred since the last annual update of our brochure in March 2025. Following is a summary of the material changes: • The “Cost Reimbursement Services and Third-Party Payments” section was updated to include the following sub-section: o Payments from Investment Providers offering SMA investment portfolios within the Signature Wealth Program. AEIS receives cost reimbursement payments for the sale of SMA investment portfolios offered within the Signature Wealth Program. AEIS receives an asset-based payment of up to 0.04% per year on Ameriprise Financial Services clients’ assets invested in the SMA investment portfolios. If an Investment Provider ceases to make such cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the firm. Cost reimbursement services and third-party payments .............................................. 18-21 Other financial relationships ................................... 21-22 Payments from other non-affiliated product companies .................................................. 23-25 Revenue sources for Ameriprise Financial Services, LLC ............................................ 25-26 Financial interest in products ....................................... 26 Economic benefits of affiliates’ products and services .............................................. 27-28 Financial advisor compensation and benefits ..... 28-35 • The “How our financial advisors get paid” section was retitled “Financial advisor compensation and benefits” and was updated in general for clarity and overall readability. You may request copies of the Brochure by writing to Ameriprise Financial Services, LLC at 2661 Ameriprise Financial Center, Minneapolis, MN 55474, or by calling 800.862.7919. Advisory Business ................................................................ 1 Ameriprise® Financial Planning Service ...................... 1-2 AFPS planning goals ..................................................... 2-3 Initial recommendations ............................................... 3-4 Ongoing relationship ........................................................ 4 Changing your planning goals ......................................... 4 Implementation of your financial planning recommendations ......................................... 4-5 How to make the most of your financial planning relationship ..................................... 6-7 Other advisory services .................................................... 7 Fees and Compensation ...................................................... 7 Sweep program and expenses ................................. 9-11 Client programs and promotions .................................. 11 Pro bono financial planning .......................................... 11 Institutional services ...................................................... 11 Termination of AFPS ...................................................... 12 Code of Ethics, Participation or Interest in Transactions and Personal Trading ................................ 35 Code of ethics ................................................................. 35 Participation or interest in client transactions ........... 35 Personal trading rules and procedures ....................... 35 Insider trading policy ...................................................... 35 Performance-Based Fees and Side-by-Side Management ............................................... 12 Brokerage Practices .......................................................... 35 Types of Clients .................................................................. 12 Review of Accounts ........................................................... 36 Client Referrals and Other Compensation ..................... 36 Methods of Analysis, Investment Strategies and Risk of Loss .............................................. 12 Methods of financial analysis ................................. 12-13 Sources of information ............................................ 13-14 Third-party research provider materials not approved for use with clients ................................. 14 Investment strategies .................................................... 14 Referral arrangements and other economic benefits ................................................ 36 Review of issuers of financial products ...................... 37 Revenue sources for RiverSource ................................ 38 Revenue sources for Columbia Management and Threadneedle ................ 38 Revenue sources for other Ameriprise Financial, Inc. companies .................... 38-40 Disciplinary Information .................................................... 14 Regulatory proceedings ........................................... 14-15 Custody ................................................................................ 40 Investment Discretion ....................................................... 40 Voting Client Securities ..................................................... 40 Financial Information ............................................ 42-51 Terms and Conditions of Your AFPS Agreement ... 52-55 Glossary ......................................................................... 56-57 Other financial industry activities and affiliations ................................................... 15 Broker-dealer ................................................................... 15 Investment company ...................................................... 16 Investment advisory firm ......................................... 16-17 Banking institution .......................................................... 17 Trust company ................................................................ 17 Insurance company ........................................................ 17 Ameriprise Financial Institutions Group (“AFIG”) .17-18 Please retain a copy of this Brochure for your records. Code”). Such communications should not be (and are not intended to be) relied upon as a primary basis for your investment decisions with respect to your retirement assets. Advisory Business Ameriprise Financial Services, LLC (“Ameriprise Financial Services”) is an investment advisory firm offering financial planning services since 1986. Ameriprise Financial, Inc., a publicly held company, is the parent company of Ameriprise Financial Services. References in this Brochure to “you” and “your” apply to each AFPS client who signs the AFPS Agreement. References to “us,” “we,” and “our” refer to Ameriprise Financial Services, LLC. References to “your financial advisor” are to your Ameriprise financial advisor. Additionally, if in connection with discussing, presenting, or offering particular Managed Accounts to you, we provide you with a sample or proposed asset allocation, including one that identifies specific securities or other investments, such asset allocation is merely an example of, or proposal for, the fiduciary advice and recommendations that may potentially be made available through the Managed Account once you decide to establish a Managed Account, and should not be relied upon as investment or fiduciary advice or a recommendation under ERISA or the Internal Revenue Code. We are not acting as a fiduciary under ERISA or the Internal Revenue Code when you decide to engage us in a new service, including with respect to your decision, or the decision of a plan participant, to roll over assets into an Ameriprise IRA. Similarly, we are not acting as a fiduciary under ERISA or the Internal Revenue Code when you decide to move assets from one type of account held at Ameriprise Financial Services to another type of account (e.g., moving assets from an Ameriprise brokerage account to a Managed Account). Ameriprise® Financial Planning Service Ameriprise® Financial Planning Service (“AFPS”) is designed as a long-term, collaborative, ongoing financial planning relationship to help you achieve at least one financial goal or need. You and your financial advisor will work together to define your goal or need, develop a plan to help you get there and track your progress along the way, making changes when needed. AFPS is a six-step financial planning process. As participants in this process, you and your financial advisor will: To the extent that you receive recommendations related to assets held in your brokerage account or with respect to commission-based securities, such recommendations are made as part of your brokerage relationship and are made in your best interest but are not fiduciary recommendations under ERISA or the Internal Revenue Code. Identify/prioritize objectives. Discuss your goals and needs to develop a clear vision of your financial future. • Ameriprise Financial Services provides Managed Accounts where you can receive individual securities level fiduciary recommendations. • Gather information. Review important documents such as your bank and brokerage statements, tax returns, insurance policies and retirement plans. • Analyze information. Understand the big picture of your financial situation, based on information you provide, and analyze how the different elements of financial planning may impact each other. Also, to the extent an asset allocation service identifies any specific investment alternative in a retirement plan, please note that other investment alternatives with similar risk and return characteristics may be available to you. Such investment alternatives may be more or less costly than those available at or recommended by Ameriprise Financial Services. Your Plan sponsor (for government plans or those that fall under ERISA) or your financial advisor can assist you in obtaining information about other potential investment alternatives. • Propose recommendations. Develop written financial planning recommendations that align with your goals. • Take action. Act on your recommendations after developing proposed financial solutions to help reach AFPS tailors advisory services to the individual needs of clients as discussed in the next several sections. your goals. AFPS planning goals • Track your progress. Your needs and goals evolve over time. Tracking your progress will enable you to adjust your plan in light of personal, legislative or regulatory and economic changes. Your financial advisor will review your data and other information to make recommendations that can help you meet your goals. If you are a client of the Ameriprise Personal Wealth Group, you may receive advice and support in the financial planning process from a dedicated team of financial advisors and professionals whose members may use titles such as Client Support Associate, Client Relationship Manager, or Financial Consultant. Financial fundamentals The advice you receive from your financial advisor is intended for your use only. If you choose to share your analysis and recommendations with a third party (e.g., a non-client spouse), neither your financial advisor nor Ameriprise Financial Services (nor any of its affiliates) is responsible for the outcome. Basic financial position. At a minimum, this review will include a high-level compilation of your net worth, income (inflows) and expenses (outflows). It may also include action step(s) and/or an acknowledgement by your financial advisor that figures are based on estimates if you are not able to provide precise data. Ameriprise Financial Services and our financial advisors owe you a fiduciary duty, as applied under the Investment Advisers Act of 1940, as amended, when you enter a financial planning relationship with Ameriprise Financial Services. This duty means that Ameriprise Financial Services and your financial advisor make investment recommendations that are in your best interest and place your interest ahead of our own and those of your financial advisor. This is accomplished by: • Explaining and providing to you written disclosures that outline key, relevant factors about the investment Protection needs. At a minimum, this review will include an inventory of your insurance policies, including life, disability (if you are not retired) and long-term care (if you have reached a certain age). You may also receive an analysis of your needs and your family’s needs in the event of death, disability and long-term care, as applicable. This may include an overview of other protection needs (e.g., property and casualty). Your financial advisor may also provide action steps in the form of recommendations; observations about the adequacy of your coverage; and/or other statements acknowledging your insurance situation, protection planning preferences, and/or whether any of the data or analysis is based on estimates if you are not able to provide precise data. advice and recommendations you receive; and • Providing you with written disclosures that describe material conflicts of interest that your financial advisor and/or Ameriprise Financial Services have as part of AFPS. (You will find these written disclosures throughout this Brochure, and in the “Other Financial Industry Activities and Affiliations” section.) Basic estate needs. This review will include an inventory of basic estate documents that are essential for the proper disposition of your assets upon your death and to provide for appropriate care in the event of your incapacity. It may also include a review of asset and policy ownership and beneficiary designations, as well as action steps or comments on how to work with legal advisors to improve your basic estate situation. Your financial advisor will review the financial fundamentals in the first year of your financial planning relationship and thereafter as needed, for example, if your personal financial circumstances or financial goals change. The review of fundamentals is not provided in advisory relationships with entity clients, such as trusts or businesses. The review of fundamentals is not provided as part of estate settlement or educational seminars and workshops. Your financial advisor can provide you with guidance to help you meet a wide variety of your financial needs, including asset allocation services. Your financial advisor may discuss, present or offer ideas for you to consider related to the allocation of retirement assets among one or more Managed Accounts. Such communications are offered solely as education, marketing and examples of the potential uses of these Managed Accounts for purposes of discussion and for your independent consideration, and should not be viewed, construed or relied upon, as investment or fiduciary recommendations or advice under the Employee Retirement Income Security Act of 1974 ("ERISA") or Section 4975 of the Internal Revenue Code of 1986, as amended (the “Internal Revenue 1 2 Code”). Such communications should not be (and are not intended to be) relied upon as a primary basis for your investment decisions with respect to your retirement assets. Advisory Business Ameriprise Financial Services, LLC (“Ameriprise Financial Services”) is an investment advisory firm offering financial planning services since 1986. Ameriprise Financial, Inc., a publicly held company, is the parent company of Ameriprise Financial Services. References in this Brochure to “you” and “your” apply to each AFPS client who signs the AFPS Agreement. References to “us,” “we,” and “our” refer to Ameriprise Financial Services, LLC. References to “your financial advisor” are to your Ameriprise financial advisor. Additionally, if in connection with discussing, presenting, or offering particular Managed Accounts to you, we provide you with a sample or proposed asset allocation, including one that identifies specific securities or other investments, such asset allocation is merely an example of, or proposal for, the fiduciary advice and recommendations that may potentially be made available through the Managed Account once you decide to establish a Managed Account, and should not be relied upon as investment or fiduciary advice or a recommendation under ERISA or the Internal Revenue Code. We are not acting as a fiduciary under ERISA or the Internal Revenue Code when you decide to engage us in a new service, including with respect to your decision, or the decision of a plan participant, to roll over assets into an Ameriprise IRA. Similarly, we are not acting as a fiduciary under ERISA or the Internal Revenue Code when you decide to move assets from one type of account held at Ameriprise Financial Services to another type of account (e.g., moving assets from an Ameriprise brokerage account to a Managed Account). Ameriprise® Financial Planning Service Ameriprise® Financial Planning Service (“AFPS”) is designed as a long-term, collaborative, ongoing financial planning relationship to help you achieve at least one financial goal or need. You and your financial advisor will work together to define your goal or need, develop a plan to help you get there and track your progress along the way, making changes when needed. AFPS is a six-step financial planning process. As participants in this process, you and your financial advisor will: To the extent that you receive recommendations related to assets held in your brokerage account or with respect to commission-based securities, such recommendations are made as part of your brokerage relationship and are made in your best interest but are not fiduciary recommendations under ERISA or the Internal Revenue Code. Identify/prioritize objectives. Discuss your goals and needs to develop a clear vision of your financial future. • Ameriprise Financial Services provides Managed Accounts where you can receive individual securities level fiduciary recommendations. • Gather information. Review important documents such as your bank and brokerage statements, tax returns, insurance policies and retirement plans. • Analyze information. Understand the big picture of your financial situation, based on information you provide, and analyze how the different elements of financial planning may impact each other. Also, to the extent an asset allocation service identifies any specific investment alternative in a retirement plan, please note that other investment alternatives with similar risk and return characteristics may be available to you. Such investment alternatives may be more or less costly than those available at or recommended by Ameriprise Financial Services. Your Plan sponsor (for government plans or those that fall under ERISA) or your financial advisor can assist you in obtaining information about other potential investment alternatives. • Propose recommendations. Develop written financial planning recommendations that align with your goals. • Take action. Act on your recommendations after developing proposed financial solutions to help reach AFPS tailors advisory services to the individual needs of clients as discussed in the next several sections. your goals. AFPS planning goals • Track your progress. Your needs and goals evolve over time. Tracking your progress will enable you to adjust your plan in light of personal, legislative or regulatory and economic changes. Your financial advisor will review your data and other information to make recommendations that can help you meet your goals. If you are a client of the Ameriprise Personal Wealth Group, you may receive advice and support in the financial planning process from a dedicated team of financial advisors and professionals whose members may use titles such as Client Support Associate, Client Relationship Manager, or Financial Consultant. Financial fundamentals The advice you receive from your financial advisor is intended for your use only. If you choose to share your analysis and recommendations with a third party (e.g., a non-client spouse), neither your financial advisor nor Ameriprise Financial Services (nor any of its affiliates) is responsible for the outcome. Basic financial position. At a minimum, this review will include a high-level compilation of your net worth, income (inflows) and expenses (outflows). It may also include action step(s) and/or an acknowledgement by your financial advisor that figures are based on estimates if you are not able to provide precise data. Ameriprise Financial Services and our financial advisors owe you a fiduciary duty, as applied under the Investment Advisers Act of 1940, as amended, when you enter a financial planning relationship with Ameriprise Financial Services. This duty means that Ameriprise Financial Services and your financial advisor make investment recommendations that are in your best interest and place your interest ahead of our own and those of your financial advisor. This is accomplished by: • Explaining and providing to you written disclosures that outline key, relevant factors about the investment Protection needs. At a minimum, this review will include an inventory of your insurance policies, including life, disability (if you are not retired) and long-term care (if you have reached a certain age). You may also receive an analysis of your needs and your family’s needs in the event of death, disability and long-term care, as applicable. This may include an overview of other protection needs (e.g., property and casualty). Your financial advisor may also provide action steps in the form of recommendations; observations about the adequacy of your coverage; and/or other statements acknowledging your insurance situation, protection planning preferences, and/or whether any of the data or analysis is based on estimates if you are not able to provide precise data. advice and recommendations you receive; and • Providing you with written disclosures that describe material conflicts of interest that your financial advisor and/or Ameriprise Financial Services have as part of AFPS. (You will find these written disclosures throughout this Brochure, and in the “Other Financial Industry Activities and Affiliations” section.) Basic estate needs. This review will include an inventory of basic estate documents that are essential for the proper disposition of your assets upon your death and to provide for appropriate care in the event of your incapacity. It may also include a review of asset and policy ownership and beneficiary designations, as well as action steps or comments on how to work with legal advisors to improve your basic estate situation. Your financial advisor will review the financial fundamentals in the first year of your financial planning relationship and thereafter as needed, for example, if your personal financial circumstances or financial goals change. The review of fundamentals is not provided in advisory relationships with entity clients, such as trusts or businesses. The review of fundamentals is not provided as part of estate settlement or educational seminars and workshops. Your financial advisor can provide you with guidance to help you meet a wide variety of your financial needs, including asset allocation services. Your financial advisor may discuss, present or offer ideas for you to consider related to the allocation of retirement assets among one or more Managed Accounts. Such communications are offered solely as education, marketing and examples of the potential uses of these Managed Accounts for purposes of discussion and for your independent consideration, and should not be viewed, construed or relied upon, as investment or fiduciary recommendations or advice under the Employee Retirement Income Security Act of 1974 ("ERISA") or Section 4975 of the Internal Revenue Code of 1986, as amended (the “Internal Revenue 1 2 Shortly after you sign the AFPS Agreement, you will receive a confirmation of services that reflects: Additional financial planning areas the total quoted AFPS fee; • Your analysis and written recommendations may address one or more of the following goals: the date your initial engagement began; and • the latest date on which you can expect to receive your initial written recommendations. • Financial position planning — applying cash flow management strategies to help you optimize resources available to help you reach your goals. This may include debt management techniques, major purchase financing options, cash reserve strategies and family budgeting. Future purchase planning — applying strategies to help you plan to fund a future purchase or accumulate funds for a particular goal. You will also receive a confirmation of services annually, in the form of a notice on your consolidated statement or other written notice to you, each time your AFPS Agreement renews. Please contact Ameriprise Financial Services at 800.862.7919 if you do not receive a confirmation of services within 120 days of your renewal date. If your personal financial circumstances or need for financial planning services change, you and your financial advisor should discuss whether your fee needs to change. Education planning — applying strategies to help you fund the education of children, grandchildren or others. This may also include financial aid analysis. Ongoing relationship Retirement planning — applying strategies to help you fund retirement, transition to retirement or ensure adequate retirement income. As your financial planning relationship continues, you will work with your financial advisor following the financial planning process described above. For example, you and your financial advisor will: Investment planning — applying strategies to help optimize portfolio performance to reach future financial goals. AFPS does not include current market analysis or other ongoing investment-related advice. Income tax related planning — addressing general tax considerations for financial services products, transactions and registrations (ownerships) and helping you understand how individual income, estate and gift tax planning techniques apply to your situation. Identify key changes to your situation and revisit your financial goals • Confirm your working relationship and the associated fee, annually • Track progress over time toward identified goals • • Propose new financial planning recommendations as appropriate Employee benefits planning — helping you make decisions related to your employer-sponsored benefit plans. Estate, legacy or multigenerational planning — helping you prepare to pass wealth to your beneficiaries in an efficient manner. Your AFPS Agreement is effective the day that Ameriprise Financial Services processes the AFPS Agreement (“Effective Date”), which may be different than the date(s) signed by you and your financial advisor. Your initial engagement begins on the Effective Date and ends the day prior to the anniversary date of your Effective Date. Each twelve-month period thereafter will be a new engagement period (“Engagement Period”). Estate settlement — applying strategies to help an estate or testamentary trust meet its obligations, such as distribution of assets and payment of income and estate taxes. Your AFPS Agreement will automatically renew each year. If you do not receive your written financial planning recommendation(s) within the Engagement Period, you are entitled to a refund of your AFPS fee. Business financial planning — addressing your financial planning needs as a business owner, which may include an analysis of business cash flow, business valuation for financial planning purposes, business tax planning, business benefits planning and business transition. Changing your planning goals Educational seminars and workshops — providing seminars and workshops on financial planning or investment- related topics to businesses or organizations. This service does not include the financial planning process or provision of written advice recommendations to individuals. You may change the financial planning goals on which you are requesting financial advice by discussing any desired changes with your financial advisor. In addition, after looking at all your financial data, your financial advisor may decide to recommend further assessment in a specific area that has not already been identified. Changes to your financial planning goals are confirmed to you by the delivery of recommendations consistent with your new goals. Other types of financial planning services may be offered such as divorce financial analysis or limited scope analysis. Your financial advisor may not be certified to offer certain types of financial planning. Talk with your financial advisor for more information about these services. Read and understand those recommendations to determine if you received advice on the goals you specified. If you did not, please contact your financial advisor or call 800.862.7919. Financial advisors are required to complete specialized training to provide divorce financial analysis, as well as some forms of income tax planning and planning for some types of trusts. If your financial advisor has not met these requirements, another qualified financial advisor may provide these services. You and your financial advisor should also discuss whether your AFPS fee needs to change in light of the changes to your planning goals. Ameriprise Financial Services and your financial advisor do not provide legal or tax advice. Implementation of your financial planning recommendations Initial recommendations Any recommendations provided in your financial plan are provided relative to the goals you establish with your financial advisor and do not include ongoing monitoring of your investments or your accounts, nor do they include the implementation of the recommendations provided in the plan by your financial advisor. In the first year following the effective date (described below) of your AFPS Agreement, your financial advisor will make best efforts to perform an analysis and deliver initial written recommendations within 180 days. This timeframe does not apply to estate settlement planning. You may decide to implement the recommendations you receive through Ameriprise Financial Services, its affiliates or unaffiliated financial services providers. Before implementing any recommendations, consider carefully the consequences of purchasing products or services. You may want to seek further advice from your lawyer and/or accountant, particularly for estate planning, taxes, or business financial planning issues. The analysis and written recommendations will address the fundamentals of your financial situation as well as the priority goal(s) you have discussed with your financial advisor. The remainder of the first year may focus on tracking your progress to goals, addressing other financial planning goals and/or beginning to take action on written recommendations as appropriate. When you choose to purchase products and services through Ameriprise Financial Services, you have the option of investing through a commission-based brokerage account, a fee-based Managed Account, or both. 3 4 Shortly after you sign the AFPS Agreement, you will receive a confirmation of services that reflects: Additional financial planning areas the total quoted AFPS fee; • Your analysis and written recommendations may address one or more of the following goals: the date your initial engagement began; and • the latest date on which you can expect to receive your initial written recommendations. • Financial position planning — applying cash flow management strategies to help you optimize resources available to help you reach your goals. This may include debt management techniques, major purchase financing options, cash reserve strategies and family budgeting. Future purchase planning — applying strategies to help you plan to fund a future purchase or accumulate funds for a particular goal. You will also receive a confirmation of services annually, in the form of a notice on your consolidated statement or other written notice to you, each time your AFPS Agreement renews. Please contact Ameriprise Financial Services at 800.862.7919 if you do not receive a confirmation of services within 120 days of your renewal date. If your personal financial circumstances or need for financial planning services change, you and your financial advisor should discuss whether your fee needs to change. Education planning — applying strategies to help you fund the education of children, grandchildren or others. This may also include financial aid analysis. Ongoing relationship Retirement planning — applying strategies to help you fund retirement, transition to retirement or ensure adequate retirement income. As your financial planning relationship continues, you will work with your financial advisor following the financial planning process described above. For example, you and your financial advisor will: Investment planning — applying strategies to help optimize portfolio performance to reach future financial goals. AFPS does not include current market analysis or other ongoing investment-related advice. Income tax related planning — addressing general tax considerations for financial services products, transactions and registrations (ownerships) and helping you understand how individual income, estate and gift tax planning techniques apply to your situation. Identify key changes to your situation and revisit your financial goals • Confirm your working relationship and the associated fee, annually • Track progress over time toward identified goals • • Propose new financial planning recommendations as appropriate Employee benefits planning — helping you make decisions related to your employer-sponsored benefit plans. Estate, legacy or multigenerational planning — helping you prepare to pass wealth to your beneficiaries in an efficient manner. Your AFPS Agreement is effective the day that Ameriprise Financial Services processes the AFPS Agreement (“Effective Date”), which may be different than the date(s) signed by you and your financial advisor. Your initial engagement begins on the Effective Date and ends the day prior to the anniversary date of your Effective Date. Each twelve-month period thereafter will be a new engagement period (“Engagement Period”). Estate settlement — applying strategies to help an estate or testamentary trust meet its obligations, such as distribution of assets and payment of income and estate taxes. Your AFPS Agreement will automatically renew each year. If you do not receive your written financial planning recommendation(s) within the Engagement Period, you are entitled to a refund of your AFPS fee. Business financial planning — addressing your financial planning needs as a business owner, which may include an analysis of business cash flow, business valuation for financial planning purposes, business tax planning, business benefits planning and business transition. Changing your planning goals Educational seminars and workshops — providing seminars and workshops on financial planning or investment- related topics to businesses or organizations. This service does not include the financial planning process or provision of written advice recommendations to individuals. You may change the financial planning goals on which you are requesting financial advice by discussing any desired changes with your financial advisor. In addition, after looking at all your financial data, your financial advisor may decide to recommend further assessment in a specific area that has not already been identified. Changes to your financial planning goals are confirmed to you by the delivery of recommendations consistent with your new goals. Other types of financial planning services may be offered such as divorce financial analysis or limited scope analysis. Your financial advisor may not be certified to offer certain types of financial planning. Talk with your financial advisor for more information about these services. Read and understand those recommendations to determine if you received advice on the goals you specified. If you did not, please contact your financial advisor or call 800.862.7919. Financial advisors are required to complete specialized training to provide divorce financial analysis, as well as some forms of income tax planning and planning for some types of trusts. If your financial advisor has not met these requirements, another qualified financial advisor may provide these services. You and your financial advisor should also discuss whether your AFPS fee needs to change in light of the changes to your planning goals. Ameriprise Financial Services and your financial advisor do not provide legal or tax advice. Implementation of your financial planning recommendations Initial recommendations Any recommendations provided in your financial plan are provided relative to the goals you establish with your financial advisor and do not include ongoing monitoring of your investments or your accounts, nor do they include the implementation of the recommendations provided in the plan by your financial advisor. In the first year following the effective date (described below) of your AFPS Agreement, your financial advisor will make best efforts to perform an analysis and deliver initial written recommendations within 180 days. This timeframe does not apply to estate settlement planning. You may decide to implement the recommendations you receive through Ameriprise Financial Services, its affiliates or unaffiliated financial services providers. Before implementing any recommendations, consider carefully the consequences of purchasing products or services. You may want to seek further advice from your lawyer and/or accountant, particularly for estate planning, taxes, or business financial planning issues. The analysis and written recommendations will address the fundamentals of your financial situation as well as the priority goal(s) you have discussed with your financial advisor. The remainder of the first year may focus on tracking your progress to goals, addressing other financial planning goals and/or beginning to take action on written recommendations as appropriate. When you choose to purchase products and services through Ameriprise Financial Services, you have the option of investing through a commission-based brokerage account, a fee-based Managed Account, or both. 3 4 How to make the most of your financial planning relationship At Ameriprise Financial Services, we believe that financial planning is the best way to help you achieve your goals. The financial planning relationship begins with you. As an AFPS client, you will need to: Brokerage Account. You pay commissions and other charges (such as sales loads on mutual funds) at the time of each individual securities transaction. As a result, this type of account may be more suitable than a Managed Account if you do not expect to trade on a regular basis and do not want ongoing investment advice on assets held in your Managed Account. Establish clear and measurable financial goals. Talk with your financial advisor about your goals so he or she may be part of the financial planning process. For example, if your goal is a “comfortable” retirement, talk with your financial advisor about what that means to you. The more specific you are about the lifestyle you envision, the better equipped your financial advisor will be to make recommendations to help you get there. Managed Account. You pay an ongoing Asset-based Fee (rather than a commission on each individual transaction) for investment advisory services such as investment selection, asset allocation, execution of transactions, custody of securities and account reporting services. The Asset-based Fee is assessed monthly. As a result, a Managed Account may be more suitable than a brokerage account if you want ongoing investment advice and expect to trade frequently. Ameriprise Financial Services is the sponsor and introducing broker for a variety of investment advisory accounts (“Advisory Solutions”). Within its Advisory Solutions, Ameriprise Financial Services offers a number of investment advisory programs (“Programs”) that have a wide array of investment strategies. When you decide upon a Program, you may open a Managed Account. See the Ameriprise® Managed Accounts Client Disclosure Brochure or, if you have elected to pay a consolidated advisory fee, the Ameriprise® Managed Accounts and Financial Planning Service Disclosure Brochure for additional important information, including applicable fees and other charges. Your financial advisor may not offer all Programs or accounts available from Ameriprise Financial Services. Provide complete and timely information to your financial advisor. Your financial advisor will base your financial planning analysis and written recommendations on the information you provide. You must provide the requested information in a timely manner to receive your recommendations in a timely manner. When you become an AFPS client, you represent that all financial and other data that you and/or your representatives or agents furnish to your financial advisor relating to your assets, liabilities, policies, present and future income, and obligations are true and correct and may be relied upon by your financial advisor and Ameriprise Financial Services for the purposes of providing AFPS. Your financial advisor will be better able to make recommendations to help you achieve your goals if you provide complete and thoughtful information to your financial advisor about your current financial and economic situation, the financial goals on which you want advice, your investment objectives, and any investment restrictions you may have. Promptly inform your financial advisor if you experience significant life events, or material changes in your financial situation, risk tolerance or financial objectives. Depending on how long you choose to be a financial planning client and the number and types of products you purchase from Ameriprise Financial Services, you may pay more or less to purchase products and services through Ameriprise Financial Services and its affiliates than if you were to purchase products and services from other financial services providers. Review the written recommendations you receive. Based on the information you provided, your financial advisor will perform financial planning analysis and give you written recommendations on the financial goals you have identified. Your financial advisor is obligated to provide recommendation(s) within a particular timeframe, which is discussed in detail in the “Ameriprise® Financial Planning Service” section of this Brochure. If your financial advisor’s assumptions, methods, conclusions or recommendations do not meet your expectations, contact your financial advisor right away to resolve your concerns. Your financial advisor may provide asset allocation strategies that include advice on allocations into certain classes of investments. Except where we are providing you guidance related to your Outside Workplace Retirement Plan or Health Savings Account (“HSA”) as described below, your financial advisor cannot provide specific buy, sell or hold recommendations or initiate transactions concerning individual securities in your investment accounts held in custody elsewhere, unless held by one of our broker-dealer affiliates. See the “Other Financial Industry Activities and Affiliations” section of this brochure for more information about these affiliates. None of the mutual funds currently offered in Ameriprise Managed Accounts Programs impose a front-end sales charge. For most mutual funds, a share class that does not have a sales load and does not assess 12b-1 fees (collectively “Advisory Shares”) is offered in all Ameriprise Managed Account Programs as the only mutual fund share class, where available to us through a selling agreement. If not available to us through a selling agreement or if the mutual fund does not offer an Advisory Share class, we offer Class A shares that may pay a 12b-1 fee or a no-load share class that does not have a sales load but that may pay a 12b-1 fee. 12b-1 fees are paid by a mutual fund out of fund assets to cover distribution expenses and sometimes shareholder service expenses. The share class offered by Ameriprise Financial Services for a particular mutual fund is the only share class we allow for additional purchase within your Account. Any 12b-1 fees received by Ameriprise Financial Services will be promptly rebated to your Managed Account. The share class offered by Ameriprise Financial Services for each applicable fund is listed in our Mutual Fund Screener Tool. Access the tool by logging into your Ameriprise Secure Site account and navigating to “Trade & Research” and then “Screeners” followed by “Mutual Fund.” From there, apply the Product Type filter and choose either SPS Advantage or SPS Advisor to view the funds and share classes available for purchase. The Advisory Share or other share class we offer in Ameriprise Managed Accounts is less expensive than share classes made available through an Ameriprise brokerage account that charge investors a 12b-1 fee or assess a sales charge. This presents a conflict of interest because Ameriprise Financial Services and its financial advisors typically earn higher fees from share classes that charge such fees. It is therefore generally more profitable to Ameriprise Financial Services, its affiliates and its financial advisors, and more costly to clients, if clients invest in mutual fund share classes made available through an Ameriprise brokerage account. Where requested and as part of your AFPS, your financial advisor may provide guidance on your retirement plan or HSA assets that are held outside of Ameriprise Financial Services in a participant-directed defined contribution plan (e.g., 401(k) plan) (“Outside Workplace Retirement Plan”) or HSA. Any guidance provided to you is based on information provided by you about your Outside Workplace Retirement Plan or HSA and is limited to investments offered through the core lineup of funds established by your plan sponsor. Your Outside Workplace Retirement Plan or HSA may include investment options not available at Ameriprise Financial Services or for which your financial advisor may not have access to detailed information. Neither Ameriprise Financial Services nor your financial advisor is responsible for the selection of the available investment options in your Outside Workplace Retirement Plan or HSA. Your financial advisor cannot make buy recommendations related to employer stock that may be available within your Outside Workplace Retirement Plan or HSA. Your financial advisor cannot make recommendations with respect to any current portfolio holdings or investment options available through a self-directed brokerage account associated with your Outside Workplace Retirement Plan or HSA. You are responsible for placing any transactions recommended by your financial advisor. If you desire ongoing guidance on your Outside Workplace Retirement Plan or HSA you must provide your financial advisor with updated information, including statements and a list of funds available in your Outside Workplace Retirement Plan or HSA, on a regular basis. Your investment objectives and risk tolerance for your Outside Workplace Retirement Plan or HSA may differ from those of your Ameriprise account(s), if any. However, any guidance provided for your Outside Workplace Retirement Plan or HSA is provided in consideration of the investment objectives and risk tolerance of any Ameriprise account(s) you hold. A financial advisor’s recommendation that the client invest in mutual fund share classes through an Ameriprise brokerage account service will cause the client to pay higher internal expenses for certain mutual funds than the client might otherwise pay if participating in an Ameriprise Managed Account Program or by buying the mutual funds directly from the distributor outside of a brokerage account service, if possible. The client’s participation in a brokerage account service that does not offer the Advisory Share or other share class we offer in Ameriprise Managed Accounts may still be an appropriate choice depending on the facts and circumstances of the client’s individual situation and in light of the features and benefits of the particular brokerage account service. Please refer to the mutual fund’s prospectus(es) or website to determine whether your investment would qualify for a less expensive share class outside a brokerage account service, with corresponding lower expenses and fees. Form reasonable expectations. Understand the benefits of and limits to the financial planning process and be reasonable in your expectations of the results you can achieve with your financial plan and investments, given your risk tolerance and objectives. Financial planning is an ongoing process; it will not change your situation overnight. Furthermore, events beyond your financial advisor’s control, such as changes in economic conditions, will affect 5 6 How to make the most of your financial planning relationship At Ameriprise Financial Services, we believe that financial planning is the best way to help you achieve your goals. The financial planning relationship begins with you. As an AFPS client, you will need to: Brokerage Account. You pay commissions and other charges (such as sales loads on mutual funds) at the time of each individual securities transaction. As a result, this type of account may be more suitable than a Managed Account if you do not expect to trade on a regular basis and do not want ongoing investment advice on assets held in your Managed Account. Establish clear and measurable financial goals. Talk with your financial advisor about your goals so he or she may be part of the financial planning process. For example, if your goal is a “comfortable” retirement, talk with your financial advisor about what that means to you. The more specific you are about the lifestyle you envision, the better equipped your financial advisor will be to make recommendations to help you get there. Managed Account. You pay an ongoing Asset-based Fee (rather than a commission on each individual transaction) for investment advisory services such as investment selection, asset allocation, execution of transactions, custody of securities and account reporting services. The Asset-based Fee is assessed monthly. As a result, a Managed Account may be more suitable than a brokerage account if you want ongoing investment advice and expect to trade frequently. Ameriprise Financial Services is the sponsor and introducing broker for a variety of investment advisory accounts (“Advisory Solutions”). Within its Advisory Solutions, Ameriprise Financial Services offers a number of investment advisory programs (“Programs”) that have a wide array of investment strategies. When you decide upon a Program, you may open a Managed Account. See the Ameriprise® Managed Accounts Client Disclosure Brochure or, if you have elected to pay a consolidated advisory fee, the Ameriprise® Managed Accounts and Financial Planning Service Disclosure Brochure for additional important information, including applicable fees and other charges. Your financial advisor may not offer all Programs or accounts available from Ameriprise Financial Services. Provide complete and timely information to your financial advisor. Your financial advisor will base your financial planning analysis and written recommendations on the information you provide. You must provide the requested information in a timely manner to receive your recommendations in a timely manner. When you become an AFPS client, you represent that all financial and other data that you and/or your representatives or agents furnish to your financial advisor relating to your assets, liabilities, policies, present and future income, and obligations are true and correct and may be relied upon by your financial advisor and Ameriprise Financial Services for the purposes of providing AFPS. Your financial advisor will be better able to make recommendations to help you achieve your goals if you provide complete and thoughtful information to your financial advisor about your current financial and economic situation, the financial goals on which you want advice, your investment objectives, and any investment restrictions you may have. Promptly inform your financial advisor if you experience significant life events, or material changes in your financial situation, risk tolerance or financial objectives. Depending on how long you choose to be a financial planning client and the number and types of products you purchase from Ameriprise Financial Services, you may pay more or less to purchase products and services through Ameriprise Financial Services and its affiliates than if you were to purchase products and services from other financial services providers. Review the written recommendations you receive. Based on the information you provided, your financial advisor will perform financial planning analysis and give you written recommendations on the financial goals you have identified. Your financial advisor is obligated to provide recommendation(s) within a particular timeframe, which is discussed in detail in the “Ameriprise® Financial Planning Service” section of this Brochure. If your financial advisor’s assumptions, methods, conclusions or recommendations do not meet your expectations, contact your financial advisor right away to resolve your concerns. Your financial advisor may provide asset allocation strategies that include advice on allocations into certain classes of investments. Except where we are providing you guidance related to your Outside Workplace Retirement Plan or Health Savings Account (“HSA”) as described below, your financial advisor cannot provide specific buy, sell or hold recommendations or initiate transactions concerning individual securities in your investment accounts held in custody elsewhere, unless held by one of our broker-dealer affiliates. See the “Other Financial Industry Activities and Affiliations” section of this brochure for more information about these affiliates. None of the mutual funds currently offered in Ameriprise Managed Accounts Programs impose a front-end sales charge. For most mutual funds, a share class that does not have a sales load and does not assess 12b-1 fees (collectively “Advisory Shares”) is offered in all Ameriprise Managed Account Programs as the only mutual fund share class, where available to us through a selling agreement. If not available to us through a selling agreement or if the mutual fund does not offer an Advisory Share class, we offer Class A shares that may pay a 12b-1 fee or a no-load share class that does not have a sales load but that may pay a 12b-1 fee. 12b-1 fees are paid by a mutual fund out of fund assets to cover distribution expenses and sometimes shareholder service expenses. The share class offered by Ameriprise Financial Services for a particular mutual fund is the only share class we allow for additional purchase within your Account. Any 12b-1 fees received by Ameriprise Financial Services will be promptly rebated to your Managed Account. The share class offered by Ameriprise Financial Services for each applicable fund is listed in our Mutual Fund Screener Tool. Access the tool by logging into your Ameriprise Secure Site account and navigating to “Trade & Research” and then “Screeners” followed by “Mutual Fund.” From there, apply the Product Type filter and choose either SPS Advantage or SPS Advisor to view the funds and share classes available for purchase. The Advisory Share or other share class we offer in Ameriprise Managed Accounts is less expensive than share classes made available through an Ameriprise brokerage account that charge investors a 12b-1 fee or assess a sales charge. This presents a conflict of interest because Ameriprise Financial Services and its financial advisors typically earn higher fees from share classes that charge such fees. It is therefore generally more profitable to Ameriprise Financial Services, its affiliates and its financial advisors, and more costly to clients, if clients invest in mutual fund share classes made available through an Ameriprise brokerage account. Where requested and as part of your AFPS, your financial advisor may provide guidance on your retirement plan or HSA assets that are held outside of Ameriprise Financial Services in a participant-directed defined contribution plan (e.g., 401(k) plan) (“Outside Workplace Retirement Plan”) or HSA. Any guidance provided to you is based on information provided by you about your Outside Workplace Retirement Plan or HSA and is limited to investments offered through the core lineup of funds established by your plan sponsor. Your Outside Workplace Retirement Plan or HSA may include investment options not available at Ameriprise Financial Services or for which your financial advisor may not have access to detailed information. Neither Ameriprise Financial Services nor your financial advisor is responsible for the selection of the available investment options in your Outside Workplace Retirement Plan or HSA. Your financial advisor cannot make buy recommendations related to employer stock that may be available within your Outside Workplace Retirement Plan or HSA. Your financial advisor cannot make recommendations with respect to any current portfolio holdings or investment options available through a self-directed brokerage account associated with your Outside Workplace Retirement Plan or HSA. You are responsible for placing any transactions recommended by your financial advisor. If you desire ongoing guidance on your Outside Workplace Retirement Plan or HSA you must provide your financial advisor with updated information, including statements and a list of funds available in your Outside Workplace Retirement Plan or HSA, on a regular basis. Your investment objectives and risk tolerance for your Outside Workplace Retirement Plan or HSA may differ from those of your Ameriprise account(s), if any. However, any guidance provided for your Outside Workplace Retirement Plan or HSA is provided in consideration of the investment objectives and risk tolerance of any Ameriprise account(s) you hold. A financial advisor’s recommendation that the client invest in mutual fund share classes through an Ameriprise brokerage account service will cause the client to pay higher internal expenses for certain mutual funds than the client might otherwise pay if participating in an Ameriprise Managed Account Program or by buying the mutual funds directly from the distributor outside of a brokerage account service, if possible. The client’s participation in a brokerage account service that does not offer the Advisory Share or other share class we offer in Ameriprise Managed Accounts may still be an appropriate choice depending on the facts and circumstances of the client’s individual situation and in light of the features and benefits of the particular brokerage account service. Please refer to the mutual fund’s prospectus(es) or website to determine whether your investment would qualify for a less expensive share class outside a brokerage account service, with corresponding lower expenses and fees. Form reasonable expectations. Understand the benefits of and limits to the financial planning process and be reasonable in your expectations of the results you can achieve with your financial plan and investments, given your risk tolerance and objectives. Financial planning is an ongoing process; it will not change your situation overnight. Furthermore, events beyond your financial advisor’s control, such as changes in economic conditions, will affect 5 6 based on your personal financial circumstances, your financial planning needs, and the frequency with which your financial advisor meets with you and/or other professionals or family members. your financial planning results. Share with your financial advisor your expectations about the financial planning process and what you want to achieve. If your expectations are not met, let your financial advisor know so he or she can make adjustments to meet your needs. Ask questions about the AFPS fee so that you understand the factors considered in arriving at your AFPS fee and what you can expect for this fee. Take action. After reviewing your financial planning recommendations with your financial advisor, the next step is to act on the advice you have received. You decide whether to implement any of the recommendations. You are not obligated to purchase products or services through Ameriprise Financial Services. The minimum annual AFPS fee for new AFPS Agreements is $500. Your financial advisor’s AFPS fee may be higher. The AFPS fee to enter a new financial planning relationship with financial advisors from the Ameriprise Personal Wealth Group is $50.00/month. Depending on the overall complexity of your advice needs, you may pay a higher fee. If you have an existing AFPS Engagement with financial advisors from the Ameriprise Personal Wealth Group, you may pay a lower fee. If you would like to work with a different financial advisor, please call us at 800.862.7919 and we will help you find another financial advisor. If for some reason your financial advisor is unable to fulfill the terms of the service agreement, another Ameriprise financial advisor may be assigned to you to provide the written financial planning recommendations and complete the terms of your Agreement. Understand that your financial planning service will continue until you terminate it. You will receive written recommendations and pay an AFPS fee during each Engagement Period. The service will automatically renew on an annual basis until you decide to terminate the AFPS Agreement or stop paying the fee. In addition, Ameriprise Financial Services will notify you when there are material changes to this Brochure and offer you the opportunity to receive a copy of the revised Brochure. You should carefully consider accepting this offer, as that revised Brochure replaces any previous version you have received. The AFPS fee that you pay in the first year of service may differ from the AFPS fee you pay for services in ongoing years, as described in the “Ongoing relationship” subsection of the “Ameriprise® Financial Planning Service” section of this Brochure. A portion of the AFPS fee will be allocated to your financial advisor for introducing you to the service, gathering the information necessary to prepare your service, helping you establish needs and goals, preparing and presenting your service, and/or providing financial advice on behalf of Ameriprise Financial Services. The portion of the AFPS fee allocated to your financial advisor is impacted by factors including the level of affiliation that the financial advisor has with Ameriprise Financial Services and whether the financial advisor was assisted by another person (who may be a financial advisor or other individual who makes a referral) in providing services to you. You may request and receive copies of a current Brochure at any time by writing to Ameriprise Financial Services at the following address or by contacting us at 800.862.7919 between 7 a.m. and 6 p.m. Central time. Ameriprise Financial Services, LLC 476 Ameriprise Financial Center Minneapolis, MN 55474 The remaining portion of the fee goes to Ameriprise Financial Services for the supervisory, technical, administrative and other support provided to all financial advisors. If you establish an Ameriprise Managed Account, the Asset-based fee you pay for the Managed Account is separate from your AFPS fee. Please refer to the Ameriprise Managed Accounts Client Disclosure Brochure, or if you have elected to pay a consolidated advisory fee, the Ameriprise Managed Accounts and Financial Planning Service Disclosure Brochure for more detail about the allocation of Asset-based Fees. Take an active role in the process. Understand the process, your role and your financial advisor’s role. Provide information. Ask questions about the recommendations you receive. If at any time there are additional goals you would like to cover, let your financial advisor know. Take an active role in making decisions about your financial future, and you will position yourself to get the most out of your financial planning relationship. Some financial advisors require clients to pay AFPS fees either at the beginning of an Engagement Period or before providing AFPS. See the “Termination of AFPS” and “Termination procedure” sections below for information regarding refunds if you or Ameriprise Financial Services terminates the AFPS Agreement before the end of an Engagement Period. Other advisory services Ameriprise Financial Services is dedicated to providing quality client service. We work hard to ensure your satisfaction with the AFPS services that you receive and seek to meet or exceed your expectations. We will work with you to address any of your concerns, including helping you work with a different financial advisor or terminating the AFPS Agreement. Ameriprise Financial Services offers a suite of Advisory Solutions that features several types of Programs, including Strategic Portfolio Service (“SPS”) Advantage, SPS Advisor, Signature Wealth, Active Portfolios® investments, Select Separate Account, Vista Separate Account, Investor Unified Account, and Access Account. Not all Managed Account Programs are available to all clients; contact your financial advisor for more information. Please review the Ameriprise Managed Accounts Client Disclosure Brochure, or if you have elected to pay a consolidated advisory fee, the Ameriprise Managed Accounts and Financial Planning Service Disclosure Brochure for a full description of these Programs. As of December 31, 2025, Ameriprise Financial Services managed $304,183,842,664 in nondiscretionary assets and $356,290,579,112 in discretionary assets. Our affiliate American Enterprise Investment Services Inc. (“AEIS”) receives revenue from several different sources on the products and services you purchase through Ameriprise. These sources include arrangements we have in place with product companies, and investment and interest income. See the “Cost Reimbursement Services and Third-Party Payments” subsection of the “How we get paid” section later in this brochure for more information on conflicts of interest regarding revenue sources for Ameriprise Financial Services and its affiliates, as well as the subsection “Revenue sources for RiverSource” for more information about the fees and commissions you pay when you implement your financial advisor’s recommendations through Ameriprise Financial Services and its affiliates. The revenue generated or received supports the development of new products, maintenance of our infrastructure, and retention of employees and financial advisors. Fees and Compensation Ameriprise financial advisors receive compensation for financial advice in the form of commissions and fees. Ameriprise Personal Wealth Group financial advisors can receive compensation for financial advice in the form of bonuses. AFPS fees are negotiable and there is no assurance that similarly situated clients will be assessed comparable fees. Your financial advisor will explain the AFPS fee and the factors considered in calculating the AFPS fee before asking you to sign the AFPS Agreement. Your financial advisor may recommend mutual funds and other investment products offered by firms that make Third Party Payments to our affiliate, AEIS, as described in the “Payments from product companies” subsection later in this Disclosure Brochure. Within its investment advisory business, compensation for the sale of investment products recommended by financial advisors is not Ameriprise Financial Services’ primary source of revenue from its advisory clients. A state may impose a sales tax on your AFPS fee, which we will collect and remit to the applicable state. AFPS fees vary based on (1) your financial advisor’s fee schedule, which is based on your financial advisor’s years of financial planning experience, professional credentials, and other factors, such as local market considerations; and (2) the overall complexity of your advice needs. Your AFPS fee does not include markups or brokerage commissions by Ameriprise Financial Services or your financial advisor. If you implement your financial plan in whole or in part through Ameriprise Financial Services or its affiliates, wrap fees, product fees, markups or markdowns and brokerage commissions will apply as applicable. Both time of sale and ongoing fees, if applicable, will apply for products and services purchased in a transaction- based brokerage account. Your financial advisor will assign an overall complexity factor of “low,” “medium” or “high” to your advice needs 7 8 based on your personal financial circumstances, your financial planning needs, and the frequency with which your financial advisor meets with you and/or other professionals or family members. your financial planning results. Share with your financial advisor your expectations about the financial planning process and what you want to achieve. If your expectations are not met, let your financial advisor know so he or she can make adjustments to meet your needs. Ask questions about the AFPS fee so that you understand the factors considered in arriving at your AFPS fee and what you can expect for this fee. Take action. After reviewing your financial planning recommendations with your financial advisor, the next step is to act on the advice you have received. You decide whether to implement any of the recommendations. You are not obligated to purchase products or services through Ameriprise Financial Services. The minimum annual AFPS fee for new AFPS Agreements is $500. Your financial advisor’s AFPS fee may be higher. The AFPS fee to enter a new financial planning relationship with financial advisors from the Ameriprise Personal Wealth Group is $50.00/month. Depending on the overall complexity of your advice needs, you may pay a higher fee. If you have an existing AFPS Engagement with financial advisors from the Ameriprise Personal Wealth Group, you may pay a lower fee. If you would like to work with a different financial advisor, please call us at 800.862.7919 and we will help you find another financial advisor. If for some reason your financial advisor is unable to fulfill the terms of the service agreement, another Ameriprise financial advisor may be assigned to you to provide the written financial planning recommendations and complete the terms of your Agreement. Understand that your financial planning service will continue until you terminate it. You will receive written recommendations and pay an AFPS fee during each Engagement Period. The service will automatically renew on an annual basis until you decide to terminate the AFPS Agreement or stop paying the fee. In addition, Ameriprise Financial Services will notify you when there are material changes to this Brochure and offer you the opportunity to receive a copy of the revised Brochure. You should carefully consider accepting this offer, as that revised Brochure replaces any previous version you have received. The AFPS fee that you pay in the first year of service may differ from the AFPS fee you pay for services in ongoing years, as described in the “Ongoing relationship” subsection of the “Ameriprise® Financial Planning Service” section of this Brochure. A portion of the AFPS fee will be allocated to your financial advisor for introducing you to the service, gathering the information necessary to prepare your service, helping you establish needs and goals, preparing and presenting your service, and/or providing financial advice on behalf of Ameriprise Financial Services. The portion of the AFPS fee allocated to your financial advisor is impacted by factors including the level of affiliation that the financial advisor has with Ameriprise Financial Services and whether the financial advisor was assisted by another person (who may be a financial advisor or other individual who makes a referral) in providing services to you. You may request and receive copies of a current Brochure at any time by writing to Ameriprise Financial Services at the following address or by contacting us at 800.862.7919 between 7 a.m. and 6 p.m. Central time. Ameriprise Financial Services, LLC 476 Ameriprise Financial Center Minneapolis, MN 55474 The remaining portion of the fee goes to Ameriprise Financial Services for the supervisory, technical, administrative and other support provided to all financial advisors. If you establish an Ameriprise Managed Account, the Asset-based fee you pay for the Managed Account is separate from your AFPS fee. Please refer to the Ameriprise Managed Accounts Client Disclosure Brochure, or if you have elected to pay a consolidated advisory fee, the Ameriprise Managed Accounts and Financial Planning Service Disclosure Brochure for more detail about the allocation of Asset-based Fees. Take an active role in the process. Understand the process, your role and your financial advisor’s role. Provide information. Ask questions about the recommendations you receive. If at any time there are additional goals you would like to cover, let your financial advisor know. Take an active role in making decisions about your financial future, and you will position yourself to get the most out of your financial planning relationship. Some financial advisors require clients to pay AFPS fees either at the beginning of an Engagement Period or before providing AFPS. See the “Termination of AFPS” and “Termination procedure” sections below for information regarding refunds if you or Ameriprise Financial Services terminates the AFPS Agreement before the end of an Engagement Period. Other advisory services Ameriprise Financial Services is dedicated to providing quality client service. We work hard to ensure your satisfaction with the AFPS services that you receive and seek to meet or exceed your expectations. We will work with you to address any of your concerns, including helping you work with a different financial advisor or terminating the AFPS Agreement. Ameriprise Financial Services offers a suite of Advisory Solutions that features several types of Programs, including Strategic Portfolio Service (“SPS”) Advantage, SPS Advisor, Signature Wealth, Active Portfolios® investments, Select Separate Account, Vista Separate Account, Investor Unified Account, and Access Account. Not all Managed Account Programs are available to all clients; contact your financial advisor for more information. Please review the Ameriprise Managed Accounts Client Disclosure Brochure, or if you have elected to pay a consolidated advisory fee, the Ameriprise Managed Accounts and Financial Planning Service Disclosure Brochure for a full description of these Programs. As of December 31, 2025, Ameriprise Financial Services managed $304,183,842,664 in nondiscretionary assets and $356,290,579,112 in discretionary assets. Our affiliate American Enterprise Investment Services Inc. (“AEIS”) receives revenue from several different sources on the products and services you purchase through Ameriprise. These sources include arrangements we have in place with product companies, and investment and interest income. See the “Cost Reimbursement Services and Third-Party Payments” subsection of the “How we get paid” section later in this brochure for more information on conflicts of interest regarding revenue sources for Ameriprise Financial Services and its affiliates, as well as the subsection “Revenue sources for RiverSource” for more information about the fees and commissions you pay when you implement your financial advisor’s recommendations through Ameriprise Financial Services and its affiliates. The revenue generated or received supports the development of new products, maintenance of our infrastructure, and retention of employees and financial advisors. Fees and Compensation Ameriprise financial advisors receive compensation for financial advice in the form of commissions and fees. Ameriprise Personal Wealth Group financial advisors can receive compensation for financial advice in the form of bonuses. AFPS fees are negotiable and there is no assurance that similarly situated clients will be assessed comparable fees. Your financial advisor will explain the AFPS fee and the factors considered in calculating the AFPS fee before asking you to sign the AFPS Agreement. Your financial advisor may recommend mutual funds and other investment products offered by firms that make Third Party Payments to our affiliate, AEIS, as described in the “Payments from product companies” subsection later in this Disclosure Brochure. Within its investment advisory business, compensation for the sale of investment products recommended by financial advisors is not Ameriprise Financial Services’ primary source of revenue from its advisory clients. A state may impose a sales tax on your AFPS fee, which we will collect and remit to the applicable state. AFPS fees vary based on (1) your financial advisor’s fee schedule, which is based on your financial advisor’s years of financial planning experience, professional credentials, and other factors, such as local market considerations; and (2) the overall complexity of your advice needs. Your AFPS fee does not include markups or brokerage commissions by Ameriprise Financial Services or your financial advisor. If you implement your financial plan in whole or in part through Ameriprise Financial Services or its affiliates, wrap fees, product fees, markups or markdowns and brokerage commissions will apply as applicable. Both time of sale and ongoing fees, if applicable, will apply for products and services purchased in a transaction- based brokerage account. Your financial advisor will assign an overall complexity factor of “low,” “medium” or “high” to your advice needs 7 8 Sweep program and expenses AIMMA Your Ameriprise accounts will from time to time receive and disburse cash. Cash received can be in the form of deposits you make to your account, the proceeds from investments you sell, and the receipt of dividend and interest payments from investments you own. Cash is disbursed from your account to pay for new investment products you buy, to cover debit card, ACH or bill pay activity, and to pay the Asset-based Fee for a Managed Account and other fees you may incur. Any portion of your account balance that is held in cash will be included in the Asset-based Fee calculation. On a daily basis, Ameriprise Financial Services will move all uninvested cash into the Sweep Program applied to your Account(s). The Sweep Programs may pay interest or dividends. By authorizing Ameriprise Financial Services to open an account, you expressly authorize Ameriprise Financial Services to move such cash balances. AIMMA is an interest-bearing multi-bank deposit product made available by Ameriprise Financial and held in an omnibus account(s) at one or more FDIC member banks (collectively, the "Program Banks"). Our affiliate, Ameriprise Bank, FSB (“Ameriprise Bank”) is a Program Bank and participates in AIMMA. The Program Banks may serve individually as custodians for all or a portion of the cash balance held within your account that are swept to AIMMA, as described in the Other Important Brokerage Disclosures document. Multi-bank deposit products are eligible for FDIC insurance, subject to certain conditions, up to $250,000 per depositor ($500,000 for joint ownerships) per Program Bank, including deposits held at Ameriprise Bank, and, under ordinary business conditions, up to $2.5 million per depositor ($5 million for joint ownerships) across all Program Banks combined, per FDIC rules. For any amount above the applicable limit that is deposited in a single Program Bank, including any other FDIC insured product you may own through that Program Bank, the amount above the limit will not be eligible for FDIC deposit insurance. Deposit products are not covered by the SIPC. Regardless of the Sweep Program made available to you, you can also buy and sell positional money market mutual funds, brokered certificates of deposit, treasury bills, and other similar cash-equivalent products to manage cash in your non-discretionary Managed Accounts and Ameriprise brokerage accounts, and such investment products may be available for you buy and sell in certain discretionary Managed Accounts. These options for the investment of cash balances are generally expected to offer higher returns than the Sweep Program we make available for your account. Some types of investment products may not be available to you under the terms of your specific account. If your account uses AIMMA as its Sweep Program, you agree to accept the proprietary algorithm applied by IntraFi LLC (“IntraFi”), which determines the Program Banks into which your deposits are placed. You also understand and agree that IntraFi will periodically change the order of the Program Banks to optimize the amount of FDIC insurance available in the AIMMA Sweep Program. Under ordinary business conditions, changes to the Program Bank List will be published at least five business days prior to the effective date, and current interest rates for each interest rate tier will be published three to five business days prior to their effective date. The Program Banks are identified on the Program Bank List and interest rate information is available at Ameriprise.com/cashrates. More detail regarding Sweep Programs offered by Ameriprise Financial Services is available in the Other Important Brokerage Disclosures document and the Money Settlement Options section of the Ameriprise Brokerage Client Agreement. For a copy of the Other Important Brokerage Disclosures or the Ameriprise Brokerage Client Agreement, visit our website at ameriprise.com/disclosures or call our service line at 800.862.7919. The Sweep Programs offered in Managed Accounts are: • Ameriprise Insured Money Market Account ("AIMMA") is the Sweep Program offered for Ameriprise brokerage Any cash in your account(s) that is swept to AIMMA is aggregated with cash held by other Ameriprise clients that utilize AIMMA and is held in an omnibus account at one or more Program Banks. Omnibus accounts, by virtue of their ability to raise significant balances for the Program Banks, are generally able to earn higher interest rates than those you would be able to earn if you deposited cash individually at a bank. The Program Banks participating in AIMMA earn income by lending or investing the deposits they receive and charging a higher interest rate to borrowers, or earning a higher yield, than the Program Banks pay on the deposits held through AIMMA. This difference is known as the "spread." Like the unaffiliated Program Banks participating in AIMMA, Ameriprise Bank earns spread revenue when it participates in AIMMA as a Program Bank. accounts, SPS Advantage Accounts, except for trustee-directed 401(a) Accounts; and for non-qualified Accounts in the following Advisory Programs: SPS Advisor Accounts, Signature Wealth, Active Portfolios® Accounts, Select Separate Accounts, Vista Separate Accounts, Investor Unified Accounts, and Access Accounts. • Ameriprise Bank Insured Sweep Account (“ABISA”) is the Sweep Program offered for SPS Advantage trustee- directed 401(a) Accounts and qualified Accounts in the following Advisory Programs: SPS Advisor Accounts, Signature Wealth, Active Portfolios® Accounts, Select Separate Accounts, Vista Separate Accounts, Investor Unified Accounts, and Access Accounts. AEIS receives and retains compensation from Program Banks for its services related to AIMMA for the Managed Account Programs, based on the cash deposits held at each Program Bank. This compensation is either negotiated between each Program Bank and AEIS, or between the Program Bank and our vendor, IntraFi, and is either a fixed rate or is based on a benchmark interest rate, such as the Federal Funds Rate, plus or minus a spread. You can find up-to-date information on the revenue AEIS receives from unaffiliated Program Banks participating in AIMMA at ameriprise.com/products/ investments/brokerage-sweep-options. • Either Dreyfus Government Cash Management – Institutional Shares or the Dreyfus Government Cash Ameriprise Bank does not compensate AEIS for its sweep services provided or for the cash deposits held at Ameriprise Bank but reimburses AEIS for its direct out-of-pocket expenses related to AIMMA. Your financial advisor does not receive any of (i) the compensation paid by the Program Banks; or (ii) the reimbursements paid by Ameriprise Bank to AEIS. ABISA Management – Wealth Share are the Sweep Program offered for TSCA/403(b) brokerage accounts and Managed Accounts and personal trust services Ameriprise brokerage accounts and Managed Accounts opened by Ameriprise Bank as trustee and certain other non-qualified Ameriprise brokerage accounts and Managed Accounts that are ineligible for an insured deposit Sweep Program. For existing accounts that have Dreyfus General Government Securities Money Market Fund – Dreyfus Class sweep option, effective May 2021 that sweep option will change to the Dreyfus Government Cash Management – Wealth Shares. An investment in a money market fund is not a bank deposit and is not insured or guaranteed by the FDIC or any other government agency. Rates and yields vary across the different Sweep Programs and maybe be higher or lower depending on the particular money market fund or interest-bearing bank deposit product, and on the cash balance you maintain in your account. ABISA is an interest-bearing single bank deposit product made available by Ameriprise Financial Services. Deposits into ABISA are held in an omnibus account(s) at Ameriprise Bank, Member FDIC, an affiliate of Ameriprise Financial. Ameriprise Bank serves as custodian for the cash balances held within accounts that are swept to ABISA, as described in the Other Important Brokerage Disclosures. Single bank deposit products are eligible for FDIC insurance, subject to certain conditions, up to $250,000 per depositor ($500,000 for joint accounts), per FDIC rules. For any amount above the applicable limit, the amount above the limit will not be eligible for FDIC deposit insurance. Deposit products are not covered by SIPC. If your account uses ABISA as its Sweep Program, Ameriprise Bank earns spread revenue, the difference between what it pays in interest and what it earns on its investments. Ameriprise Bank does not compensate AEIS for its sweep services provided or for the cash deposits held at Ameriprise Bank but reimburses AEIS for its direct out-of-pocket expenses related to ABISA. Your financial advisor does not receive any of (i) the compensation earned by Ameriprise Bank; or (ii) the reimbursements paid by Ameriprise Bank to AEIS. If you decline the Sweep Program offered for your account(s), or if you subsequently revoke your acceptance, you may at any time direct Ameriprise Financial Services to (i) hold your Sweep Program balance as a free credit balance in your account(s); (ii) return the proceeds to your account(s) for investment in a cash equivalent investment product; or (iii) have us remit the cash to you. Cash held as a free credit balance is eligible for coverage by SIPC, up to $250,000 per capacity as determined by SIPC. Cash held as a free credit balance is not eligible for FDIC coverage. We may earn interest or other revenue on the balance but are not obligated to pay interest on cash held as a credit balance in your account(s). 9 10 Sweep program and expenses AIMMA Your Ameriprise accounts will from time to time receive and disburse cash. Cash received can be in the form of deposits you make to your account, the proceeds from investments you sell, and the receipt of dividend and interest payments from investments you own. Cash is disbursed from your account to pay for new investment products you buy, to cover debit card, ACH or bill pay activity, and to pay the Asset-based Fee for a Managed Account and other fees you may incur. Any portion of your account balance that is held in cash will be included in the Asset-based Fee calculation. On a daily basis, Ameriprise Financial Services will move all uninvested cash into the Sweep Program applied to your Account(s). The Sweep Programs may pay interest or dividends. By authorizing Ameriprise Financial Services to open an account, you expressly authorize Ameriprise Financial Services to move such cash balances. AIMMA is an interest-bearing multi-bank deposit product made available by Ameriprise Financial and held in an omnibus account(s) at one or more FDIC member banks (collectively, the "Program Banks"). Our affiliate, Ameriprise Bank, FSB (“Ameriprise Bank”) is a Program Bank and participates in AIMMA. The Program Banks may serve individually as custodians for all or a portion of the cash balance held within your account that are swept to AIMMA, as described in the Other Important Brokerage Disclosures document. Multi-bank deposit products are eligible for FDIC insurance, subject to certain conditions, up to $250,000 per depositor ($500,000 for joint ownerships) per Program Bank, including deposits held at Ameriprise Bank, and, under ordinary business conditions, up to $2.5 million per depositor ($5 million for joint ownerships) across all Program Banks combined, per FDIC rules. For any amount above the applicable limit that is deposited in a single Program Bank, including any other FDIC insured product you may own through that Program Bank, the amount above the limit will not be eligible for FDIC deposit insurance. Deposit products are not covered by the SIPC. Regardless of the Sweep Program made available to you, you can also buy and sell positional money market mutual funds, brokered certificates of deposit, treasury bills, and other similar cash-equivalent products to manage cash in your non-discretionary Managed Accounts and Ameriprise brokerage accounts, and such investment products may be available for you buy and sell in certain discretionary Managed Accounts. These options for the investment of cash balances are generally expected to offer higher returns than the Sweep Program we make available for your account. Some types of investment products may not be available to you under the terms of your specific account. If your account uses AIMMA as its Sweep Program, you agree to accept the proprietary algorithm applied by IntraFi LLC (“IntraFi”), which determines the Program Banks into which your deposits are placed. You also understand and agree that IntraFi will periodically change the order of the Program Banks to optimize the amount of FDIC insurance available in the AIMMA Sweep Program. Under ordinary business conditions, changes to the Program Bank List will be published at least five business days prior to the effective date, and current interest rates for each interest rate tier will be published three to five business days prior to their effective date. The Program Banks are identified on the Program Bank List and interest rate information is available at Ameriprise.com/cashrates. More detail regarding Sweep Programs offered by Ameriprise Financial Services is available in the Other Important Brokerage Disclosures document and the Money Settlement Options section of the Ameriprise Brokerage Client Agreement. For a copy of the Other Important Brokerage Disclosures or the Ameriprise Brokerage Client Agreement, visit our website at ameriprise.com/disclosures or call our service line at 800.862.7919. The Sweep Programs offered in Managed Accounts are: • Ameriprise Insured Money Market Account ("AIMMA") is the Sweep Program offered for Ameriprise brokerage Any cash in your account(s) that is swept to AIMMA is aggregated with cash held by other Ameriprise clients that utilize AIMMA and is held in an omnibus account at one or more Program Banks. Omnibus accounts, by virtue of their ability to raise significant balances for the Program Banks, are generally able to earn higher interest rates than those you would be able to earn if you deposited cash individually at a bank. The Program Banks participating in AIMMA earn income by lending or investing the deposits they receive and charging a higher interest rate to borrowers, or earning a higher yield, than the Program Banks pay on the deposits held through AIMMA. This difference is known as the "spread." Like the unaffiliated Program Banks participating in AIMMA, Ameriprise Bank earns spread revenue when it participates in AIMMA as a Program Bank. accounts, SPS Advantage Accounts, except for trustee-directed 401(a) Accounts; and for non-qualified Accounts in the following Advisory Programs: SPS Advisor Accounts, Signature Wealth, Active Portfolios® Accounts, Select Separate Accounts, Vista Separate Accounts, Investor Unified Accounts, and Access Accounts. • Ameriprise Bank Insured Sweep Account (“ABISA”) is the Sweep Program offered for SPS Advantage trustee- directed 401(a) Accounts and qualified Accounts in the following Advisory Programs: SPS Advisor Accounts, Signature Wealth, Active Portfolios® Accounts, Select Separate Accounts, Vista Separate Accounts, Investor Unified Accounts, and Access Accounts. AEIS receives and retains compensation from Program Banks for its services related to AIMMA for the Managed Account Programs, based on the cash deposits held at each Program Bank. This compensation is either negotiated between each Program Bank and AEIS, or between the Program Bank and our vendor, IntraFi, and is either a fixed rate or is based on a benchmark interest rate, such as the Federal Funds Rate, plus or minus a spread. You can find up-to-date information on the revenue AEIS receives from unaffiliated Program Banks participating in AIMMA at ameriprise.com/products/ investments/brokerage-sweep-options. • Either Dreyfus Government Cash Management – Institutional Shares or the Dreyfus Government Cash Ameriprise Bank does not compensate AEIS for its sweep services provided or for the cash deposits held at Ameriprise Bank but reimburses AEIS for its direct out-of-pocket expenses related to AIMMA. Your financial advisor does not receive any of (i) the compensation paid by the Program Banks; or (ii) the reimbursements paid by Ameriprise Bank to AEIS. ABISA Management – Wealth Share are the Sweep Program offered for TSCA/403(b) brokerage accounts and Managed Accounts and personal trust services Ameriprise brokerage accounts and Managed Accounts opened by Ameriprise Bank as trustee and certain other non-qualified Ameriprise brokerage accounts and Managed Accounts that are ineligible for an insured deposit Sweep Program. For existing accounts that have Dreyfus General Government Securities Money Market Fund – Dreyfus Class sweep option, effective May 2021 that sweep option will change to the Dreyfus Government Cash Management – Wealth Shares. An investment in a money market fund is not a bank deposit and is not insured or guaranteed by the FDIC or any other government agency. Rates and yields vary across the different Sweep Programs and maybe be higher or lower depending on the particular money market fund or interest-bearing bank deposit product, and on the cash balance you maintain in your account. ABISA is an interest-bearing single bank deposit product made available by Ameriprise Financial Services. Deposits into ABISA are held in an omnibus account(s) at Ameriprise Bank, Member FDIC, an affiliate of Ameriprise Financial. Ameriprise Bank serves as custodian for the cash balances held within accounts that are swept to ABISA, as described in the Other Important Brokerage Disclosures. Single bank deposit products are eligible for FDIC insurance, subject to certain conditions, up to $250,000 per depositor ($500,000 for joint accounts), per FDIC rules. For any amount above the applicable limit, the amount above the limit will not be eligible for FDIC deposit insurance. Deposit products are not covered by SIPC. If your account uses ABISA as its Sweep Program, Ameriprise Bank earns spread revenue, the difference between what it pays in interest and what it earns on its investments. Ameriprise Bank does not compensate AEIS for its sweep services provided or for the cash deposits held at Ameriprise Bank but reimburses AEIS for its direct out-of-pocket expenses related to ABISA. Your financial advisor does not receive any of (i) the compensation earned by Ameriprise Bank; or (ii) the reimbursements paid by Ameriprise Bank to AEIS. If you decline the Sweep Program offered for your account(s), or if you subsequently revoke your acceptance, you may at any time direct Ameriprise Financial Services to (i) hold your Sweep Program balance as a free credit balance in your account(s); (ii) return the proceeds to your account(s) for investment in a cash equivalent investment product; or (iii) have us remit the cash to you. Cash held as a free credit balance is eligible for coverage by SIPC, up to $250,000 per capacity as determined by SIPC. Cash held as a free credit balance is not eligible for FDIC coverage. We may earn interest or other revenue on the balance but are not obligated to pay interest on cash held as a credit balance in your account(s). 9 10 Money market fund Termination of AFPS If your account's Sweep Program uses a money market mutual fund, our affiliate AEIS may receive marketing support payments of up to 0.37% of the amount held in that money market mutual fund Sweep Program. Please refer to the applicable prospectus or the “Cost reimbursement services and third-party payments” sub-section for further specific details regarding mutual fund marketing and sales support payments received by AEIS. An investment in a money market fund is not a bank deposit and is not insured or guaranteed by the FDIC or any other government agency. AFPS will remain in effect until one of the following occurs: termination by you; termination of an existing AFPS Agreement by replacing it with a new one, as described in the preceding paragraph; termination by Ameriprise Financial Services, which would require sending you written notice reasonably in advance of the termination date (except as noted in this paragraph) to your address as shown on our records; termination by Ameriprise Financial Services, with no advance notice, for non-delivery of services to you by your financial advisor; or termination by you through nonpayment of the AFPS fee. Affiliate compensation If you choose to terminate the Agreement during the first year before receiving your initial recommendations, you will receive a full refund of AFPS Fees paid. However, if you terminate at any time after Ameriprise Financial Services has performed under this Agreement, or if you terminate the services and have not provided your financial advisor with complete and accurate information concerning your financial situation, Ameriprise Financial Services reserves the right in its sole discretion to limit the amount of the refund you receive, if any. Sweep Programs made available in accounts are offered by Ameriprise Financial Services in its capacity as a broker-dealer, and services are provided by our affiliate AEIS as part of the overall brokerage services provided to your account(s) pursuant to the “Money Settlement Options” section of the Ameriprise Brokerage Client Agreement. Your financial advisor does not recommend the Sweep Program offered to you for any particular account(s) and revenues received by our affiliates related to the Sweep Programs are not shared with financial advisors. To terminate or cancel the Agreement and request a refund, if eligible, complete an AFPS Cancellation and Refund Request form available from ameriprise.com. You may also request the form from your financial advisor or by calling Ameriprise Financial Services directly at 800.862.7919 between the hours of 7 a.m. and 6 p.m. Central time, Monday through Friday. Generally, the combined revenue earned by our affiliates AEIS and Ameriprise Bank is excepted to be (i) the highest when your account sweeps cash into ABISA or AIMMA where Ameriprise Bank is utilized as a Program Bank; (ii) the second highest when your account sweeps cash into AIMMA where unaffiliated Program Banks are utilized; and (iii) the lowest when your account sweeps cash into an eligible money market mutual fund. Performance-Based Fees and Side-by-Side Management Neither Ameriprise Financial Services nor any of its supervised persons accepts performance-based fees for its investment advisory services. Our affiliates AEIS and Ameriprise Bank use this revenue to defray the cost of operating our Sweep Programs and the expense of providing other services to our clients, as well as for general operating expenses and to provide net earnings to AEIS and Ameriprise Bank. In the absence of this revenue Ameriprise Financial Services would likely charge higher fees or other charges to clients for the services AEIS and Ameriprise Bank provide to clients. Ameriprise Financial Services addresses this conflict of interest through a combination of disclosures and policies and procedures regarding Sweep Program availability and the free-credit balance, as well as supervision and surveillance of cash balances held in Managed Accounts. Client programs and promotions Types of Clients AFPS is generally appropriate for individuals who seek an ongoing fee-based financial planning relationship and who have financial goals and sufficient assets and income to begin addressing those goals. AFPS is intended for individuals, couples, and entities with financial planning needs, such as trusts, estates, nonprofit organizations and businesses. Methods of Analysis, Investment Strategies and Risk of Loss Ameriprise Financial Services may provide a fee reduction to corporate, institutional or membership organizations and their employees, partners, independent contractors or members. Ameriprise Financial Services may, from time to time, offer reduced fees on AFPS to individuals in a particular market segment or geographic area. Your financial advisor can tell you whether there is a promotion available to you. Methods of financial analysis Ameriprise Financial Services, in its sole discretion, determines when to offer, modify and/or discontinue these promotions and programs. These promotions and programs are not available to financial advisors from the Ameriprise Personal Wealth Group. Pro bono financial planning Ameriprise Financial advisors may seek approval from Ameriprise Financial Services to offer, on a limited basis, pro bono financial planning to persons who otherwise cannot afford to pay for financial planning services. These promotions and programs are not available to financial advisors from the Ameriprise Personal Wealth Group. Institutional services When developing recommendations for you, your financial advisor compares your stated financial goals with your financial situation, investment risk tolerance, investment horizon and the risk and potential investment solutions. Your financial advisor may use asset value, current and projected rates of return, and other assumptions you provide, as well as historical return analysis prepared by Ameriprise Financial Services or an affiliate. Your financial plan may be prepared through the use of one or more software packages that take a needs-based approach to analyze your goals using one or more methods of analysis, including deterministic and probability modeling. The analysis and projections generated by the tools or other analysis described in this section of the Brochure include information regarding the likelihood of various potential investment outcomes. They are hypothetical in nature, vary depending on which tool of analysis is used and with each use and over time, do not reflect actual investment results, and are not guarantees of future results. Investing in securities involves the risk of loss and you should be prepared to bear this loss. The probability of success also varies based on differing assumptions, on different tools and from one Engagement Period to the next based on changing circumstances and market information. Results may reflect one point in time only and are only one factor you should consider as you determine how best to plan for your future. Ameriprise Financial Services may enter into written agreements with corporate, institutional or membership organizations to provide AFPS to their employees, partners, independent contractors or members. The fees for institutional services vary by agreement. These agreements may include other services and fees that are lower than the AFPS fees paid by other AFPS clients. Your financial plan also may include an asset allocation analysis designed to assist you in positioning your investment assets. If your financial plan includes such analysis, the recommended portfolio allocation will be These promotions and programs are not available to financial advisors from the Ameriprise Advisor Center Personal Wealth Group. 11 12 Money market fund Termination of AFPS If your account's Sweep Program uses a money market mutual fund, our affiliate AEIS may receive marketing support payments of up to 0.37% of the amount held in that money market mutual fund Sweep Program. Please refer to the applicable prospectus or the “Cost reimbursement services and third-party payments” sub-section for further specific details regarding mutual fund marketing and sales support payments received by AEIS. An investment in a money market fund is not a bank deposit and is not insured or guaranteed by the FDIC or any other government agency. AFPS will remain in effect until one of the following occurs: termination by you; termination of an existing AFPS Agreement by replacing it with a new one, as described in the preceding paragraph; termination by Ameriprise Financial Services, which would require sending you written notice reasonably in advance of the termination date (except as noted in this paragraph) to your address as shown on our records; termination by Ameriprise Financial Services, with no advance notice, for non-delivery of services to you by your financial advisor; or termination by you through nonpayment of the AFPS fee. Affiliate compensation If you choose to terminate the Agreement during the first year before receiving your initial recommendations, you will receive a full refund of AFPS Fees paid. However, if you terminate at any time after Ameriprise Financial Services has performed under this Agreement, or if you terminate the services and have not provided your financial advisor with complete and accurate information concerning your financial situation, Ameriprise Financial Services reserves the right in its sole discretion to limit the amount of the refund you receive, if any. Sweep Programs made available in accounts are offered by Ameriprise Financial Services in its capacity as a broker-dealer, and services are provided by our affiliate AEIS as part of the overall brokerage services provided to your account(s) pursuant to the “Money Settlement Options” section of the Ameriprise Brokerage Client Agreement. Your financial advisor does not recommend the Sweep Program offered to you for any particular account(s) and revenues received by our affiliates related to the Sweep Programs are not shared with financial advisors. To terminate or cancel the Agreement and request a refund, if eligible, complete an AFPS Cancellation and Refund Request form available from ameriprise.com. You may also request the form from your financial advisor or by calling Ameriprise Financial Services directly at 800.862.7919 between the hours of 7 a.m. and 6 p.m. Central time, Monday through Friday. Generally, the combined revenue earned by our affiliates AEIS and Ameriprise Bank is excepted to be (i) the highest when your account sweeps cash into ABISA or AIMMA where Ameriprise Bank is utilized as a Program Bank; (ii) the second highest when your account sweeps cash into AIMMA where unaffiliated Program Banks are utilized; and (iii) the lowest when your account sweeps cash into an eligible money market mutual fund. Performance-Based Fees and Side-by-Side Management Neither Ameriprise Financial Services nor any of its supervised persons accepts performance-based fees for its investment advisory services. Our affiliates AEIS and Ameriprise Bank use this revenue to defray the cost of operating our Sweep Programs and the expense of providing other services to our clients, as well as for general operating expenses and to provide net earnings to AEIS and Ameriprise Bank. In the absence of this revenue Ameriprise Financial Services would likely charge higher fees or other charges to clients for the services AEIS and Ameriprise Bank provide to clients. Ameriprise Financial Services addresses this conflict of interest through a combination of disclosures and policies and procedures regarding Sweep Program availability and the free-credit balance, as well as supervision and surveillance of cash balances held in Managed Accounts. Client programs and promotions Types of Clients AFPS is generally appropriate for individuals who seek an ongoing fee-based financial planning relationship and who have financial goals and sufficient assets and income to begin addressing those goals. AFPS is intended for individuals, couples, and entities with financial planning needs, such as trusts, estates, nonprofit organizations and businesses. Methods of Analysis, Investment Strategies and Risk of Loss Ameriprise Financial Services may provide a fee reduction to corporate, institutional or membership organizations and their employees, partners, independent contractors or members. Ameriprise Financial Services may, from time to time, offer reduced fees on AFPS to individuals in a particular market segment or geographic area. Your financial advisor can tell you whether there is a promotion available to you. Methods of financial analysis Ameriprise Financial Services, in its sole discretion, determines when to offer, modify and/or discontinue these promotions and programs. These promotions and programs are not available to financial advisors from the Ameriprise Personal Wealth Group. Pro bono financial planning Ameriprise Financial advisors may seek approval from Ameriprise Financial Services to offer, on a limited basis, pro bono financial planning to persons who otherwise cannot afford to pay for financial planning services. These promotions and programs are not available to financial advisors from the Ameriprise Personal Wealth Group. Institutional services When developing recommendations for you, your financial advisor compares your stated financial goals with your financial situation, investment risk tolerance, investment horizon and the risk and potential investment solutions. Your financial advisor may use asset value, current and projected rates of return, and other assumptions you provide, as well as historical return analysis prepared by Ameriprise Financial Services or an affiliate. Your financial plan may be prepared through the use of one or more software packages that take a needs-based approach to analyze your goals using one or more methods of analysis, including deterministic and probability modeling. The analysis and projections generated by the tools or other analysis described in this section of the Brochure include information regarding the likelihood of various potential investment outcomes. They are hypothetical in nature, vary depending on which tool of analysis is used and with each use and over time, do not reflect actual investment results, and are not guarantees of future results. Investing in securities involves the risk of loss and you should be prepared to bear this loss. The probability of success also varies based on differing assumptions, on different tools and from one Engagement Period to the next based on changing circumstances and market information. Results may reflect one point in time only and are only one factor you should consider as you determine how best to plan for your future. Ameriprise Financial Services may enter into written agreements with corporate, institutional or membership organizations to provide AFPS to their employees, partners, independent contractors or members. The fees for institutional services vary by agreement. These agreements may include other services and fees that are lower than the AFPS fees paid by other AFPS clients. Your financial plan also may include an asset allocation analysis designed to assist you in positioning your investment assets. If your financial plan includes such analysis, the recommended portfolio allocation will be These promotions and programs are not available to financial advisors from the Ameriprise Advisor Center Personal Wealth Group. 11 12 determined based on a variety of factors, including your personal financial information and the historical and anticipated performance of different asset classes. Neither Ameriprise Financial nor your financial advisor has undertaken to review or verify the accuracy of Non- Held Assets and the inclusion of information and assumptions about Non-Held Assets in your AFPS written recommendations, or any other analysis, review, or guidance offered by Ameriprise Financial Services and your financial advisor creates no duty or other responsibility to advise you to take any action or inaction regarding such Non-Held Assets. Third-party research provider materials not approved for use with clients The analysis is meant only to illustrate the relative experience among asset classes and portfolios. Periodic rebalancing of your portfolio and reallocation among the asset classes is recommended in most circumstances, and rebalancing and reallocation may not be part of AFPS. Rebalancing your non-qualified portfolio to meet asset allocation objectives may result in taxable gains or losses. Unless included in a particular Ameriprise Managed Account Program, Ameriprise Financial Services does not rebalance your portfolio or reallocate your target asset allocations on a continuous basis. If you have a substantial percentage of your net worth concentrated in a given asset or asset class, the illustrations may prompt your financial advisor to recommend that you sell or exchange a significant portion of such position to reduce risk by reducing the concentrated positions within your portfolio. From time to time, financial advisors may access research, models, investment tools or other material from third- party research providers that are not approved for use with clients for the purposes of the financial advisor’s general education, staying current on industry trends or developing potential investment ideas. Financial advisors may provide clients with general market commentary or non-security information once the individual pieces have been approved for use by Ameriprise Financial Services. Special tax rules apply to net unrealized appreciation of employer securities held in a retirement plan. This is particularly true if the asset in question is stock of your employer, given that both your income and investment could be tied to the profitability of your employer. Investment strategies Before you actually sell any such assets, consult with your legal and tax professionals regarding the tax and other implications of any such sales. The asset allocation analysis does not provide a comprehensive financial analysis of your ability to reach your other financial planning goals, and it does not identify the impact of your investment strategy on your tax and estate planning situations. Asset allocation does not guarantee a profit or protect against a loss. Sources of information Your financial advisor may recommend long-term strategies for your financial plan, such as dollar-cost averaging, reinvestment of dividends or other proceeds on investments, and asset allocation. Recommendations may also be made to help you realize capital gains or losses on securities or investment products that you own. Such transactions may have tax consequences for non-qualified accounts. See the “Implementation of your financial planning recommendations” subsection of the "Advisory Business" section and the “Broker-dealer” subsection of the “Other Financial Industry Activities and Affiliations” section for further information on investment products and services offered by Ameriprise Financial Services. We cannot guarantee future financial results or the achievement of your financial goals through implementation of your financial plan and any advice or recommendations provided to you. Ameriprise Financial Services does not monitor the day-to-day performance of your specific investments. Before implementing your financial plan, you should consider carefully the ramifications of purchasing products or services, and you may want to seek further advice from your lawyer and/or accountant, particularly in connection with estate planning, taxes or small business owner planning issues. The benefits and advantages of cash value life insurance generally increase as the policy matures and are most fully realized with the death of the insured. A client with immediate liquidity needs may consider whether to sell the policy to a third party at a discounted value (commonly referred to as a life settlement). The principal source of information used by your financial advisor is the data provided by you, such as your personal data, assets and liabilities, income expectations, assumed overall rates of interest and inflation, short- term and long-term financial goals, tax information, risk tolerance associated with goals, and other relevant information. When developing product recommendations, your financial advisor may also use training and marketing materials and prospectuses and annual reports for a particular investment product. In addition, your financial advisor may also utilize research produced by Ameriprise Financial Services or its affiliates, such as material prepared by the Ameriprise Investment Research Group ("IRG") or from third-party research providers that have been approved by Ameriprise Financial Services when providing investment advice. Although the information and data are believed to be accurate, Ameriprise Financial Services and its financial advisors do not independently verify third-party information. Neither Ameriprise Financial Services nor its financial advisors guarantee the accuracy, completeness or timeliness of any such information nor do they imply any warranty of any kind regarding the information provided. Disciplinary Information Below is notice of certain regulatory and legal settlements entered into by Ameriprise Financial Services during the last ten years: Regulatory proceedings For your accounts held at Ameriprise Financial, if any, market value (i.e., account value) is provided from the source of record and is generally captured at a point in time. If the date and market value displayed in analysis or written recommendations you receive does not correspond with the date and market value of your official Ameriprise Financial consolidated statement, the market values shown on the material you receive will differ from your consolidated statement. Ameriprise Financial Services entered into each of the regulatory settlements listed below without admitting or denying the allegations. The information provided to you in your analysis and written recommendations is not intended to be a substitute for the valuation and other information contained in your official Ameriprise Financial consolidated statement. Securities and Exchange Commission (“SEC”) and FINRA actions For your accounts and assets not held at Ameriprise Financial (“Non-Held Assets”) all asset and net worth information used in connection with your AFPS was provided by you or your designated agents and is shown as of the date it was provided to Ameriprise Financial Services. Ameriprise Financial services does not have knowledge of changes in your Non-Held Assets, including your accounts and portfolio holdings, and the materials provided in connection with your AFPS will not reflect changes to your Non-Held Assets. This means that if you view your AFPS materials without updating your Non-Held Assets, the information and assumptions provided to you will be based on data about Non-Held Assets that is not current. Ameriprise Financial and your financial advisor take reasonable steps to reproduce information obtained from you or your designated agents regarding Non-Held Assets. In August 2024, Ameriprise Financial Services reached a settlement with the SEC in connection with its industry- wide review of firms’ recordkeeping practices regarding business-related electronic communications sent or received by firm personnel using non-approved channels or methods (“off-channel communications”). The settlement resolved allegations that, from at least June 2019, the firm did not maintain or preserve a substantial majority of off-channel communications that were records required to be maintained under federal securities laws and therefore failed to reasonably supervise its personnel. The firm agreed to pay a civil penalty amount of $50 million. Prior to the settlement, the firm retained a compliance consultant to address certain undertakings outlined in the settlement and took steps to enhance its policies and procedures and increase training concerning the use of approved communications methods. 13 14 determined based on a variety of factors, including your personal financial information and the historical and anticipated performance of different asset classes. Neither Ameriprise Financial nor your financial advisor has undertaken to review or verify the accuracy of Non- Held Assets and the inclusion of information and assumptions about Non-Held Assets in your AFPS written recommendations, or any other analysis, review, or guidance offered by Ameriprise Financial Services and your financial advisor creates no duty or other responsibility to advise you to take any action or inaction regarding such Non-Held Assets. Third-party research provider materials not approved for use with clients The analysis is meant only to illustrate the relative experience among asset classes and portfolios. Periodic rebalancing of your portfolio and reallocation among the asset classes is recommended in most circumstances, and rebalancing and reallocation may not be part of AFPS. Rebalancing your non-qualified portfolio to meet asset allocation objectives may result in taxable gains or losses. Unless included in a particular Ameriprise Managed Account Program, Ameriprise Financial Services does not rebalance your portfolio or reallocate your target asset allocations on a continuous basis. If you have a substantial percentage of your net worth concentrated in a given asset or asset class, the illustrations may prompt your financial advisor to recommend that you sell or exchange a significant portion of such position to reduce risk by reducing the concentrated positions within your portfolio. From time to time, financial advisors may access research, models, investment tools or other material from third- party research providers that are not approved for use with clients for the purposes of the financial advisor’s general education, staying current on industry trends or developing potential investment ideas. Financial advisors may provide clients with general market commentary or non-security information once the individual pieces have been approved for use by Ameriprise Financial Services. Special tax rules apply to net unrealized appreciation of employer securities held in a retirement plan. This is particularly true if the asset in question is stock of your employer, given that both your income and investment could be tied to the profitability of your employer. Investment strategies Before you actually sell any such assets, consult with your legal and tax professionals regarding the tax and other implications of any such sales. The asset allocation analysis does not provide a comprehensive financial analysis of your ability to reach your other financial planning goals, and it does not identify the impact of your investment strategy on your tax and estate planning situations. Asset allocation does not guarantee a profit or protect against a loss. Sources of information Your financial advisor may recommend long-term strategies for your financial plan, such as dollar-cost averaging, reinvestment of dividends or other proceeds on investments, and asset allocation. Recommendations may also be made to help you realize capital gains or losses on securities or investment products that you own. Such transactions may have tax consequences for non-qualified accounts. See the “Implementation of your financial planning recommendations” subsection of the "Advisory Business" section and the “Broker-dealer” subsection of the “Other Financial Industry Activities and Affiliations” section for further information on investment products and services offered by Ameriprise Financial Services. We cannot guarantee future financial results or the achievement of your financial goals through implementation of your financial plan and any advice or recommendations provided to you. Ameriprise Financial Services does not monitor the day-to-day performance of your specific investments. Before implementing your financial plan, you should consider carefully the ramifications of purchasing products or services, and you may want to seek further advice from your lawyer and/or accountant, particularly in connection with estate planning, taxes or small business owner planning issues. The benefits and advantages of cash value life insurance generally increase as the policy matures and are most fully realized with the death of the insured. A client with immediate liquidity needs may consider whether to sell the policy to a third party at a discounted value (commonly referred to as a life settlement). The principal source of information used by your financial advisor is the data provided by you, such as your personal data, assets and liabilities, income expectations, assumed overall rates of interest and inflation, short- term and long-term financial goals, tax information, risk tolerance associated with goals, and other relevant information. When developing product recommendations, your financial advisor may also use training and marketing materials and prospectuses and annual reports for a particular investment product. In addition, your financial advisor may also utilize research produced by Ameriprise Financial Services or its affiliates, such as material prepared by the Ameriprise Investment Research Group ("IRG") or from third-party research providers that have been approved by Ameriprise Financial Services when providing investment advice. Although the information and data are believed to be accurate, Ameriprise Financial Services and its financial advisors do not independently verify third-party information. Neither Ameriprise Financial Services nor its financial advisors guarantee the accuracy, completeness or timeliness of any such information nor do they imply any warranty of any kind regarding the information provided. Disciplinary Information Below is notice of certain regulatory and legal settlements entered into by Ameriprise Financial Services during the last ten years: Regulatory proceedings For your accounts held at Ameriprise Financial, if any, market value (i.e., account value) is provided from the source of record and is generally captured at a point in time. If the date and market value displayed in analysis or written recommendations you receive does not correspond with the date and market value of your official Ameriprise Financial consolidated statement, the market values shown on the material you receive will differ from your consolidated statement. Ameriprise Financial Services entered into each of the regulatory settlements listed below without admitting or denying the allegations. The information provided to you in your analysis and written recommendations is not intended to be a substitute for the valuation and other information contained in your official Ameriprise Financial consolidated statement. Securities and Exchange Commission (“SEC”) and FINRA actions For your accounts and assets not held at Ameriprise Financial (“Non-Held Assets”) all asset and net worth information used in connection with your AFPS was provided by you or your designated agents and is shown as of the date it was provided to Ameriprise Financial Services. Ameriprise Financial services does not have knowledge of changes in your Non-Held Assets, including your accounts and portfolio holdings, and the materials provided in connection with your AFPS will not reflect changes to your Non-Held Assets. This means that if you view your AFPS materials without updating your Non-Held Assets, the information and assumptions provided to you will be based on data about Non-Held Assets that is not current. Ameriprise Financial and your financial advisor take reasonable steps to reproduce information obtained from you or your designated agents regarding Non-Held Assets. In August 2024, Ameriprise Financial Services reached a settlement with the SEC in connection with its industry- wide review of firms’ recordkeeping practices regarding business-related electronic communications sent or received by firm personnel using non-approved channels or methods (“off-channel communications”). The settlement resolved allegations that, from at least June 2019, the firm did not maintain or preserve a substantial majority of off-channel communications that were records required to be maintained under federal securities laws and therefore failed to reasonably supervise its personnel. The firm agreed to pay a civil penalty amount of $50 million. Prior to the settlement, the firm retained a compliance consultant to address certain undertakings outlined in the settlement and took steps to enhance its policies and procedures and increase training concerning the use of approved communications methods. 13 14 In August 2018, Ameriprise Financial Services reached a settlement with the SEC regarding allegations that from 2011 through 2014 the firm failed to adopt and implement policies and procedures reasonably designed to safeguard retail investor assets against misappropriation and failed to reasonably supervise five representatives with a view to preventing and detecting violations of certain federal securities laws by these representatives. The firm agreed to pay a civil penalty amount of $4.5 million. The firm further reimbursed all impacted clients for the losses they incurred due to the misconduct. The firm also took steps to enhance policies, procedures and controls related to the safeguarding of client assets against theft or misappropriation by its associated persons and voluntarily retained a compliance consultant to assess and confirm the reasonableness of these policies, procedures and controls. Retail brokerage services are made available through Ameriprise Financial Services, which has an agreement with American Enterprise Investment Services Inc. (“AEIS”), a registered broker-dealer and an affiliate of Ameriprise Financial Services. Ameriprise Financial Services requires clients to agree in their client agreements that their account(s) are introduced by Ameriprise Financial Services to AEIS on a fully disclosed basis, and that securities purchase and sale transactions in their account(s) shall be directed through AEIS. You should consider that not all investment advisory firms require clients to direct execution of transactions through a specific broker-dealer. Brokerage accounts are carried by, and brokerage transactions are cleared and settled through, AEIS, subject to AEIS policies to assure that the resultant price to the client is as favorable as possible under the prevailing market conditions. See the “Working in Your Best Interest-Regulation Best Interest Disclosure” for more information about potential conflicts of interest relating to brokerage transactions. For purposes of Form ADV Part 2 certain Ameriprise Financial Services management persons are registered representatives of Ameriprise Financial Services in its capacity as a broker-dealer, registered representatives of American Enterprise Investment Services Inc., and are associated persons of Ameriprise Financial Services in its capacity as a commodity trading advisor. In December 2017, Ameriprise Financial Services reached a settlement with the SEC regarding allegations that from December 2010 through October 2013, the firm negligently relied on misrepresentations made by F-Squared Investments, Inc. regarding certain of its ETF portfolios and, as a result, the firm made false statements about the portfolios in certain advertisements. The SEC also alleged that the firm had failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the alleged violations. The firm agreed to pay a disgorgement amount of $6.3 million plus prejudgment interest of $700,000 and a civil penalty amount of $1.75 million. Ameriprise Financial Services approves and opens accounts and accepts securities order instructions with respect to the accounts. AEIS serves as Ameriprise Financial Services’ clearing agent in providing clearing and settlement services for transactions that are executed for customers of Ameriprise Financial Services. In exchange for a fee paid by Ameriprise Financial Services, AEIS provides clearing, custody, record keeping and all clearing functions for certain advice-based accounts. In addition, AEIS may act as an agent in effecting securities transactions for certain Ameriprise Bank trust accounts. In September 2016, Ameriprise Financial Services reached a settlement with FINRA regarding allegations that between October 2011 and September 2013 the firm failed to detect and prevent the conversion, via wire transfers, of more than $370,000 from five of its customers by one of its registered representatives. The customers were family members of the registered representative. FINRA also alleged this went undetected because the firm failed to establish, maintain, and enforce a supervisory system that was reasonably designed to review and monitor the transmittal of funds from accounts of customers to third parties, including those controlled by registered representatives of the firm. The firm paid restitution and a fine of $850,000. AMPF Holding LLC, an indirect wholly-owned subsidiary of Ameriprise Financial, Inc., is a holding company for Ameriprise Financial Services and AEIS. Columbia Management Investment Distributors, Inc. (“Columbia Management Investment Distributors”), an indirect wholly-owned subsidiary of Ameriprise Financial, Inc., is a registered broker-dealer serving as principal underwriter and distributor of registered mutual funds and other funds advised by affiliated companies Columbia Management Investment Advisers, LLC (“CMIA”) and Columbia Wanger Asset Management, LLC, (“Columbia Wanger Asset Management”) (collectively, “Columbia Management” or “Columbia”). These funds are collectively referred to as the “Columbia Funds.” Other financial industry activities and affiliations Ameriprise Financial Services, LLC is a subsidiary of Ameriprise Financial, Inc. and conducts its activities directly and through its affiliates. These activities may be material to its investment advisory business or its investment advisory clients. These affiliates include companies under common control with Ameriprise Financial Services by virtue of their status as direct or indirect subsidiaries of Ameriprise Financial, Inc. The information below provides you an overview of the Ameriprise Financial, Inc. companies. These companies work together to offer you financial products and services designed to help you reach your financial goals. Investment company Broker-dealer Ameriprise Financial Services has arrangements with Ameriprise Certificate Company to distribute and sell its face-amount certificates and selling arrangements with Columbia Management Investment Distributors to distribute the Columbia Funds. Investment advisory firm Columbia Management Investment Advisers, LLC (CMIA) is registered as an investment adviser with the SEC. CMIA provides investment management services to: Ameriprise Financial Services, LLC is a registered investment adviser and broker-dealer with the SEC and is authorized to engage in the securities business in all 50 states as well as the District of Columbia, Puerto Rico, and the U.S. Virgin Islands. Ameriprise Financial Services is also a member of FINRA and the Securities Investor Protection Corporation (“SIPC”). Ameriprise Financial Services is registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor (“CTA”) and has obtained membership with the National Futures Association (“NFA”) in connection with such CFTC registration. • Columbia Funds, as well as Columbia ETFs, closed-end funds and private funds • Ameriprise Certificate Company • RiverSource, as well as the Columbia Funds underlying certain variable contracts issued by RiverSource • Various wrap program sponsors, including Ameriprise Financial Services In its capacity as a broker-dealer, Ameriprise Financial Services distributes or receives compensation from selling various products including but not limited to equities and fixed income products. Offerings include corporate bonds and municipal securities, mutual fund shares, ETFs, 529 plans, face-amount certificates, closed-end funds, preferred securities, UITs, non-traded REITs, non-traded BDCs, non-traded closed end funds, hedge fund offerings, structured products, real estate private placement offerings, exchange funds, private equity offerings, 1031 exchanges, fixed, structured and variable annuities, and fixed and variable insurance. Ameriprise Financial Services also sells managed futures funds that engage in trading commodity interests, including futures. • Other affiliated and unaffiliated clients. In addition, Ameriprise Financial Services is the distributor of the publicly offered face-amount certificates issued by Ameriprise Certificate Company. Ameriprise Financial Services also may serve as an underwriter or member of a selling group for securities offerings, including those issued by affiliates. Ameriprise Financial, Inc. has other subsidiaries that are registered as investment advisers with the SEC, including, among others, Threadneedle International Limited, Pyrford International Ltd. and Lionstone Partners, LLC. These subsidiaries are registered as investment advisers and may provide advice to domestic and foreign institutional clients, the Columbia Funds, the Columbia ETFs, the Columbia closed-end funds, private funds and other fiduciary clients. These entities provide services independent from Ameriprise Financial Services. Columbia Management 15 16 In August 2018, Ameriprise Financial Services reached a settlement with the SEC regarding allegations that from 2011 through 2014 the firm failed to adopt and implement policies and procedures reasonably designed to safeguard retail investor assets against misappropriation and failed to reasonably supervise five representatives with a view to preventing and detecting violations of certain federal securities laws by these representatives. The firm agreed to pay a civil penalty amount of $4.5 million. The firm further reimbursed all impacted clients for the losses they incurred due to the misconduct. The firm also took steps to enhance policies, procedures and controls related to the safeguarding of client assets against theft or misappropriation by its associated persons and voluntarily retained a compliance consultant to assess and confirm the reasonableness of these policies, procedures and controls. Retail brokerage services are made available through Ameriprise Financial Services, which has an agreement with American Enterprise Investment Services Inc. (“AEIS”), a registered broker-dealer and an affiliate of Ameriprise Financial Services. Ameriprise Financial Services requires clients to agree in their client agreements that their account(s) are introduced by Ameriprise Financial Services to AEIS on a fully disclosed basis, and that securities purchase and sale transactions in their account(s) shall be directed through AEIS. You should consider that not all investment advisory firms require clients to direct execution of transactions through a specific broker-dealer. Brokerage accounts are carried by, and brokerage transactions are cleared and settled through, AEIS, subject to AEIS policies to assure that the resultant price to the client is as favorable as possible under the prevailing market conditions. See the “Working in Your Best Interest-Regulation Best Interest Disclosure” for more information about potential conflicts of interest relating to brokerage transactions. For purposes of Form ADV Part 2 certain Ameriprise Financial Services management persons are registered representatives of Ameriprise Financial Services in its capacity as a broker-dealer, registered representatives of American Enterprise Investment Services Inc., and are associated persons of Ameriprise Financial Services in its capacity as a commodity trading advisor. In December 2017, Ameriprise Financial Services reached a settlement with the SEC regarding allegations that from December 2010 through October 2013, the firm negligently relied on misrepresentations made by F-Squared Investments, Inc. regarding certain of its ETF portfolios and, as a result, the firm made false statements about the portfolios in certain advertisements. The SEC also alleged that the firm had failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the alleged violations. The firm agreed to pay a disgorgement amount of $6.3 million plus prejudgment interest of $700,000 and a civil penalty amount of $1.75 million. Ameriprise Financial Services approves and opens accounts and accepts securities order instructions with respect to the accounts. AEIS serves as Ameriprise Financial Services’ clearing agent in providing clearing and settlement services for transactions that are executed for customers of Ameriprise Financial Services. In exchange for a fee paid by Ameriprise Financial Services, AEIS provides clearing, custody, record keeping and all clearing functions for certain advice-based accounts. In addition, AEIS may act as an agent in effecting securities transactions for certain Ameriprise Bank trust accounts. In September 2016, Ameriprise Financial Services reached a settlement with FINRA regarding allegations that between October 2011 and September 2013 the firm failed to detect and prevent the conversion, via wire transfers, of more than $370,000 from five of its customers by one of its registered representatives. The customers were family members of the registered representative. FINRA also alleged this went undetected because the firm failed to establish, maintain, and enforce a supervisory system that was reasonably designed to review and monitor the transmittal of funds from accounts of customers to third parties, including those controlled by registered representatives of the firm. The firm paid restitution and a fine of $850,000. AMPF Holding LLC, an indirect wholly-owned subsidiary of Ameriprise Financial, Inc., is a holding company for Ameriprise Financial Services and AEIS. Columbia Management Investment Distributors, Inc. (“Columbia Management Investment Distributors”), an indirect wholly-owned subsidiary of Ameriprise Financial, Inc., is a registered broker-dealer serving as principal underwriter and distributor of registered mutual funds and other funds advised by affiliated companies Columbia Management Investment Advisers, LLC (“CMIA”) and Columbia Wanger Asset Management, LLC, (“Columbia Wanger Asset Management”) (collectively, “Columbia Management” or “Columbia”). These funds are collectively referred to as the “Columbia Funds.” Other financial industry activities and affiliations Ameriprise Financial Services, LLC is a subsidiary of Ameriprise Financial, Inc. and conducts its activities directly and through its affiliates. These activities may be material to its investment advisory business or its investment advisory clients. These affiliates include companies under common control with Ameriprise Financial Services by virtue of their status as direct or indirect subsidiaries of Ameriprise Financial, Inc. The information below provides you an overview of the Ameriprise Financial, Inc. companies. These companies work together to offer you financial products and services designed to help you reach your financial goals. Investment company Broker-dealer Ameriprise Financial Services has arrangements with Ameriprise Certificate Company to distribute and sell its face-amount certificates and selling arrangements with Columbia Management Investment Distributors to distribute the Columbia Funds. Investment advisory firm Columbia Management Investment Advisers, LLC (CMIA) is registered as an investment adviser with the SEC. CMIA provides investment management services to: Ameriprise Financial Services, LLC is a registered investment adviser and broker-dealer with the SEC and is authorized to engage in the securities business in all 50 states as well as the District of Columbia, Puerto Rico, and the U.S. Virgin Islands. Ameriprise Financial Services is also a member of FINRA and the Securities Investor Protection Corporation (“SIPC”). Ameriprise Financial Services is registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor (“CTA”) and has obtained membership with the National Futures Association (“NFA”) in connection with such CFTC registration. • Columbia Funds, as well as Columbia ETFs, closed-end funds and private funds • Ameriprise Certificate Company • RiverSource, as well as the Columbia Funds underlying certain variable contracts issued by RiverSource • Various wrap program sponsors, including Ameriprise Financial Services In its capacity as a broker-dealer, Ameriprise Financial Services distributes or receives compensation from selling various products including but not limited to equities and fixed income products. Offerings include corporate bonds and municipal securities, mutual fund shares, ETFs, 529 plans, face-amount certificates, closed-end funds, preferred securities, UITs, non-traded REITs, non-traded BDCs, non-traded closed end funds, hedge fund offerings, structured products, real estate private placement offerings, exchange funds, private equity offerings, 1031 exchanges, fixed, structured and variable annuities, and fixed and variable insurance. Ameriprise Financial Services also sells managed futures funds that engage in trading commodity interests, including futures. • Other affiliated and unaffiliated clients. In addition, Ameriprise Financial Services is the distributor of the publicly offered face-amount certificates issued by Ameriprise Certificate Company. Ameriprise Financial Services also may serve as an underwriter or member of a selling group for securities offerings, including those issued by affiliates. Ameriprise Financial, Inc. has other subsidiaries that are registered as investment advisers with the SEC, including, among others, Threadneedle International Limited, Pyrford International Ltd. and Lionstone Partners, LLC. These subsidiaries are registered as investment advisers and may provide advice to domestic and foreign institutional clients, the Columbia Funds, the Columbia ETFs, the Columbia closed-end funds, private funds and other fiduciary clients. These entities provide services independent from Ameriprise Financial Services. Columbia Management 15 16 Ameriprise Financial Institutions Group (“AFIG”) and its affiliates Threadneedle Asset Management Ltd, (U.K. based), Threadneedle Investments Singapore (Pte.) Limited (Singapore based), and Columbia Threadneedle Investments (ME) Limited (Dubai based) operate under a combined global asset management brand, Columbia Threadneedle Investments. Ameriprise Financial Inc. also has non-US subsidiaries that provide asset management services. These include Columbia Threadneedle Management Limited (“CTML”), Columbia Threadneedle Netherlands B.V. (“CTLN”), Columbia Threadneedle Business Limited (“CTBL”), Columbia Threadneedle AM (Asia) Limited (“CTAMLA”), Columbia Threadneedle (EM) Investments Limited (“CT (EM)”) and Pyrford International Ltd (“Pyrford”). Each of CTML, CTLN, CTBL, CTAMLA, CT (EM) and Pyrford is registered with the appropriate respective regulators in their home jurisdictions. In addition, Pyrford is also registered with the SEC as investment advisers. Columbia Management Investment Advisers is also registered with the CFTC as a commodity pool operator and a CTA and has obtained membership with the NFA in connection with such CFTC registration. Threadneedle International Limited is registered with the CFTC as CTA and has obtained membership with the NFA in connection with such CFTC registration. AFIG is a business channel within Ameriprise Financial Services that specializes in delivering investment products and services to clients of financial institutions, such as banks and credit unions. Ameriprise Financial Services enters into a networking arrangement with each financial institution whereby AFIG financial advisors provide one or more of our investment advisory services, brokerage services and insurance products to clients of the financial institution and other persons or entities that may be introduced or referred to us by the financial institution. The financial institution provides AFIG financial advisors joint marketing access to a distinct client segment and may provide office space in the building where it conducts its business. As a part of the contractual arrangement with the financial institution, Ameriprise Financial Services shares with the financial institution a portion of up to 94% of fees and commissions, including Wrap Fees charged for investment advisory services, generated by AFIG financial advisors that are attributable to our operations under the joint marketing agreement with the financial institution. A portion of these fees may be paid to financial advisors who are employees of the financial institution, as described below. Banking institution Ameriprise Bank, FSB, a wholly owned subsidiary of Ameriprise Financial, Inc. and an affiliate of Ameriprise Financial Services, is a federal savings bank. In addition to its participation in the AIMMA and ABISA Sweep Programs, Ameriprise Bank currently makes available a core set of banking products, including mortgage financing, co-branded credit cards with an associated rewards program, savings, certificates of deposit (“CDs”), checking accounts, and pledged asset loans. Ameriprise Bank provides personal trust services to clients, including trustee and investment management services for asset trusts, and investment management and custodial agency services for individual, individual trustee, association and non-profit organization accounts. All AFIG financial advisors are licensed and registered through Ameriprise Financial Services. Ameriprise Financial Services has exclusive control over the activities conducted on our behalf under the agreement with the financial institution and is responsible for the supervision of certain activities of AFIG financial advisors. AFIG financial advisors are affiliated with Ameriprise Financial Services in one of three ways: independent contractors and their personnel, Ameriprise employee financial advisors and financial institution employee financial advisors. Financial advisors employed by the financial institution are compensated by the financial institution from the portion of fees and commissions it receives from Ameriprise Financial Services. In such cases the financial institution serves as paying agent on our behalf in accordance with applicable law. The level of compensation received by financial advisors employed by the financial institution is based on their employment agreement with the financial institution. Ameriprise Financial Services establishes custodial accounts and accepts securities order instructions for trust accounts at Ameriprise Bank. In addition, Ameriprise Financial Services may provide investment advice and research support to Ameriprise Bank and its clients for these trust accounts. Ameriprise Financial Services does not pay any compensation to any non-registered employee or agent of the financial institution for referrals. Any referral fee paid by the financial institution to an employee or agent is a one- time, per-customer fee of a nominal, fixed dollar amount and is unrelated to the products and services you purchase. Trust company AFIG financial advisors who provide services at a financial institution that does not have a Trust Department can offer trust services through other providers, including our affiliate, Ameriprise Bank. Ameriprise Financial Services and the AFIG financial advisor may serve as a finder related to trust services and may receive a referral fee for business referred to unaffiliated trust providers. Ameriprise Trust Company (“ATC”), a Minnesota-chartered trust company, provides custodial, investment management and collective trust fund services for employer-sponsored retirement plans, including pension, profit sharing, 401(k) and other qualified and nonqualified employee retirement plans. ATC also serves as custodian for IRAs, 403(b)s and some retirement plans qualified under section 401(a) of the Internal Revenue Code of 1986 as well as the Ameriprise Certificate Company. ATC is not a deposit bank or a member of FDIC. Insurance company Ameriprise Financial Services is not a bank or credit union. Any services or products you purchase through an AFIG financial advisor are not guaranteed or insured by Ameriprise Financial Services or the financial institution. The financial institution is not a party to your Client Agreement with us. Ameriprise Financial Services and each financial institution have entered into a networking agreement under which we have agreed to share fees and commissions with the financial institution, including Wrap Fees charged for investment advisory services. Non- registered employees of the financial institution may also receive compensation for referring you to Ameriprise Financial Services. Affiliated insurance products sold by Ameriprise Financial Services and its financial advisors are issued by RiverSource Life Insurance Company (“RiverSource Life”), a stock life insurance company that is qualified to do business as an insurance company in the District of Columbia, American Samoa and all states except New York; and in New York only, issued by RiverSource Life Insurance Co. of New York (“RiverSource Life of NY”), a stock life insurance company that is qualified to do business as an insurance company in New York. How we get paid This section should be read in connection with the “Advisory Business,” “Fees and Compensation” and/or the “Client Referrals and Other Compensation” sections in this Brochure. The products of RiverSource Life and RiverSource Life of NY (together, “RiverSource”) include structured annuities (RiverSource Life only), fixed and variable annuities, fixed and variable life insurance, disability income insurance and life insurance with long-term care benefits. Insurance products are also offered by other third parties through an arrangement with Ameriprise Financial Services and through Diversified Brokerage Services, Inc. and LTCI Partners, and Disability Resource Group, which act as co-general agents. Ameriprise Financial Services and its affiliates receive revenue from several different sources on the products and services you purchase. These sources include the fees and charges you pay, other arrangements we have in place with product companies, and investment and interest income. The revenue generated or received supports, in part, the development of new products, maintenance of our infrastructure, and retention of employees and financial advisors. Further on in this section you will find information on how our financial advisors are paid. RiverSource Distributors, Inc. (“RiverSource Distributors”), a wholly owned subsidiary of Ameriprise Financial, Inc., is a registered broker-dealer, serving as principal underwriter and distributor of RiverSource variable life insurance and annuities on behalf of RiverSource. Ameriprise Financial Services has selling arrangements with RiverSource and RiverSource Distributors to distribute these products. 17 18 Ameriprise Financial Institutions Group (“AFIG”) and its affiliates Threadneedle Asset Management Ltd, (U.K. based), Threadneedle Investments Singapore (Pte.) Limited (Singapore based), and Columbia Threadneedle Investments (ME) Limited (Dubai based) operate under a combined global asset management brand, Columbia Threadneedle Investments. Ameriprise Financial Inc. also has non-US subsidiaries that provide asset management services. These include Columbia Threadneedle Management Limited (“CTML”), Columbia Threadneedle Netherlands B.V. (“CTLN”), Columbia Threadneedle Business Limited (“CTBL”), Columbia Threadneedle AM (Asia) Limited (“CTAMLA”), Columbia Threadneedle (EM) Investments Limited (“CT (EM)”) and Pyrford International Ltd (“Pyrford”). Each of CTML, CTLN, CTBL, CTAMLA, CT (EM) and Pyrford is registered with the appropriate respective regulators in their home jurisdictions. In addition, Pyrford is also registered with the SEC as investment advisers. Columbia Management Investment Advisers is also registered with the CFTC as a commodity pool operator and a CTA and has obtained membership with the NFA in connection with such CFTC registration. Threadneedle International Limited is registered with the CFTC as CTA and has obtained membership with the NFA in connection with such CFTC registration. AFIG is a business channel within Ameriprise Financial Services that specializes in delivering investment products and services to clients of financial institutions, such as banks and credit unions. Ameriprise Financial Services enters into a networking arrangement with each financial institution whereby AFIG financial advisors provide one or more of our investment advisory services, brokerage services and insurance products to clients of the financial institution and other persons or entities that may be introduced or referred to us by the financial institution. The financial institution provides AFIG financial advisors joint marketing access to a distinct client segment and may provide office space in the building where it conducts its business. As a part of the contractual arrangement with the financial institution, Ameriprise Financial Services shares with the financial institution a portion of up to 94% of fees and commissions, including Wrap Fees charged for investment advisory services, generated by AFIG financial advisors that are attributable to our operations under the joint marketing agreement with the financial institution. A portion of these fees may be paid to financial advisors who are employees of the financial institution, as described below. Banking institution Ameriprise Bank, FSB, a wholly owned subsidiary of Ameriprise Financial, Inc. and an affiliate of Ameriprise Financial Services, is a federal savings bank. In addition to its participation in the AIMMA and ABISA Sweep Programs, Ameriprise Bank currently makes available a core set of banking products, including mortgage financing, co-branded credit cards with an associated rewards program, savings, certificates of deposit (“CDs”), checking accounts, and pledged asset loans. Ameriprise Bank provides personal trust services to clients, including trustee and investment management services for asset trusts, and investment management and custodial agency services for individual, individual trustee, association and non-profit organization accounts. All AFIG financial advisors are licensed and registered through Ameriprise Financial Services. Ameriprise Financial Services has exclusive control over the activities conducted on our behalf under the agreement with the financial institution and is responsible for the supervision of certain activities of AFIG financial advisors. AFIG financial advisors are affiliated with Ameriprise Financial Services in one of three ways: independent contractors and their personnel, Ameriprise employee financial advisors and financial institution employee financial advisors. Financial advisors employed by the financial institution are compensated by the financial institution from the portion of fees and commissions it receives from Ameriprise Financial Services. In such cases the financial institution serves as paying agent on our behalf in accordance with applicable law. The level of compensation received by financial advisors employed by the financial institution is based on their employment agreement with the financial institution. Ameriprise Financial Services establishes custodial accounts and accepts securities order instructions for trust accounts at Ameriprise Bank. In addition, Ameriprise Financial Services may provide investment advice and research support to Ameriprise Bank and its clients for these trust accounts. Ameriprise Financial Services does not pay any compensation to any non-registered employee or agent of the financial institution for referrals. Any referral fee paid by the financial institution to an employee or agent is a one- time, per-customer fee of a nominal, fixed dollar amount and is unrelated to the products and services you purchase. Trust company AFIG financial advisors who provide services at a financial institution that does not have a Trust Department can offer trust services through other providers, including our affiliate, Ameriprise Bank. Ameriprise Financial Services and the AFIG financial advisor may serve as a finder related to trust services and may receive a referral fee for business referred to unaffiliated trust providers. Ameriprise Trust Company (“ATC”), a Minnesota-chartered trust company, provides custodial, investment management and collective trust fund services for employer-sponsored retirement plans, including pension, profit sharing, 401(k) and other qualified and nonqualified employee retirement plans. ATC also serves as custodian for IRAs, 403(b)s and some retirement plans qualified under section 401(a) of the Internal Revenue Code of 1986 as well as the Ameriprise Certificate Company. ATC is not a deposit bank or a member of FDIC. Insurance company Ameriprise Financial Services is not a bank or credit union. Any services or products you purchase through an AFIG financial advisor are not guaranteed or insured by Ameriprise Financial Services or the financial institution. The financial institution is not a party to your Client Agreement with us. Ameriprise Financial Services and each financial institution have entered into a networking agreement under which we have agreed to share fees and commissions with the financial institution, including Wrap Fees charged for investment advisory services. Non- registered employees of the financial institution may also receive compensation for referring you to Ameriprise Financial Services. Affiliated insurance products sold by Ameriprise Financial Services and its financial advisors are issued by RiverSource Life Insurance Company (“RiverSource Life”), a stock life insurance company that is qualified to do business as an insurance company in the District of Columbia, American Samoa and all states except New York; and in New York only, issued by RiverSource Life Insurance Co. of New York (“RiverSource Life of NY”), a stock life insurance company that is qualified to do business as an insurance company in New York. How we get paid This section should be read in connection with the “Advisory Business,” “Fees and Compensation” and/or the “Client Referrals and Other Compensation” sections in this Brochure. The products of RiverSource Life and RiverSource Life of NY (together, “RiverSource”) include structured annuities (RiverSource Life only), fixed and variable annuities, fixed and variable life insurance, disability income insurance and life insurance with long-term care benefits. Insurance products are also offered by other third parties through an arrangement with Ameriprise Financial Services and through Diversified Brokerage Services, Inc. and LTCI Partners, and Disability Resource Group, which act as co-general agents. Ameriprise Financial Services and its affiliates receive revenue from several different sources on the products and services you purchase. These sources include the fees and charges you pay, other arrangements we have in place with product companies, and investment and interest income. The revenue generated or received supports, in part, the development of new products, maintenance of our infrastructure, and retention of employees and financial advisors. Further on in this section you will find information on how our financial advisors are paid. RiverSource Distributors, Inc. (“RiverSource Distributors”), a wholly owned subsidiary of Ameriprise Financial, Inc., is a registered broker-dealer, serving as principal underwriter and distributor of RiverSource variable life insurance and annuities on behalf of RiverSource. Ameriprise Financial Services has selling arrangements with RiverSource and RiverSource Distributors to distribute these products. 17 18 Cost reimbursement services and third-party payments families offered by Ameriprise Financial Services. The goal at Ameriprise Financial Services is to offer a wide range of mutual funds using the following criteria: Product breadth and strong-performing funds • Financial strength of the firm • • Marketing and sales support payments paid to our affiliate AEIS to support cost reimbursement services Ability to provide product support and training to our financial advisors Tax benefits offered by individual states • Payments from product companies. AEIS will receive the following types of payments with respect to the investment products we recommend and you select for the investment of your applicable Managed Account assets. This compensation is used in part to fund the cost of providing the services, maintaining Managed Accounts and offering an investment platform for our clients as well as providing revenue and net earnings to AEIS. For qualified SPS Advisor Accounts, inherited IRAs in qualified SPS Advantage Accounts where a trust has inherited the IRA and Ameriprise Bank acts as trustee of the trust and eligible trustee-directed retirement plans in Select Separate Accounts AEIS either does not collect Third Party Payments or credits them back to client Accounts. Overall quality of the 529 plan (specific to 529 plans) • AEIS performs certain services for the benefit of Ameriprise Financial Services, its financial advisors and clients, including but not limited to recordkeeping, administration and shareholder servicing support, applicable platform level eligibility and investment product due diligence, investment research, training and education, client telephonic and other servicing, and other support related functions such as trading systems, asset allocation and performance reporting tools, websites and mobile applications (collectively “cost reimbursement services”). Any cost reimbursement payments received by AEIS that are paid by product sponsors out of assets of the investment, such as a mutual fund or unit investment trust, reduce the investor return on their investment. Ameriprise financial advisors may offer, and clients are free to choose, mutual funds from approximately 140 fund families available. However, certain aspects of the Mutual Fund Program create a conflict of interest or incentive if Ameriprise Financial Services promotes, or Ameriprise financial advisors recommend, the mutual funds offered by a firm participating in the Mutual Fund Program versus mutual funds offered by nonparticipating firms. As further described below, these conflicts and incentives arise from the cost reimbursement related to education, training, seminar reimbursement and noncash compensation, provided to our financial advisors by, as well as the payments AEIS receives from, firms participating in the Mutual Fund Program and with other relationships with firms, including Columbia Management; see the section titled “Columbia Funds” below. AEIS also receives revenues that exceed the costs of the cost reimbursement services provided. These revenues include cost reimbursement and marketing support payments (as described below under the heading "Education, Training, Seminar Reimbursement and noncash compensation") and such payments increase the gross revenues and net earnings of AEIS. Ameriprise Financial Services has a financial incentive for its affiliate to continue to maintain these cost reimbursement arrangements, including arrangements with Full Participation Firms and for AEIS to continue to receive revenue. Because not all investments provide for cost reimbursement payments, AFSI has an incentive to recommend or select investment products that make such payments within Managed Account Programs. Ameriprise Financial Services addresses this conflict of interest by applying objective due diligence standards and requiring all mutual funds, ETFs, ETNs, CEFs, UITs and alternative investments offered in the Programs to meet these standards. To be included in the Mutual Fund Program, firms have agreed to pay AEIS a portion of the revenue generated from the sale and/or management of mutual fund shares. Full Participation Firms make cost reimbursement payments at a higher level than do firms that have arrangements discussed in the “Other financial relationships” section. For each year a client holds shares of a particular mutual fund, the mutual fund’s advisor or distributor may pay to AEIS an amount based on the value of the collective mutual fund shares held in clients’ accounts (asset-based payment). AEIS receives an asset-based payment (up to 0.20% per year for mutual funds and 0.185% per year for 529 plans) on some or all of Ameriprise Financial Services clients’ assets managed by the participating firms. In instances where a new Full Participation Firm relationship is established, in certain instances, to offset AEIS expenses for providing cost reimbursement services, the cost reimbursement payments will initially be structured in the form of an annual flat fee in addition to 0.20% of assets invested, with the total dollar amount of such payment not to exceed $1,250,000. AEIS receives a variety of payments for cost reimbursement services from affiliated products sponsored or managed by affiliated investment advisers (e.g., Columbia Management) and by non-affiliated investment product companies which reimburse the costs of beneficial client services provided by Ameriprise Financial Services and AEIS. The most significant of these payments are reimbursement for marketing support received from the product companies. AEIS receives cost reimbursement payments from product companies for the following products: mutual funds, 529 plans, actively managed ETFs, UITs, non-traded REITs, real estate private placements, tax- deferred real estate exchanges, non-traded BDCs, fixed annuities, variable annuities, structured annuities, fixed insurance, variable insurance, structured products, managed futures funds, private equity offerings, non-traded closed end funds and hedge fund offerings. Ameriprise Financial Services receives cost reimbursement payments on our affiliated and unaffiliated annuity and insurance products which are not eligible investments for Managed Accounts. These payments are discussed in the remaining paragraphs of this section. Certain Full Participation Firms pay our affiliate AEIS more marketing support for certain types of mutual funds. In general, Full Participation Firms offer actively managed mutual funds that permit cost reimbursement payments to be included in the Investment Costs charged by the mutual fund. The Investment Costs of actively managed mutual funds are generally higher than those of (i) passively managed ETFs which do not make cost reimbursement payments; and (ii) actively managed ETFs which do make such payments. Ameriprise Financial Services has a financial incentive to offer actively managed mutual funds and ETFs that make cost reimbursement payments to our affiliate. As a result, Ameriprise financial advisors may have an indirect incentive to sell such mutual funds and ETFs. We address this incentive by offering a full range of investment product options, including actively managed mutual funds and both actively and passively managed ETFs. In addition, we do not offer actively managed ETFs that are clones of an actively managed mutual fund from the same firm. A similar actively managed ETF may have a lower or comparable management fee as an actively managed mutual fund. Ameriprise further addresses this conflict of interest by calculating the compensation paid to our financial advisors for all assets without regard to the amount of cost reimbursement payments we or our affiliates receive in connection with client investments in mutual funds and other investment products. Additionally, Ameriprise Financial Services does not share with our financial advisors the cost reimbursement payments we or our affiliates receive. If your Account’s Sweep Program uses a money market mutual fund, AEIS receives cost reimbursement payments of up to 0.37% of the amount held in that money market fund Sweep Program. The amount that AEIS receives may be reduced based on fee waivers that are imposed by the money market fund firm. If AEIS and its affiliates did not receive this compensation, Ameriprise Financial Services would likely charge higher fees or other charges to clients for the services provided. When evaluating the reasonableness of the fees and expenses incurred in a Managed Account, you should consider not just the Wrap Fee, but also the fund-level fees and other compensation that Ameriprise Financial Services and its affiliates receive including payments for cost reimbursement services described in this section and other cost reimbursement and marketing support payments received by us and our other affiliates, as described in the “How we get paid” and the “Revenue sources for other Ameriprise Financial, Inc. companies” sections of this Brochure as applicable. These arrangements vary between firms and may be subject to change or renegotiation at any time. If a firm ceases to make cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the mutual fund firm. Mutual fund and 529 plan marketing and sales support payments. Mutual fund and 529 plan marketing and sales support payments are received from certain mutual fund firms. These payments form a structure referred to here as the Ameriprise Financial Mutual Fund Program (“Mutual Fund Program”) with approximately 140 mutual fund 19 20 Cost reimbursement services and third-party payments families offered by Ameriprise Financial Services. The goal at Ameriprise Financial Services is to offer a wide range of mutual funds using the following criteria: Product breadth and strong-performing funds • Financial strength of the firm • • Marketing and sales support payments paid to our affiliate AEIS to support cost reimbursement services Ability to provide product support and training to our financial advisors Tax benefits offered by individual states • Payments from product companies. AEIS will receive the following types of payments with respect to the investment products we recommend and you select for the investment of your applicable Managed Account assets. This compensation is used in part to fund the cost of providing the services, maintaining Managed Accounts and offering an investment platform for our clients as well as providing revenue and net earnings to AEIS. For qualified SPS Advisor Accounts, inherited IRAs in qualified SPS Advantage Accounts where a trust has inherited the IRA and Ameriprise Bank acts as trustee of the trust and eligible trustee-directed retirement plans in Select Separate Accounts AEIS either does not collect Third Party Payments or credits them back to client Accounts. Overall quality of the 529 plan (specific to 529 plans) • AEIS performs certain services for the benefit of Ameriprise Financial Services, its financial advisors and clients, including but not limited to recordkeeping, administration and shareholder servicing support, applicable platform level eligibility and investment product due diligence, investment research, training and education, client telephonic and other servicing, and other support related functions such as trading systems, asset allocation and performance reporting tools, websites and mobile applications (collectively “cost reimbursement services”). Any cost reimbursement payments received by AEIS that are paid by product sponsors out of assets of the investment, such as a mutual fund or unit investment trust, reduce the investor return on their investment. Ameriprise financial advisors may offer, and clients are free to choose, mutual funds from approximately 140 fund families available. However, certain aspects of the Mutual Fund Program create a conflict of interest or incentive if Ameriprise Financial Services promotes, or Ameriprise financial advisors recommend, the mutual funds offered by a firm participating in the Mutual Fund Program versus mutual funds offered by nonparticipating firms. As further described below, these conflicts and incentives arise from the cost reimbursement related to education, training, seminar reimbursement and noncash compensation, provided to our financial advisors by, as well as the payments AEIS receives from, firms participating in the Mutual Fund Program and with other relationships with firms, including Columbia Management; see the section titled “Columbia Funds” below. AEIS also receives revenues that exceed the costs of the cost reimbursement services provided. These revenues include cost reimbursement and marketing support payments (as described below under the heading "Education, Training, Seminar Reimbursement and noncash compensation") and such payments increase the gross revenues and net earnings of AEIS. Ameriprise Financial Services has a financial incentive for its affiliate to continue to maintain these cost reimbursement arrangements, including arrangements with Full Participation Firms and for AEIS to continue to receive revenue. Because not all investments provide for cost reimbursement payments, AFSI has an incentive to recommend or select investment products that make such payments within Managed Account Programs. Ameriprise Financial Services addresses this conflict of interest by applying objective due diligence standards and requiring all mutual funds, ETFs, ETNs, CEFs, UITs and alternative investments offered in the Programs to meet these standards. To be included in the Mutual Fund Program, firms have agreed to pay AEIS a portion of the revenue generated from the sale and/or management of mutual fund shares. Full Participation Firms make cost reimbursement payments at a higher level than do firms that have arrangements discussed in the “Other financial relationships” section. For each year a client holds shares of a particular mutual fund, the mutual fund’s advisor or distributor may pay to AEIS an amount based on the value of the collective mutual fund shares held in clients’ accounts (asset-based payment). AEIS receives an asset-based payment (up to 0.20% per year for mutual funds and 0.185% per year for 529 plans) on some or all of Ameriprise Financial Services clients’ assets managed by the participating firms. In instances where a new Full Participation Firm relationship is established, in certain instances, to offset AEIS expenses for providing cost reimbursement services, the cost reimbursement payments will initially be structured in the form of an annual flat fee in addition to 0.20% of assets invested, with the total dollar amount of such payment not to exceed $1,250,000. AEIS receives a variety of payments for cost reimbursement services from affiliated products sponsored or managed by affiliated investment advisers (e.g., Columbia Management) and by non-affiliated investment product companies which reimburse the costs of beneficial client services provided by Ameriprise Financial Services and AEIS. The most significant of these payments are reimbursement for marketing support received from the product companies. AEIS receives cost reimbursement payments from product companies for the following products: mutual funds, 529 plans, actively managed ETFs, UITs, non-traded REITs, real estate private placements, tax- deferred real estate exchanges, non-traded BDCs, fixed annuities, variable annuities, structured annuities, fixed insurance, variable insurance, structured products, managed futures funds, private equity offerings, non-traded closed end funds and hedge fund offerings. Ameriprise Financial Services receives cost reimbursement payments on our affiliated and unaffiliated annuity and insurance products which are not eligible investments for Managed Accounts. These payments are discussed in the remaining paragraphs of this section. Certain Full Participation Firms pay our affiliate AEIS more marketing support for certain types of mutual funds. In general, Full Participation Firms offer actively managed mutual funds that permit cost reimbursement payments to be included in the Investment Costs charged by the mutual fund. The Investment Costs of actively managed mutual funds are generally higher than those of (i) passively managed ETFs which do not make cost reimbursement payments; and (ii) actively managed ETFs which do make such payments. Ameriprise Financial Services has a financial incentive to offer actively managed mutual funds and ETFs that make cost reimbursement payments to our affiliate. As a result, Ameriprise financial advisors may have an indirect incentive to sell such mutual funds and ETFs. We address this incentive by offering a full range of investment product options, including actively managed mutual funds and both actively and passively managed ETFs. In addition, we do not offer actively managed ETFs that are clones of an actively managed mutual fund from the same firm. A similar actively managed ETF may have a lower or comparable management fee as an actively managed mutual fund. Ameriprise further addresses this conflict of interest by calculating the compensation paid to our financial advisors for all assets without regard to the amount of cost reimbursement payments we or our affiliates receive in connection with client investments in mutual funds and other investment products. Additionally, Ameriprise Financial Services does not share with our financial advisors the cost reimbursement payments we or our affiliates receive. If your Account’s Sweep Program uses a money market mutual fund, AEIS receives cost reimbursement payments of up to 0.37% of the amount held in that money market fund Sweep Program. The amount that AEIS receives may be reduced based on fee waivers that are imposed by the money market fund firm. If AEIS and its affiliates did not receive this compensation, Ameriprise Financial Services would likely charge higher fees or other charges to clients for the services provided. When evaluating the reasonableness of the fees and expenses incurred in a Managed Account, you should consider not just the Wrap Fee, but also the fund-level fees and other compensation that Ameriprise Financial Services and its affiliates receive including payments for cost reimbursement services described in this section and other cost reimbursement and marketing support payments received by us and our other affiliates, as described in the “How we get paid” and the “Revenue sources for other Ameriprise Financial, Inc. companies” sections of this Brochure as applicable. These arrangements vary between firms and may be subject to change or renegotiation at any time. If a firm ceases to make cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the mutual fund firm. Mutual fund and 529 plan marketing and sales support payments. Mutual fund and 529 plan marketing and sales support payments are received from certain mutual fund firms. These payments form a structure referred to here as the Ameriprise Financial Mutual Fund Program (“Mutual Fund Program”) with approximately 140 mutual fund 19 20 Ameriprise Financial Services sells 529 plans from seven firms that do not make cost reimbursement payments to AEIS. Moreover, 529 plans offered by these firms are available for sale to in-state residents only. Those firms are: American Funds, Ascensus, Invesco, MFS, Orion, Union Bank & Trust and Virtus. In addition, Connecticut and Iowa restrict the sale of their state plans, offered by Hartford and Voya, respectively, to in-state residents only. Certain 529 plans may pay AEIS a fee of up to 1% of assets for NAV rollovers. Full Participation. Thirty firms fully participate in the Mutual Fund Program. These fund firms include Columbia Threadneedle Investments, Allspring Funds, American Century Investments, Amundi, BlackRock Funds, BNY Mellon, Delaware Investments, DWS Investments, Eaton Vance, Eventide Funds, Federated Hermes, Fidelity, First Eagle Funds, Goldman Sachs Asset Management, Invesco, Janus Henderson Investors, John Hancock Investments, JP Morgan Asset Management, Lord Abbett, MainStay Funds, MFS, Natixis Funds, Neuberger Berman, Nuveen, Principal, PGIM Investments, Virtus and Voya Funds. These firms are referred to as “Full Participation Firms.” We offer 529 plans from nineteen firms. Of those firms, fifteen are Full Participation Firms. These fund firms include American Century, BlackRock, Columbia Threadneedle Investments, Fidelity, Franklin Templeton, Goldman Sachs, Hartford, Invesco, John Hancock, J.P. Morgan, MFS, Nuveen, Principal, Virtus and Voya. Each of these firms is referred to as a “Full Participation Firm.” The most current Mutual Fund Program information, as well as the previous calendar year’s totals of cost reimbursement payments received from Full Participation firms, in addition to distribution support amounts, may be viewed online by visiting www.ameriprise.com/funds and clicking on “An Investor’s Guide to Purchasing Mutual Funds and 529 Plans at Ameriprise Financial.” The mutual fund’s distributor or affiliate may also make payments to AEIS for networking and/or omnibus support and other client services and account maintenance activities. AEIS will also receive sub-transfer agency fees with respect to investments you make in affiliated and non-affiliated mutual funds. These fees vary depending on the mutual fund family and on whether the mutual fund keeps a separate record for each account (i.e., networked accounts) or relies on AEIS’s recordkeeping (i.e., omnibus accounts). Compensation for sub-transfer agency services may be up to $12 per position annually for networked accounts, and up to $19 per position annually for omnibus accounts or, if paid on an asset basis, from 0.10% to 0.15% annually of any amounts you have invested in such mutual funds. In the case of certain no-load fund families for which AEIS has a direct relationship, the compensation for sub-accounting, administrative and distribution support services are bundled into one asset- based fee of up to 0.35% (which may include a service fee up to 0.25%) annually of the value of such shares held in an Account. AEIS and its affiliates may have other relationships with firms whose mutual funds Ameriprise Financial Services offers. These relationships may include affiliates of firms acting as a sub-adviser to CMIA, CMIA acting as a sub- adviser to a third-party firm, or affiliates of a firm managing an investment portfolio within another Ameriprise Financial Services or affiliated product, such as a RiverSource variable annuity. Firms may use CMIA to manage an underlying investment option in products offered through the Mutual Fund Program. Education, training, seminar reimbursement and noncash compensation. Full Participation Firms provide to Ameriprise financial advisors and, in some cases, to their clients, education, training, and support services relating to the investment products they offer. These firms may reimburse Ameriprise Financial Services, and Ameriprise Financial Services may subsequently reimburse Ameriprise financial advisors, for client/prospect education events and financial advisor sales meetings, seminars and training events, consistent with Ameriprise Financial Services policies. Ameriprise Financial Services and its financial advisors may also receive nominal noncash benefits from time to time. As a result, Ameriprise financial advisors may have greater familiarity with and an incentive to sell investment products of Full Participation Firms. AEIS has a cost reimbursement agreement with BlackRock Advisors, LLC with respect to mutual fund positions held by Ameriprise Financial Services customers. BlackRock, Inc. owns more than 5% of the outstanding shares of Ameriprise Financial, Inc. stock. Firms sponsoring alternative investments may also provide Ameriprise financial advisors and, in some cases their clients, education, training, and support services relating to the investment products they offer. Our affiliate CMIA has a sub-transfer agent agreement with Vanguard Group, Inc. with respect to the distribution of its investment products. Vanguard Group, Inc. owns more than 5% of the outstanding shares of Ameriprise Financial, Inc. stock. Payments for Product Implementation and Trading Technology Expenses. For most investment products, AEIS will receive payments of up to $25,000 per investment product per expense from third-party firms to reimburse expenses associated with each of (i) conducting due diligence on the investment product; and (ii) the implementation of certain technology platforms or capabilities related to the distribution of the investment product. Columbia Funds. AEIS and other affiliates of Ameriprise Financial Services provide certain administrative and transfer agent services to the Columbia Funds whose shares are owned by Ameriprise Financial Services clients. Ameriprise Financial Services and its affiliates generally receive more revenue from sales of affiliated mutual funds than from sales of other mutual funds. Employee compensation and operating goals at all levels of the company are tied to the company’s success. Certain employees may receive higher compensation and other benefits based, in part, on assets invested in affiliated mutual funds. For most model investment portfolios in Signature Wealth and certain SMA strategies in Select Separate Account, AFS will receive payments of (i) up to $25,000 per investment product per expense; or (ii) reimbursement of actual costs incurred to reimburse expenses associated with the implementation of certain technology platforms or capabilities related to the distribution of the investment product. American Funds. For both affiliated and unaffiliated mutual funds we offer, AEIS receives cost reimbursement payments from mutual fund firms of up to 0.20% of assets invested in those funds. Payments from Investment Providers offering SMA investment portfolios within the Signature Wealth Program. AEIS receives cost reimbursement payments for the sale of SMA investment portfolios offered within the Signature Wealth Program. AEIS receives an asset-based payment of up to 0.04% per year on Ameriprise Financial Services clients’ assets invested in the SMA investment portfolios. If an Investment Provider ceases to make such cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the firm. Other financial relationships With most mutual fund firms, these payments are paid on an ongoing basis and determined solely based on total assets invested in the funds of a particular fund family held in clients’ accounts. Rather than determining the amount of the payment solely on an asset-based basis, American Funds pays AEIS an annual negotiated platform fee based on a number of factors, including prior year assets, in accordance with their prospectus governing each mutual fund. This platform fee will not exceed 0.20% of assets and will also not exceed the limits set forth in the prospectus governing each fund. You can find the total dollar amounts we receive annually from American Funds, as of the previous calendar year, by visiting www.ameriprise.com/funds and clicking on “An Investor’s Guide to Purchasing Mutual Funds and 529 Plans at Ameriprise Financial.” American funds are generally no longer available for new purchases in Ameriprise brokerage accounts (other than add-on purchases into existing positions, which may continue), and thus new investments of American Funds can generally only be executed in our Managed Account Programs. Ameriprise Preferred Line of Credit and Loan. AEIS receives compensation from Ameriprise Bank, FSB for its Ameriprise Preferred Line of Credit and Loan support services. Distribution support relationships. AEIS also has cost reimbursement arrangements with firms for distribution support services. These “Available for Sale Firms” make payments to AEIS for distribution support but do not provide marketing and sales support, such as those provided by Full Participation Firms, and make payments at a lower percentage rate than Full Participation Firms. These firms make cost reimbursement payments to AEIS of up to 0.10% on assets for these services, which support the distribution of the fund’s shares and 529 plans by making them available on one or more Ameriprise Financial Services platforms. In addition, certain mutual funds’ distributors pay a fee to AEIS of up to 0.10% for cost reimbursement services provided for the mutual fund shares purchased during a given period (sales-based payment). These mutual fund firms do not provide marketing and sales support such as those provided by Full Participation Firms to Ameriprise financial advisors, thus they do not have the same access to financial advisors as Full Participation Firms. 21 22 Ameriprise Financial Services sells 529 plans from seven firms that do not make cost reimbursement payments to AEIS. Moreover, 529 plans offered by these firms are available for sale to in-state residents only. Those firms are: American Funds, Ascensus, Invesco, MFS, Orion, Union Bank & Trust and Virtus. In addition, Connecticut and Iowa restrict the sale of their state plans, offered by Hartford and Voya, respectively, to in-state residents only. Certain 529 plans may pay AEIS a fee of up to 1% of assets for NAV rollovers. Full Participation. Thirty firms fully participate in the Mutual Fund Program. These fund firms include Columbia Threadneedle Investments, Allspring Funds, American Century Investments, Amundi, BlackRock Funds, BNY Mellon, Delaware Investments, DWS Investments, Eaton Vance, Eventide Funds, Federated Hermes, Fidelity, First Eagle Funds, Goldman Sachs Asset Management, Invesco, Janus Henderson Investors, John Hancock Investments, JP Morgan Asset Management, Lord Abbett, MainStay Funds, MFS, Natixis Funds, Neuberger Berman, Nuveen, Principal, PGIM Investments, Virtus and Voya Funds. These firms are referred to as “Full Participation Firms.” We offer 529 plans from nineteen firms. Of those firms, fifteen are Full Participation Firms. These fund firms include American Century, BlackRock, Columbia Threadneedle Investments, Fidelity, Franklin Templeton, Goldman Sachs, Hartford, Invesco, John Hancock, J.P. Morgan, MFS, Nuveen, Principal, Virtus and Voya. Each of these firms is referred to as a “Full Participation Firm.” The most current Mutual Fund Program information, as well as the previous calendar year’s totals of cost reimbursement payments received from Full Participation firms, in addition to distribution support amounts, may be viewed online by visiting www.ameriprise.com/funds and clicking on “An Investor’s Guide to Purchasing Mutual Funds and 529 Plans at Ameriprise Financial.” The mutual fund’s distributor or affiliate may also make payments to AEIS for networking and/or omnibus support and other client services and account maintenance activities. AEIS will also receive sub-transfer agency fees with respect to investments you make in affiliated and non-affiliated mutual funds. These fees vary depending on the mutual fund family and on whether the mutual fund keeps a separate record for each account (i.e., networked accounts) or relies on AEIS’s recordkeeping (i.e., omnibus accounts). Compensation for sub-transfer agency services may be up to $12 per position annually for networked accounts, and up to $19 per position annually for omnibus accounts or, if paid on an asset basis, from 0.10% to 0.15% annually of any amounts you have invested in such mutual funds. In the case of certain no-load fund families for which AEIS has a direct relationship, the compensation for sub-accounting, administrative and distribution support services are bundled into one asset- based fee of up to 0.35% (which may include a service fee up to 0.25%) annually of the value of such shares held in an Account. AEIS and its affiliates may have other relationships with firms whose mutual funds Ameriprise Financial Services offers. These relationships may include affiliates of firms acting as a sub-adviser to CMIA, CMIA acting as a sub- adviser to a third-party firm, or affiliates of a firm managing an investment portfolio within another Ameriprise Financial Services or affiliated product, such as a RiverSource variable annuity. Firms may use CMIA to manage an underlying investment option in products offered through the Mutual Fund Program. Education, training, seminar reimbursement and noncash compensation. Full Participation Firms provide to Ameriprise financial advisors and, in some cases, to their clients, education, training, and support services relating to the investment products they offer. These firms may reimburse Ameriprise Financial Services, and Ameriprise Financial Services may subsequently reimburse Ameriprise financial advisors, for client/prospect education events and financial advisor sales meetings, seminars and training events, consistent with Ameriprise Financial Services policies. Ameriprise Financial Services and its financial advisors may also receive nominal noncash benefits from time to time. As a result, Ameriprise financial advisors may have greater familiarity with and an incentive to sell investment products of Full Participation Firms. AEIS has a cost reimbursement agreement with BlackRock Advisors, LLC with respect to mutual fund positions held by Ameriprise Financial Services customers. BlackRock, Inc. owns more than 5% of the outstanding shares of Ameriprise Financial, Inc. stock. Firms sponsoring alternative investments may also provide Ameriprise financial advisors and, in some cases their clients, education, training, and support services relating to the investment products they offer. Our affiliate CMIA has a sub-transfer agent agreement with Vanguard Group, Inc. with respect to the distribution of its investment products. Vanguard Group, Inc. owns more than 5% of the outstanding shares of Ameriprise Financial, Inc. stock. Payments for Product Implementation and Trading Technology Expenses. For most investment products, AEIS will receive payments of up to $25,000 per investment product per expense from third-party firms to reimburse expenses associated with each of (i) conducting due diligence on the investment product; and (ii) the implementation of certain technology platforms or capabilities related to the distribution of the investment product. Columbia Funds. AEIS and other affiliates of Ameriprise Financial Services provide certain administrative and transfer agent services to the Columbia Funds whose shares are owned by Ameriprise Financial Services clients. Ameriprise Financial Services and its affiliates generally receive more revenue from sales of affiliated mutual funds than from sales of other mutual funds. Employee compensation and operating goals at all levels of the company are tied to the company’s success. Certain employees may receive higher compensation and other benefits based, in part, on assets invested in affiliated mutual funds. For most model investment portfolios in Signature Wealth and certain SMA strategies in Select Separate Account, AFS will receive payments of (i) up to $25,000 per investment product per expense; or (ii) reimbursement of actual costs incurred to reimburse expenses associated with the implementation of certain technology platforms or capabilities related to the distribution of the investment product. American Funds. For both affiliated and unaffiliated mutual funds we offer, AEIS receives cost reimbursement payments from mutual fund firms of up to 0.20% of assets invested in those funds. Payments from Investment Providers offering SMA investment portfolios within the Signature Wealth Program. AEIS receives cost reimbursement payments for the sale of SMA investment portfolios offered within the Signature Wealth Program. AEIS receives an asset-based payment of up to 0.04% per year on Ameriprise Financial Services clients’ assets invested in the SMA investment portfolios. If an Investment Provider ceases to make such cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the firm. Other financial relationships With most mutual fund firms, these payments are paid on an ongoing basis and determined solely based on total assets invested in the funds of a particular fund family held in clients’ accounts. Rather than determining the amount of the payment solely on an asset-based basis, American Funds pays AEIS an annual negotiated platform fee based on a number of factors, including prior year assets, in accordance with their prospectus governing each mutual fund. This platform fee will not exceed 0.20% of assets and will also not exceed the limits set forth in the prospectus governing each fund. You can find the total dollar amounts we receive annually from American Funds, as of the previous calendar year, by visiting www.ameriprise.com/funds and clicking on “An Investor’s Guide to Purchasing Mutual Funds and 529 Plans at Ameriprise Financial.” American funds are generally no longer available for new purchases in Ameriprise brokerage accounts (other than add-on purchases into existing positions, which may continue), and thus new investments of American Funds can generally only be executed in our Managed Account Programs. Ameriprise Preferred Line of Credit and Loan. AEIS receives compensation from Ameriprise Bank, FSB for its Ameriprise Preferred Line of Credit and Loan support services. Distribution support relationships. AEIS also has cost reimbursement arrangements with firms for distribution support services. These “Available for Sale Firms” make payments to AEIS for distribution support but do not provide marketing and sales support, such as those provided by Full Participation Firms, and make payments at a lower percentage rate than Full Participation Firms. These firms make cost reimbursement payments to AEIS of up to 0.10% on assets for these services, which support the distribution of the fund’s shares and 529 plans by making them available on one or more Ameriprise Financial Services platforms. In addition, certain mutual funds’ distributors pay a fee to AEIS of up to 0.10% for cost reimbursement services provided for the mutual fund shares purchased during a given period (sales-based payment). These mutual fund firms do not provide marketing and sales support such as those provided by Full Participation Firms to Ameriprise financial advisors, thus they do not have the same access to financial advisors as Full Participation Firms. 21 22 Payments from other non-affiliated product companies RiverSource and potentially other unaffiliated insurance companies may be permitted to reimburse Ameriprise Financial Services or AEIS and these entities may subsequently reimburse Ameriprise financial advisors for client/ prospect educational events and financial advisor sales meetings, seminars and training events consistent with Ameriprise Financial Services and AEIS policies, as applicable. These companies may also provide support to the Ameriprise Financial Services internal sales desk, which in turn provides support to financial advisors. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource insurance and annuity products and the unaffiliated insurance companies who provide added educational support. Payments from actively managed ETF sponsors. For certain actively managed ETFs offered for purchase in Ameriprise Managed Accounts, AEIS receives from the ETF manager or distributor both (i) ongoing asset-based cost reimbursement payments of up to 0.18% of the assets invested in these products; and (ii) an annual flat program fee of up to $400,000 per manager or distributor. AEIS receives these payments to help promote and support the offer, sale and servicing of actively managed ETFs. These payments form a structure referred to as the Ameriprise Financial ETF Program (“ETF Program”) and compensate AEIS for the costs of maintaining the ETF Program. Firms participating in the ETF Program are granted full access to Ameriprise Financial Services and our financial advisors to provide direct financial advisor education or sales support to promote their products. Generally, unaffiliated insurance companies that issue annuities and life and disability income insurance policies generally do not provide direct client or financial advisor education or sales support, other than product training materials, product sales literature and addressing client service issues. However, in some instances direct financial advisor product education may occur. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource products. From unaffiliated long-term care insurance product manufacturers, AEIS receives payments up to 27.5% of the commissionable premium. AEIS receives varying payments from unaffiliated life, disability and other insurance product manufacturers. Passively managed ETFs and actively managed ETFs that are classified as Eligible to Hold Investments or Ineligible Investments do not participate in the ETF Program, do not have access to financial advisors for education or sales support and do not make cost reimbursement payments, as summarized below. As a result, Ameriprise financial advisors may have a greater familiarity with and an indirect incentive to sell ETFs participating in the ETF Program. Ameriprise Financial Services addresses this incentive as described above in the “Mutual Fund and 529 Plan Marketing and Sales Support Payments” sub-section. Participate in ETF Program Access to Ameriprise financial advisors Make cost reimbursement payments Payments from structured products sponsors. AEIS receives cost reimbursement for the sale of structured products. Depending on the structured product, AEIS will receive payments between 0.25% and 0.60% of the amount you invest, multiplied by the product’s term up to a maximum of 1.6%. For example, a structured note with a three- year term and a 0.40% payout could have an upfront payment of 1.2% (three years x 0.40%). Yes Yes Yes Actively managed ETFs offered for purchase Payments for financial advisor support. Separately, for alternative investment products, AEIS will receive marketing and sales support payments in the form of an optional subscription for financial advisor support for a fixed annual fee of up to $250,000, which when combined with the payments described above for these types of investment products may exceed the ranges noted. No No No Actively managed ETFs that are classified as Eligible to Hold Investments or Ineligible Investments Passively managed ETFs No No No Payments from alternative investments sponsors. AEIS, in consideration for its cost reimbursement services, may receive ongoing investor service and support fee payments from products sponsors of hedge funds and managed futures available in Ameriprise Managed Accounts. Depending on the product, AEIS will receive payments up to 0.25% of the assets invested in these products. Mutual Fund & ETF Recommended list (“Starting Point List"). Ameriprise financial advisors may make mutual fund recommendations based on a group of funds that appear on the Starting Point List. Financial advisors are not required to use the Starting Point List as their source for mutual fund and ETF recommendations, and mutual funds contained on the Starting Point List may not be equally available across both Managed Accounts and Ameriprise brokerage accounts. All ETFs and mutual funds offered by Full Participation Firms or Available for Sale Firms, as further discussed below, must meet Ameriprise Financial Services’ due diligence standards to be eligible for inclusion on the Starting Point List. In developing the Starting Point List, the IRG applies a quantitative and qualitative evaluation process that includes an analysis of a fund’s returns, risk and expenses; the tenure and quality of the investment team; the soundness of the process and consistent implementation; and the overarching health of the organization. Certain mutual funds and ETFs that would have otherwise been included on Starting Point were excluded due to their high investment minimums. Client suitability must be considered when trading mutual funds and ETFs, including breakpoint discount eligibility and NAV transfer ability. The funds on the Starting Point List are subject to change periodically, however changes to the Starting Point List should not be the sole reason to prompt trading. The Starting Point List is developed by the IRG based on eligibility criteria established by Ameriprise Financial Services. Approximately 2,100 mutual funds are eligible for inclusion on the Starting Point List. The primary universe of ETFs includes funds available for sale at Ameriprise. The universe of mutual funds includes only mutual funds sponsored or managed by Full Participation Firms in the Mutual Fund Program. If a suitable mutual fund recommendation for a particular asset class cannot be found within the Full Participation Firms’ offerings, the IRG will proceed to look for mutual fund options sponsored or managed by “Available for Sale Firms”. Payments from UIT sponsors. Certain UIT sponsors with which AEIS has agreements may pay AEIS cost reimbursement payments to help promote and support the offer, sale and servicing of UITs. These UIT sponsors are granted full access to Ameriprise Financial Services and our financial advisors to provide direct financial advisor education or sales support to promote their products. UIT sponsors without such agreements do not provide direct financial advisor education or sales support, thus they do not have the same access to financial advisors as full access firms. Such marketing and sales support may create a conflict of interest if Ameriprise Financial Services promotes, or Ameriprise financial advisors recommend, the UITs from UIT sponsors that have been granted full access versus UITs offered by nonparticipating firms. These conflicts may arise from the marketing and sales support provided to our financial advisors by, as well as the payments AEIS receives from, firms that have entered into such agreements. AEIS will receive both a fixed dollar amount of cost reimbursement payments, based in part on projected UIT sales, as well as sales-based volume concessions. The total amount of these payments will not exceed 0.20% of total UIT sales. While the Starting Point List is developed by evaluating the performance characteristics of each fund’s Class A shares, the analysis is ultimately intended to apply at the mutual fund level. Mutual funds included on the Starting Point List may or may not offer an Advisory Share class or other share class that is available in our Managed Accounts Programs. As a result, Managed Account clients may be unable to purchase a fund on the Starting Point List. Similarly, Ameriprise brokerage account clients may be unable to purchase a mutual fund on the Starting Point List if that fund does not offer a share class available in Ameriprise brokerage accounts. In addition, some mutual funds included on the Starting Point List may offer lower-cost share classes than the Advisory Share class or other share class available in Managed Account Programs. You should consider whether you may be eligible to purchase these lower-cost share classes outside the Programs. Payments from insurance companies. Cost reimbursement payments are received by Ameriprise Financial Services and/or its affiliate, AEIS, from affiliated and unaffiliated insurance companies. Ameriprise Financial Services sells annuity and insurance products to its clients manufactured by its affiliate, RiverSource, as well as from select unaffiliated insurance companies. 23 24 Payments from other non-affiliated product companies RiverSource and potentially other unaffiliated insurance companies may be permitted to reimburse Ameriprise Financial Services or AEIS and these entities may subsequently reimburse Ameriprise financial advisors for client/ prospect educational events and financial advisor sales meetings, seminars and training events consistent with Ameriprise Financial Services and AEIS policies, as applicable. These companies may also provide support to the Ameriprise Financial Services internal sales desk, which in turn provides support to financial advisors. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource insurance and annuity products and the unaffiliated insurance companies who provide added educational support. Payments from actively managed ETF sponsors. For certain actively managed ETFs offered for purchase in Ameriprise Managed Accounts, AEIS receives from the ETF manager or distributor both (i) ongoing asset-based cost reimbursement payments of up to 0.18% of the assets invested in these products; and (ii) an annual flat program fee of up to $400,000 per manager or distributor. AEIS receives these payments to help promote and support the offer, sale and servicing of actively managed ETFs. These payments form a structure referred to as the Ameriprise Financial ETF Program (“ETF Program”) and compensate AEIS for the costs of maintaining the ETF Program. Firms participating in the ETF Program are granted full access to Ameriprise Financial Services and our financial advisors to provide direct financial advisor education or sales support to promote their products. Generally, unaffiliated insurance companies that issue annuities and life and disability income insurance policies generally do not provide direct client or financial advisor education or sales support, other than product training materials, product sales literature and addressing client service issues. However, in some instances direct financial advisor product education may occur. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource products. From unaffiliated long-term care insurance product manufacturers, AEIS receives payments up to 27.5% of the commissionable premium. AEIS receives varying payments from unaffiliated life, disability and other insurance product manufacturers. Passively managed ETFs and actively managed ETFs that are classified as Eligible to Hold Investments or Ineligible Investments do not participate in the ETF Program, do not have access to financial advisors for education or sales support and do not make cost reimbursement payments, as summarized below. As a result, Ameriprise financial advisors may have a greater familiarity with and an indirect incentive to sell ETFs participating in the ETF Program. Ameriprise Financial Services addresses this incentive as described above in the “Mutual Fund and 529 Plan Marketing and Sales Support Payments” sub-section. Participate in ETF Program Access to Ameriprise financial advisors Make cost reimbursement payments Payments from structured products sponsors. AEIS receives cost reimbursement for the sale of structured products. Depending on the structured product, AEIS will receive payments between 0.25% and 0.60% of the amount you invest, multiplied by the product’s term up to a maximum of 1.6%. For example, a structured note with a three- year term and a 0.40% payout could have an upfront payment of 1.2% (three years x 0.40%). Yes Yes Yes Actively managed ETFs offered for purchase Payments for financial advisor support. Separately, for alternative investment products, AEIS will receive marketing and sales support payments in the form of an optional subscription for financial advisor support for a fixed annual fee of up to $250,000, which when combined with the payments described above for these types of investment products may exceed the ranges noted. No No No Actively managed ETFs that are classified as Eligible to Hold Investments or Ineligible Investments Passively managed ETFs No No No Payments from alternative investments sponsors. AEIS, in consideration for its cost reimbursement services, may receive ongoing investor service and support fee payments from products sponsors of hedge funds and managed futures available in Ameriprise Managed Accounts. Depending on the product, AEIS will receive payments up to 0.25% of the assets invested in these products. Mutual Fund & ETF Recommended list (“Starting Point List"). Ameriprise financial advisors may make mutual fund recommendations based on a group of funds that appear on the Starting Point List. Financial advisors are not required to use the Starting Point List as their source for mutual fund and ETF recommendations, and mutual funds contained on the Starting Point List may not be equally available across both Managed Accounts and Ameriprise brokerage accounts. All ETFs and mutual funds offered by Full Participation Firms or Available for Sale Firms, as further discussed below, must meet Ameriprise Financial Services’ due diligence standards to be eligible for inclusion on the Starting Point List. In developing the Starting Point List, the IRG applies a quantitative and qualitative evaluation process that includes an analysis of a fund’s returns, risk and expenses; the tenure and quality of the investment team; the soundness of the process and consistent implementation; and the overarching health of the organization. Certain mutual funds and ETFs that would have otherwise been included on Starting Point were excluded due to their high investment minimums. Client suitability must be considered when trading mutual funds and ETFs, including breakpoint discount eligibility and NAV transfer ability. The funds on the Starting Point List are subject to change periodically, however changes to the Starting Point List should not be the sole reason to prompt trading. The Starting Point List is developed by the IRG based on eligibility criteria established by Ameriprise Financial Services. Approximately 2,100 mutual funds are eligible for inclusion on the Starting Point List. The primary universe of ETFs includes funds available for sale at Ameriprise. The universe of mutual funds includes only mutual funds sponsored or managed by Full Participation Firms in the Mutual Fund Program. If a suitable mutual fund recommendation for a particular asset class cannot be found within the Full Participation Firms’ offerings, the IRG will proceed to look for mutual fund options sponsored or managed by “Available for Sale Firms”. Payments from UIT sponsors. Certain UIT sponsors with which AEIS has agreements may pay AEIS cost reimbursement payments to help promote and support the offer, sale and servicing of UITs. These UIT sponsors are granted full access to Ameriprise Financial Services and our financial advisors to provide direct financial advisor education or sales support to promote their products. UIT sponsors without such agreements do not provide direct financial advisor education or sales support, thus they do not have the same access to financial advisors as full access firms. Such marketing and sales support may create a conflict of interest if Ameriprise Financial Services promotes, or Ameriprise financial advisors recommend, the UITs from UIT sponsors that have been granted full access versus UITs offered by nonparticipating firms. These conflicts may arise from the marketing and sales support provided to our financial advisors by, as well as the payments AEIS receives from, firms that have entered into such agreements. AEIS will receive both a fixed dollar amount of cost reimbursement payments, based in part on projected UIT sales, as well as sales-based volume concessions. The total amount of these payments will not exceed 0.20% of total UIT sales. While the Starting Point List is developed by evaluating the performance characteristics of each fund’s Class A shares, the analysis is ultimately intended to apply at the mutual fund level. Mutual funds included on the Starting Point List may or may not offer an Advisory Share class or other share class that is available in our Managed Accounts Programs. As a result, Managed Account clients may be unable to purchase a fund on the Starting Point List. Similarly, Ameriprise brokerage account clients may be unable to purchase a mutual fund on the Starting Point List if that fund does not offer a share class available in Ameriprise brokerage accounts. In addition, some mutual funds included on the Starting Point List may offer lower-cost share classes than the Advisory Share class or other share class available in Managed Account Programs. You should consider whether you may be eligible to purchase these lower-cost share classes outside the Programs. Payments from insurance companies. Cost reimbursement payments are received by Ameriprise Financial Services and/or its affiliate, AEIS, from affiliated and unaffiliated insurance companies. Ameriprise Financial Services sells annuity and insurance products to its clients manufactured by its affiliate, RiverSource, as well as from select unaffiliated insurance companies. 23 24 servicing fees assessed in Ameriprise brokerage accounts may be used to pay for marketing, distribution and shareholder service expenses. Any 12b-1 shareholder servicing fees received for the share class utilized in any Managed Accounts will be rebated to clients. These eligibility criteria are designed by Ameriprise Financial Services to primarily include, and therefore favor, mutual funds from Full Participation Firms. To be included in the Mutual Fund Program and be eligible for inclusion on the Starting Point List, each Full Participation Firm must meet a number of criteria that consider product breadth and strong-performing funds, financial strength of the firm and the ability to provide education and training to Ameriprise financial advisors, including marketing and sales support services relating to the funds they offer. Full Participation Firms have also agreed to pay our affiliate, AEIS, a portion of the revenue generated from the sale and/or management of fund shares as further described above. Ameriprise Preferred Line of Credit and Loan. Ameriprise Financial Services receives compensation from Ameriprise Bank of 0.25% on an annualized basis of the amount of the credit line or loan outstanding balance. This amount is shared with your Ameriprise financial advisor based on how your advisor is affiliated with us and on the payout rate for which your financial advisor qualifies. These affiliations and compensation structures are described in the “Financial Advisors Compensation & Benefits” section of this Brochure. The universe of mutual funds eligible for purchase in Signature Wealth generally represents a sub-set of the funds that appear on the Starting Point List or are otherwise sponsored or managed by Full Participation Firms that make cost reimbursement payments to AEIS. The list of eligible funds for Signature Wealth is therefore designed to primarily include, and therefore favor, mutual funds from Full Participation Firms. Ameriprise Bank Savings Account and CDs. Ameriprise Financial Services receives compensation from Ameriprise Bank of 0.05% on an annualized basis of the amount of the average monthly balance. This amount is shared with your Ameriprise financial advisor based on how your advisor is affiliated with us and on the payout rate for which your financial advisor qualifies. These affiliations and compensations structures are described in the “Financial Advisors Compensation & Benefits” section of this Brochure. Payments for referrals to structured settlements annuity brokers. Ameriprise Financial Services receives a fee, shared with financial advisors, for referrals to non- affiliated structured settlement professionals for both client and non-client referrals. The amount and basis for the referral fee varies by relationship multiplied by the notional sales amount of the product. Underwriters’ compensation. Ameriprise Financial Services receives a fee comprised of a selling concession, management fee, underwriting fee, and in some cases, a structuring fee for the sale of initial public offerings (“IPOs”) such as closed-end funds and preferred securities. The specific amounts vary by individual offering and are discussed in the prospectus of each offering. Transaction charges. Ameriprise Financial Services does not assess online transactions charges in Managed Accounts to financial advisors. Franchisee financial advisors are assessed a transaction charge if entering an order by phone for SPS Advantage or SPS Advisor accounts. For employee financial advisors, this transaction charge is assessed to the employee’s branch and not paid by the advisor. Direct payment by the financial advisor of phone-in transaction charges may be a disincentive for a franchisee financial advisor to recommend an SPS Advantage or SPS Advisor account or to recommend trades in the accounts. Available for Sale Firms make payments at a lower percentage rate than Full Participation Firms. They do not have the same wholesaling access to financial advisors as Full Participation Firms. As a result, Ameriprise financial advisors may have a greater familiarity with and an incentive to sell funds of Full Participation Firms. The payments made to AEIS by Full Participation Firms and Available for Sale Firms reimburse the costs of client beneficial services provided by Ameriprise Financial Services and AEIS to financial advisors and clients, including but not limited to distribution, marketing, administration and shareholder servicing support, due diligence, training and education, and other support related functions (e.g., Cost Reimbursement Services) and increase the revenues and profitability of AEIS. The most significant of these payments are reimbursement for marketing support received from Full Participation Firms and other product companies. Full Participation Firms make Cost Reimbursement Payments at a higher percentage rate than do Available for Sale Firms. This presents a conflict of interest as Full Participation Firms pay AEIS more revenue than Available for Sale Firms, and thus AEIS earns more revenue from the purchase of mutual funds offered by Full Participation Firms than from the purchase of mutual funds offered by Available for Sale Firms. Clients may choose to follow the recommendations provided by their Ameriprise financial advisor or they may select from any of the other funds offered through Ameriprise Financial Services regardless of whether that fund appears on the Starting Point List. More information on the Full Participation Firms that participate in the Program, specific arrangements we have with them, and conflicts of interest or incentives that exist for Ameriprise Financial Services to promote (and for Ameriprise financial advisors to recommend) one fund over another fund is provided on our website at ameriprise.com/funds and click "Purchasing Mutual Funds Through Ameriprise." Revenue sources for Ameriprise Financial Services, LLC For Managed Accounts, Ameriprise financial advisors pay the same mutual fund transaction rate for orders entered by phone for all mutual fund firms. Not all mutual fund families are available for purchase in a Managed Account. For more information about payments and potential conflicts of interest, please see the applicable prospectus, term sheet, application or other client disclosure forms. Financial planning and advisory service fees. These are fees you pay for financial planning and fee-based investment advisory account services, respectively. Distribution access fees. Ameriprise Financial Services directs securities purchase and sale transactions through our affiliate, AEIS, on a fully disclosed basis. In exchange, Ameriprise Financial Services receives reimbursements from AEIS for our non-distribution related expenses. Financial interest in products Ameriprise Financial Services has a financial interest in the sales of proprietary products that are manufactured by its affiliates. Ameriprise Financial Services and its affiliates receive more revenue from the sale of some financial products and services, particularly those products and services sold under the Ameriprise, Columbia Threadneedle Investments and RiverSource brands, than for the sale of other products and services. Ameriprise brokerage account sales charges. Sales charges, commissions and/or selling concessions are paid when you buy or sell equities or fixed income products including corporate bonds and municipal securities, mutual funds, ETFs, 529 plans, closed- end funds, preferred securities, UITs, non-traded REITs, non-traded BDCs, non- traded closed-end funds, hedge fund offerings, exchange funds, private equity offerings, managed futures funds, real estate private placement offerings and structured products. In addition, you may pay a markup or markdown in bond transactions executed in a principal capacity with AEIS. These charges vary by product and product type. For example, with respect to mutual funds, the sales charge for a stock mutual fund is typically greater than that for a bond mutual fund. For other product types such as non-traded REITs, the sales charge you pay may also include a portion of the distribution, organization and offering fees and expenses. Periodic Fees. Periodic fees include IRA custodial fees, brokerage fees (i.e., account maintenance and order handling fees), and a portion of the fees associated with certain banking products and services (i.e., personal trust services). Generally, Ameriprise Financial Services receives more revenue for securities or products sold in a fee-based account than for those sold with only a sales charge or commission. Higher revenue generally results in greater profitability for Ameriprise Financial Services. Employee compensation (including management and field leader compensation) and operating goals at all levels of the company are tied to the company’s success. Management, sales leaders and other employees generally spend more of their time and resources promoting Ameriprise, Columbia Threadneedle Investments and RiverSource branded products and services. Sales charges, trading commissions, markups, markdowns and financial planning and advisory services fees are not eligible for reimbursement or offered at a discount. Periodic expenses. Periodic expenses are paid from product assets, such as 12b-1 shareholder servicing fees paid from mutual fund assets (including 12b-1 fees paid on certain funds that serve as underlying investment options for 529 plan assets) and distribution fees paid from Ameriprise Certificate Company assets. 12b-1 shareholder Any 12b-1 fees received by Ameriprise Financial Services for mutual funds held in any Managed Accounts will be rebated to clients, and financial advisors do not receive compensation from 12b-1 fees assessed on mutual funds held in Managed Accounts. For brokerage accounts, both Ameriprise Financial Services and individual financial advisors are compensated when clients buy mutual funds through Ameriprise Financial Services. Generally, 25 26 servicing fees assessed in Ameriprise brokerage accounts may be used to pay for marketing, distribution and shareholder service expenses. Any 12b-1 shareholder servicing fees received for the share class utilized in any Managed Accounts will be rebated to clients. These eligibility criteria are designed by Ameriprise Financial Services to primarily include, and therefore favor, mutual funds from Full Participation Firms. To be included in the Mutual Fund Program and be eligible for inclusion on the Starting Point List, each Full Participation Firm must meet a number of criteria that consider product breadth and strong-performing funds, financial strength of the firm and the ability to provide education and training to Ameriprise financial advisors, including marketing and sales support services relating to the funds they offer. Full Participation Firms have also agreed to pay our affiliate, AEIS, a portion of the revenue generated from the sale and/or management of fund shares as further described above. Ameriprise Preferred Line of Credit and Loan. Ameriprise Financial Services receives compensation from Ameriprise Bank of 0.25% on an annualized basis of the amount of the credit line or loan outstanding balance. This amount is shared with your Ameriprise financial advisor based on how your advisor is affiliated with us and on the payout rate for which your financial advisor qualifies. These affiliations and compensation structures are described in the “Financial Advisors Compensation & Benefits” section of this Brochure. The universe of mutual funds eligible for purchase in Signature Wealth generally represents a sub-set of the funds that appear on the Starting Point List or are otherwise sponsored or managed by Full Participation Firms that make cost reimbursement payments to AEIS. The list of eligible funds for Signature Wealth is therefore designed to primarily include, and therefore favor, mutual funds from Full Participation Firms. Ameriprise Bank Savings Account and CDs. Ameriprise Financial Services receives compensation from Ameriprise Bank of 0.05% on an annualized basis of the amount of the average monthly balance. This amount is shared with your Ameriprise financial advisor based on how your advisor is affiliated with us and on the payout rate for which your financial advisor qualifies. These affiliations and compensations structures are described in the “Financial Advisors Compensation & Benefits” section of this Brochure. Payments for referrals to structured settlements annuity brokers. Ameriprise Financial Services receives a fee, shared with financial advisors, for referrals to non- affiliated structured settlement professionals for both client and non-client referrals. The amount and basis for the referral fee varies by relationship multiplied by the notional sales amount of the product. Underwriters’ compensation. Ameriprise Financial Services receives a fee comprised of a selling concession, management fee, underwriting fee, and in some cases, a structuring fee for the sale of initial public offerings (“IPOs”) such as closed-end funds and preferred securities. The specific amounts vary by individual offering and are discussed in the prospectus of each offering. Transaction charges. Ameriprise Financial Services does not assess online transactions charges in Managed Accounts to financial advisors. Franchisee financial advisors are assessed a transaction charge if entering an order by phone for SPS Advantage or SPS Advisor accounts. For employee financial advisors, this transaction charge is assessed to the employee’s branch and not paid by the advisor. Direct payment by the financial advisor of phone-in transaction charges may be a disincentive for a franchisee financial advisor to recommend an SPS Advantage or SPS Advisor account or to recommend trades in the accounts. Available for Sale Firms make payments at a lower percentage rate than Full Participation Firms. They do not have the same wholesaling access to financial advisors as Full Participation Firms. As a result, Ameriprise financial advisors may have a greater familiarity with and an incentive to sell funds of Full Participation Firms. The payments made to AEIS by Full Participation Firms and Available for Sale Firms reimburse the costs of client beneficial services provided by Ameriprise Financial Services and AEIS to financial advisors and clients, including but not limited to distribution, marketing, administration and shareholder servicing support, due diligence, training and education, and other support related functions (e.g., Cost Reimbursement Services) and increase the revenues and profitability of AEIS. The most significant of these payments are reimbursement for marketing support received from Full Participation Firms and other product companies. Full Participation Firms make Cost Reimbursement Payments at a higher percentage rate than do Available for Sale Firms. This presents a conflict of interest as Full Participation Firms pay AEIS more revenue than Available for Sale Firms, and thus AEIS earns more revenue from the purchase of mutual funds offered by Full Participation Firms than from the purchase of mutual funds offered by Available for Sale Firms. Clients may choose to follow the recommendations provided by their Ameriprise financial advisor or they may select from any of the other funds offered through Ameriprise Financial Services regardless of whether that fund appears on the Starting Point List. More information on the Full Participation Firms that participate in the Program, specific arrangements we have with them, and conflicts of interest or incentives that exist for Ameriprise Financial Services to promote (and for Ameriprise financial advisors to recommend) one fund over another fund is provided on our website at ameriprise.com/funds and click "Purchasing Mutual Funds Through Ameriprise." Revenue sources for Ameriprise Financial Services, LLC For Managed Accounts, Ameriprise financial advisors pay the same mutual fund transaction rate for orders entered by phone for all mutual fund firms. Not all mutual fund families are available for purchase in a Managed Account. For more information about payments and potential conflicts of interest, please see the applicable prospectus, term sheet, application or other client disclosure forms. Financial planning and advisory service fees. These are fees you pay for financial planning and fee-based investment advisory account services, respectively. Distribution access fees. Ameriprise Financial Services directs securities purchase and sale transactions through our affiliate, AEIS, on a fully disclosed basis. In exchange, Ameriprise Financial Services receives reimbursements from AEIS for our non-distribution related expenses. Financial interest in products Ameriprise Financial Services has a financial interest in the sales of proprietary products that are manufactured by its affiliates. Ameriprise Financial Services and its affiliates receive more revenue from the sale of some financial products and services, particularly those products and services sold under the Ameriprise, Columbia Threadneedle Investments and RiverSource brands, than for the sale of other products and services. Ameriprise brokerage account sales charges. Sales charges, commissions and/or selling concessions are paid when you buy or sell equities or fixed income products including corporate bonds and municipal securities, mutual funds, ETFs, 529 plans, closed- end funds, preferred securities, UITs, non-traded REITs, non-traded BDCs, non- traded closed-end funds, hedge fund offerings, exchange funds, private equity offerings, managed futures funds, real estate private placement offerings and structured products. In addition, you may pay a markup or markdown in bond transactions executed in a principal capacity with AEIS. These charges vary by product and product type. For example, with respect to mutual funds, the sales charge for a stock mutual fund is typically greater than that for a bond mutual fund. For other product types such as non-traded REITs, the sales charge you pay may also include a portion of the distribution, organization and offering fees and expenses. Periodic Fees. Periodic fees include IRA custodial fees, brokerage fees (i.e., account maintenance and order handling fees), and a portion of the fees associated with certain banking products and services (i.e., personal trust services). Generally, Ameriprise Financial Services receives more revenue for securities or products sold in a fee-based account than for those sold with only a sales charge or commission. Higher revenue generally results in greater profitability for Ameriprise Financial Services. Employee compensation (including management and field leader compensation) and operating goals at all levels of the company are tied to the company’s success. Management, sales leaders and other employees generally spend more of their time and resources promoting Ameriprise, Columbia Threadneedle Investments and RiverSource branded products and services. Sales charges, trading commissions, markups, markdowns and financial planning and advisory services fees are not eligible for reimbursement or offered at a discount. Periodic expenses. Periodic expenses are paid from product assets, such as 12b-1 shareholder servicing fees paid from mutual fund assets (including 12b-1 fees paid on certain funds that serve as underlying investment options for 529 plan assets) and distribution fees paid from Ameriprise Certificate Company assets. 12b-1 shareholder Any 12b-1 fees received by Ameriprise Financial Services for mutual funds held in any Managed Accounts will be rebated to clients, and financial advisors do not receive compensation from 12b-1 fees assessed on mutual funds held in Managed Accounts. For brokerage accounts, both Ameriprise Financial Services and individual financial advisors are compensated when clients buy mutual funds through Ameriprise Financial Services. Generally, 25 26 financial advisors receive a portion of the sales charge and 12b-1 fees paid to the firm in connection with mutual fund purchases for as long as clients own the mutual fund shares. Sales charges and 12b-1 fees vary from mutual fund to mutual fund and from share class to share class. Ameriprise Financial Services and the financial advisor receive more compensation on fund or share classes that pay higher fees. Ameriprise Financial Services and the financial advisor generally receive less compensation when the sales charge and/or 12b-1 fee is reduced, waived completely, or where there is no sales charge or 12b-1 fee. Therefore, for brokerage accounts there is an incentive for our financial advisors to sell a fund that pays a load or a fund that pays a 12b-1 fee over funds that do not. Financial advisors are required to take training on complex products developed by Ameriprise Financial Services and its affiliates and non-affiliated product manufacturers, prior to soliciting certain insurance and annuity products and a targeted subset of nonproprietary products. Additional general product training is available and specific product training is required for a number of complex products, including Columbia Threadneedle Investments and RiverSource branded products. It is likely that a product recommendation from your financial advisor will be drawn from the universe of products on which they were trained. Ameriprise Financial Services may enter into strategic alliances with companies that offer products or services that Ameriprise Financial Services and its financial advisors do not sell. As part of those alliances, Ameriprise financial advisors may receive gifts or non- cash compensation from the other companies, which are subject to SEC and FINRA regulations as well as Ameriprise Financial Services’ internal compliance policies. Some, but not all, of the financial planning software tools available for use by your financial advisor were developed by Ameriprise Financial Services or by unaffiliated third parties and may make it more convenient for your financial advisor to select proprietary products. Ameriprise Financial Services and Ameriprise financial advisors are paid in different ways for helping you choose mutual funds, depending on the type of fund, amount invested, and share class purchased. Financial advisors receive compensation only from 12b-1 fees for mutual funds held in brokerage accounts. Ameriprise Financial Services and financial advisors receive more compensation for sales of certain types of products, such as insurance, rather than others. Most Ameriprise financial advisors are also appointed agents of RiverSource Life and, in New York only, RiverSource Life of New York, affiliates of Ameriprise Financial Services. Economic benefits of affiliates’ products and services Ameriprise Financial Services grants RiverSource access to Ameriprise financial advisors and provides RiverSource with limited information related to Ameriprise clients to promote sales of RiverSource products and to assist financial advisors in understanding the features and benefits of those products. Ameriprise Financial Services does not grant this access to other non-affiliated companies offering similar products, thus they do not have the same access to financial advisors as RiverSource. As with all financial services firms, a portion of our revenue and compensation can generate a profit for the firm. The revenue and compensation we receive help us cover our expenses in providing and servicing these products and services. Employee and financial advisor compensation and operating goals at all levels of Ameriprise Financial, Inc. are tied to the success of its businesses. As a result, certain incentives and conflicts of interest may exist for Ameriprise Financial Services, our affiliates and our financial advisors if you purchase certain products or services recommended by your financial advisor. Generally, among other things, Ameriprise Financial Services and our affiliates will receive: Additionally, it is possible that Ameriprise Bank would send an order on behalf of a trust account to AEIS and at the same time AEIS would execute the opposite order for a brokerage client. Investments may be made for Ameriprise Bank’s trust accounts in which Ameriprise Financial Services or its related persons have a position or interest. Although Ameriprise Financial Services and its related persons may own securities suitable for or held by clients, in no case will holdings of Ameriprise Financial, Inc., its subsidiaries or their employees or directors be directly sold to or purchased from Ameriprise Bank’s trust accounts. AEIS, an affiliate of Ameriprise Financial Services, may buy or • More revenue, in aggregate, from the purchase of products sponsored or managed by Ameriprise, Columbia Management and RiverSource (“proprietary products”) than from the purchase of products sponsored or managed by firms that aren’t affiliated with Ameriprise Financial, Inc. (“nonproprietary products”). Ameriprise Financial Services actively promotes the products of our affiliates through advertising, direct mail, and product support and training events. sell for its own account securities that Ameriprise Financial Services may recommend for Ameriprise Bank’s trust accounts. • More revenue from the purchase of products and services than from Wrap Fees. • More revenue as the size of any margin account or Ameriprise Preferred Line of Credit balance increases. • More revenue when you purchase certain types of products, such as insurance and annuity products and Ameriprise Financial Services does not anticipate that conflicts of interest will arise because we have adopted policies and procedures prohibiting Ameriprise Financial Services and our related persons from engaging in trading activity that creates a conflict of interest with our clients, as discussed in the “Code of Ethics, Participation or Interest in Transactions and Personal Trading” section. direct investments. Financial advisor compensation and benefits • More revenue from products and services that generate ongoing revenue streams, such as mutual funds that pay ongoing 12b-1 fees, an investment advisory account service, and insurance and annuity products with mortality and expense charges. The compensation programs for our financial advisors may vary based on, among other factors, the financial advisor’s industry experience, tenure with Ameriprise Financial Services, the type of practice structure (solo or team), and whether the financial advisor was formerly associated with a firm acquired by Ameriprise Financial, Inc. • More revenue when you purchase shares of mutual funds or 529 plans from Full Participation Firms than from firms with other distribution support relationships, as described in the “Cost reimbursement services and third-party payments” section of this Brochure. • More revenue when you purchase investment products for which we receive cost reimbursement payments or have similar financial arrangements, as described in the “Cost reimbursement services and third-party payments” and “Revenue sources for Ameriprise Financial Services, LLC” sections of this Brochure. An Ameriprise financial advisor is assigned to every investment advisory service. Ameriprise financial advisors have a wide range of business and educational backgrounds. They are required to have appropriate licenses and registrations to transact business, including Financial Industry Regulatory Authority (“FINRA”) registration, required state securities and insurance licenses and carrier appointments and, where required, a state investment adviser representative registration. • Less revenue when a sales charge or commission is reduced or waived completely, or where there is no sales charge. • More revenue when you move assets (including retirement plan accounts) from another institution to Many financial advisors hold advanced academic degrees and/or professional designations, including the Certified Financial Planner™ (CFP®) designation. In addition, ongoing training is available to financial advisors. For additional important information about an advisor check FINRA BrokerCheck at www.finra.org/brokercheck or call 800.289.9999. Ameriprise Financial Services or RiverSource or into a product managed by Columbia Management or another affiliate. Your financial advisor earns a living by providing you with financial advice and product recommendations to suit your goals. To understand how your financial advisor gets paid, you should first know that there are four ways Ameriprise financial advisors can be affiliated with us. 27 28 financial advisors receive a portion of the sales charge and 12b-1 fees paid to the firm in connection with mutual fund purchases for as long as clients own the mutual fund shares. Sales charges and 12b-1 fees vary from mutual fund to mutual fund and from share class to share class. Ameriprise Financial Services and the financial advisor receive more compensation on fund or share classes that pay higher fees. Ameriprise Financial Services and the financial advisor generally receive less compensation when the sales charge and/or 12b-1 fee is reduced, waived completely, or where there is no sales charge or 12b-1 fee. Therefore, for brokerage accounts there is an incentive for our financial advisors to sell a fund that pays a load or a fund that pays a 12b-1 fee over funds that do not. Financial advisors are required to take training on complex products developed by Ameriprise Financial Services and its affiliates and non-affiliated product manufacturers, prior to soliciting certain insurance and annuity products and a targeted subset of nonproprietary products. Additional general product training is available and specific product training is required for a number of complex products, including Columbia Threadneedle Investments and RiverSource branded products. It is likely that a product recommendation from your financial advisor will be drawn from the universe of products on which they were trained. Ameriprise Financial Services may enter into strategic alliances with companies that offer products or services that Ameriprise Financial Services and its financial advisors do not sell. As part of those alliances, Ameriprise financial advisors may receive gifts or non- cash compensation from the other companies, which are subject to SEC and FINRA regulations as well as Ameriprise Financial Services’ internal compliance policies. Some, but not all, of the financial planning software tools available for use by your financial advisor were developed by Ameriprise Financial Services or by unaffiliated third parties and may make it more convenient for your financial advisor to select proprietary products. Ameriprise Financial Services and Ameriprise financial advisors are paid in different ways for helping you choose mutual funds, depending on the type of fund, amount invested, and share class purchased. Financial advisors receive compensation only from 12b-1 fees for mutual funds held in brokerage accounts. Ameriprise Financial Services and financial advisors receive more compensation for sales of certain types of products, such as insurance, rather than others. Most Ameriprise financial advisors are also appointed agents of RiverSource Life and, in New York only, RiverSource Life of New York, affiliates of Ameriprise Financial Services. Economic benefits of affiliates’ products and services Ameriprise Financial Services grants RiverSource access to Ameriprise financial advisors and provides RiverSource with limited information related to Ameriprise clients to promote sales of RiverSource products and to assist financial advisors in understanding the features and benefits of those products. Ameriprise Financial Services does not grant this access to other non-affiliated companies offering similar products, thus they do not have the same access to financial advisors as RiverSource. As with all financial services firms, a portion of our revenue and compensation can generate a profit for the firm. The revenue and compensation we receive help us cover our expenses in providing and servicing these products and services. Employee and financial advisor compensation and operating goals at all levels of Ameriprise Financial, Inc. are tied to the success of its businesses. As a result, certain incentives and conflicts of interest may exist for Ameriprise Financial Services, our affiliates and our financial advisors if you purchase certain products or services recommended by your financial advisor. Generally, among other things, Ameriprise Financial Services and our affiliates will receive: Additionally, it is possible that Ameriprise Bank would send an order on behalf of a trust account to AEIS and at the same time AEIS would execute the opposite order for a brokerage client. Investments may be made for Ameriprise Bank’s trust accounts in which Ameriprise Financial Services or its related persons have a position or interest. Although Ameriprise Financial Services and its related persons may own securities suitable for or held by clients, in no case will holdings of Ameriprise Financial, Inc., its subsidiaries or their employees or directors be directly sold to or purchased from Ameriprise Bank’s trust accounts. AEIS, an affiliate of Ameriprise Financial Services, may buy or • More revenue, in aggregate, from the purchase of products sponsored or managed by Ameriprise, Columbia Management and RiverSource (“proprietary products”) than from the purchase of products sponsored or managed by firms that aren’t affiliated with Ameriprise Financial, Inc. (“nonproprietary products”). Ameriprise Financial Services actively promotes the products of our affiliates through advertising, direct mail, and product support and training events. sell for its own account securities that Ameriprise Financial Services may recommend for Ameriprise Bank’s trust accounts. • More revenue from the purchase of products and services than from Wrap Fees. • More revenue as the size of any margin account or Ameriprise Preferred Line of Credit balance increases. • More revenue when you purchase certain types of products, such as insurance and annuity products and Ameriprise Financial Services does not anticipate that conflicts of interest will arise because we have adopted policies and procedures prohibiting Ameriprise Financial Services and our related persons from engaging in trading activity that creates a conflict of interest with our clients, as discussed in the “Code of Ethics, Participation or Interest in Transactions and Personal Trading” section. direct investments. Financial advisor compensation and benefits • More revenue from products and services that generate ongoing revenue streams, such as mutual funds that pay ongoing 12b-1 fees, an investment advisory account service, and insurance and annuity products with mortality and expense charges. The compensation programs for our financial advisors may vary based on, among other factors, the financial advisor’s industry experience, tenure with Ameriprise Financial Services, the type of practice structure (solo or team), and whether the financial advisor was formerly associated with a firm acquired by Ameriprise Financial, Inc. • More revenue when you purchase shares of mutual funds or 529 plans from Full Participation Firms than from firms with other distribution support relationships, as described in the “Cost reimbursement services and third-party payments” section of this Brochure. • More revenue when you purchase investment products for which we receive cost reimbursement payments or have similar financial arrangements, as described in the “Cost reimbursement services and third-party payments” and “Revenue sources for Ameriprise Financial Services, LLC” sections of this Brochure. An Ameriprise financial advisor is assigned to every investment advisory service. Ameriprise financial advisors have a wide range of business and educational backgrounds. They are required to have appropriate licenses and registrations to transact business, including Financial Industry Regulatory Authority (“FINRA”) registration, required state securities and insurance licenses and carrier appointments and, where required, a state investment adviser representative registration. • Less revenue when a sales charge or commission is reduced or waived completely, or where there is no sales charge. • More revenue when you move assets (including retirement plan accounts) from another institution to Many financial advisors hold advanced academic degrees and/or professional designations, including the Certified Financial Planner™ (CFP®) designation. In addition, ongoing training is available to financial advisors. For additional important information about an advisor check FINRA BrokerCheck at www.finra.org/brokercheck or call 800.289.9999. Ameriprise Financial Services or RiverSource or into a product managed by Columbia Management or another affiliate. Your financial advisor earns a living by providing you with financial advice and product recommendations to suit your goals. To understand how your financial advisor gets paid, you should first know that there are four ways Ameriprise financial advisors can be affiliated with us. 27 28 • Independent contractor franchisees. These financial advisors are not employed by Ameriprise Financial Services and they do not receive a salary from us. • Employee financial advisors. These financial advisors are employed by Ameriprise Financial Services. • Associate financial advisors. These financial advisors are employed by or contract with the independent contractor franchisees and they do not receive a salary or other compensation from Ameriprise Financial Services. within a Managed Account. However, the amount of this compensation may be more or less than what your financial advisor would receive if you paid separately for investment advice, brokerage and other transaction-based services. Therefore, your financial advisor may have a financial incentive to recommend a Program over a transaction-based brokerage account. Ameriprise Financial Services seeks to address this conflict of interest through a combination of disclosures and through our policies, procedures and supervision, related to the review and determination that a Managed Account is appropriate for you based on your financial and risk profile information and investment objectives (“Client Information”) in accordance with all applicable regulatory requirements. • Financial institution employee financial advisors. These financial advisors are employed by the financial Other compensation available to financial advisors. The compensation programs for our financial advisors may vary based on, among other factors, the financial advisor’s industry experience, tenure with Ameriprise Financial Services, the type of practice structure (solo or team), and whether the financial advisor was formerly associated with a firm acquired by Ameriprise Financial, Inc. institution where they provide services and are compensated by the financial institution from the portion of fees and commissions it receives from Ameriprise Financial Services. The financial institution serves as paying agent for such compensation on our behalf in accordance with applicable law. Financial institution employee financial advisors’ compensation is based on their employment agreement with the financial institution. All Ameriprise financial advisors are licensed registered representatives. Depending on the affiliation, our financial advisors are compensated differently. Financial advisors may choose to change how they are affiliated with Ameriprise Financial Services over time. Ameriprise Financial Services offers a vast range of investment solutions to clients. Some products and services may be offered only by certain Ameriprise financial advisors. Discuss with your financial advisor the products he or she offers and the compensation your financial advisor receives, as some investment product companies and issuers, including RiverSource, may pay higher compensation than others. Generally, among other things, your financial advisor may earn: • More depending on how your financial advisor is affiliated with Ameriprise Financial Services, as Salary and bonus. In addition to the fees described below, employee financial advisors may receive a salary or wage from Ameriprise Financial Services. Associate financial advisors may receive either a salary or a flat fee from the independent contractor franchisee for whom they work, at the discretion of the employing or contracting independent contractor franchisee. described above • More on the sale of certain fixed life and disability insurance products because of special Financial advisors may also have the potential to receive bonus compensation. At the discretion of the employing or contracting independent contractor franchisee, the associate financial advisor may receive a bonus. compensation programs that provide increasing levels of compensation the more a financial advisor sells of these products from each individual insurance company. • More on the purchase of annuity and insurance products and direct investments, because they are more complex than other products and take more time to service. • More revenue from products and services that generate ongoing revenue streams, such as mutual Advisory fees and compensation. The AFPS fee and any applicable Advisory Fee you pay in your Managed Account is shared between Ameriprise Financial Services and your financial advisor as further described below. Both independent contractor franchisee financial advisors and employee financial advisors receive a portion of the Advisory Fee and, if applicable, a portion of the AFPS Fee as compensation for your participation in a Managed Account Program. Independent contractor franchisee financial advisors, however, receive a higher portion, or payout rate. funds that pay ongoing 12b-1 fees, an investment advisory account service, and insurance and annuity products with mortality and expense charges. • More from certain sales incentive programs to increase overall assets under management. A portion of the AFPS fee and Advisory Fee is paid to your financial advisor for introducing you to the service, gathering the information necessary to prepare your service, helping you establish needs and goals, preparing and presenting your service, and/or providing financial advice on behalf of Ameriprise Financial Services. • Less on individual purchases within a transaction- based brokerage account because of the higher transaction charges your financial advisor pays on these accounts compared to a fee-based investment advisory account. The remaining portion of the fees goes to Ameriprise Financial Services for the supervisory, technical, administrative and other support that is provided to all financial advisors. The portion of fees retained by Ameriprise Financial Services differs by the type of investment advisory program. • Less when a sales charge or commission is reduced or waived completely, or where there is no sales charge. • Typically, less when you exchange an existing annuity contract, mutual fund or insurance policy for The actual portion of the AFPS fee and Advisory Fee paid to your financial advisor depends on the payout rate for which your financial advisor qualifies and the amount of Asset-based Fees you pay. Only the Advisory Fee component of your Aset-based Fee is shared with your financial advisor. certain like or similar products from the same company, unless you have held the existing product for a certain period of time. • Independent contractor franchisees generally receive 72% to 91%, and employee financial advisors generally receive 0% to 46% of the advisory service fees and product commissions we receive (the “advisor payout rate”). • More revenue if you purchase securities on margin that you could not otherwise purchase in a cash account. • In addition, the financial advisor may qualify for a bonus which could increase the effective advisor payout rate up to 91% for independent contractor franchisees and 57% for employee financial advisors, respectively. • A higher payout rate based on the level of product sales, on the number of financial plans sold, and on higher face value and/or death benefit amount for certain insurance products. • Financial institution employee financial advisors generally receive an advisor payout rate of 0% to 91% based on their employment agreement with the financial institution. • More when you move accounts (including retirement plan accounts) from another institution to Ameriprise Financial Services, CMIA or RiverSource. • • If your financial advisor is a shareholder of Ameriprise Financial through our deferred compensation program, more compensation the more profitable the firm is. If you are a client of the Ameriprise Personal Wealth Group, your employee financial advisor does not receive a portion of the fees but may receive compensation in the form of a bonus based in part on revenue generated through your AFPS fee or Advisory Fee. • • Compensation for servicing trust accounts held with Ameriprise Bank. • Compensation for performing certain activities associated with your mortgage if that loan is In general, fees generated by an associate financial advisor are paid to the employing or contracting independent contractor franchisee. At the discretion of the employing or contracting independent contractor franchisee, the associate financial advisor may receive financial advisory or referral fees. purchased and serviced by Ameriprise Bank. Importantly, financial advisor compensation does not vary depending upon the investment(s) recommended to you 29 30 • Independent contractor franchisees. These financial advisors are not employed by Ameriprise Financial Services and they do not receive a salary from us. • Employee financial advisors. These financial advisors are employed by Ameriprise Financial Services. • Associate financial advisors. These financial advisors are employed by or contract with the independent contractor franchisees and they do not receive a salary or other compensation from Ameriprise Financial Services. within a Managed Account. However, the amount of this compensation may be more or less than what your financial advisor would receive if you paid separately for investment advice, brokerage and other transaction-based services. Therefore, your financial advisor may have a financial incentive to recommend a Program over a transaction-based brokerage account. Ameriprise Financial Services seeks to address this conflict of interest through a combination of disclosures and through our policies, procedures and supervision, related to the review and determination that a Managed Account is appropriate for you based on your financial and risk profile information and investment objectives (“Client Information”) in accordance with all applicable regulatory requirements. • Financial institution employee financial advisors. These financial advisors are employed by the financial Other compensation available to financial advisors. The compensation programs for our financial advisors may vary based on, among other factors, the financial advisor’s industry experience, tenure with Ameriprise Financial Services, the type of practice structure (solo or team), and whether the financial advisor was formerly associated with a firm acquired by Ameriprise Financial, Inc. institution where they provide services and are compensated by the financial institution from the portion of fees and commissions it receives from Ameriprise Financial Services. The financial institution serves as paying agent for such compensation on our behalf in accordance with applicable law. Financial institution employee financial advisors’ compensation is based on their employment agreement with the financial institution. All Ameriprise financial advisors are licensed registered representatives. Depending on the affiliation, our financial advisors are compensated differently. Financial advisors may choose to change how they are affiliated with Ameriprise Financial Services over time. Ameriprise Financial Services offers a vast range of investment solutions to clients. Some products and services may be offered only by certain Ameriprise financial advisors. Discuss with your financial advisor the products he or she offers and the compensation your financial advisor receives, as some investment product companies and issuers, including RiverSource, may pay higher compensation than others. Generally, among other things, your financial advisor may earn: • More depending on how your financial advisor is affiliated with Ameriprise Financial Services, as Salary and bonus. In addition to the fees described below, employee financial advisors may receive a salary or wage from Ameriprise Financial Services. Associate financial advisors may receive either a salary or a flat fee from the independent contractor franchisee for whom they work, at the discretion of the employing or contracting independent contractor franchisee. described above • More on the sale of certain fixed life and disability insurance products because of special Financial advisors may also have the potential to receive bonus compensation. At the discretion of the employing or contracting independent contractor franchisee, the associate financial advisor may receive a bonus. compensation programs that provide increasing levels of compensation the more a financial advisor sells of these products from each individual insurance company. • More on the purchase of annuity and insurance products and direct investments, because they are more complex than other products and take more time to service. • More revenue from products and services that generate ongoing revenue streams, such as mutual Advisory fees and compensation. The AFPS fee and any applicable Advisory Fee you pay in your Managed Account is shared between Ameriprise Financial Services and your financial advisor as further described below. Both independent contractor franchisee financial advisors and employee financial advisors receive a portion of the Advisory Fee and, if applicable, a portion of the AFPS Fee as compensation for your participation in a Managed Account Program. Independent contractor franchisee financial advisors, however, receive a higher portion, or payout rate. funds that pay ongoing 12b-1 fees, an investment advisory account service, and insurance and annuity products with mortality and expense charges. • More from certain sales incentive programs to increase overall assets under management. A portion of the AFPS fee and Advisory Fee is paid to your financial advisor for introducing you to the service, gathering the information necessary to prepare your service, helping you establish needs and goals, preparing and presenting your service, and/or providing financial advice on behalf of Ameriprise Financial Services. • Less on individual purchases within a transaction- based brokerage account because of the higher transaction charges your financial advisor pays on these accounts compared to a fee-based investment advisory account. The remaining portion of the fees goes to Ameriprise Financial Services for the supervisory, technical, administrative and other support that is provided to all financial advisors. The portion of fees retained by Ameriprise Financial Services differs by the type of investment advisory program. • Less when a sales charge or commission is reduced or waived completely, or where there is no sales charge. • Typically, less when you exchange an existing annuity contract, mutual fund or insurance policy for The actual portion of the AFPS fee and Advisory Fee paid to your financial advisor depends on the payout rate for which your financial advisor qualifies and the amount of Asset-based Fees you pay. Only the Advisory Fee component of your Aset-based Fee is shared with your financial advisor. certain like or similar products from the same company, unless you have held the existing product for a certain period of time. • Independent contractor franchisees generally receive 72% to 91%, and employee financial advisors generally receive 0% to 46% of the advisory service fees and product commissions we receive (the “advisor payout rate”). • More revenue if you purchase securities on margin that you could not otherwise purchase in a cash account. • In addition, the financial advisor may qualify for a bonus which could increase the effective advisor payout rate up to 91% for independent contractor franchisees and 57% for employee financial advisors, respectively. • A higher payout rate based on the level of product sales, on the number of financial plans sold, and on higher face value and/or death benefit amount for certain insurance products. • Financial institution employee financial advisors generally receive an advisor payout rate of 0% to 91% based on their employment agreement with the financial institution. • More when you move accounts (including retirement plan accounts) from another institution to Ameriprise Financial Services, CMIA or RiverSource. • • If your financial advisor is a shareholder of Ameriprise Financial through our deferred compensation program, more compensation the more profitable the firm is. If you are a client of the Ameriprise Personal Wealth Group, your employee financial advisor does not receive a portion of the fees but may receive compensation in the form of a bonus based in part on revenue generated through your AFPS fee or Advisory Fee. • • Compensation for servicing trust accounts held with Ameriprise Bank. • Compensation for performing certain activities associated with your mortgage if that loan is In general, fees generated by an associate financial advisor are paid to the employing or contracting independent contractor franchisee. At the discretion of the employing or contracting independent contractor franchisee, the associate financial advisor may receive financial advisory or referral fees. purchased and serviced by Ameriprise Bank. Importantly, financial advisor compensation does not vary depending upon the investment(s) recommended to you 29 30 • Compensation for providing services related to your Ameriprise Preferred Line of Credit based on an annualized fixed percentage of the client’s average daily outstanding balance. • Compensation for your Ameriprise Bank Savings Account and CD balances based on an annualized fixed percentage of the client’s average monthly balance. • Compensation for marketing that leads to you opening a co-branded credit card account provided you Financial advisor compensation — Incentives, training and education. Product companies with which we have agreements work with Ameriprise Financial Services and our financial advisors to promote their products. They may pay for training and education events or due diligence meetings; and may reimburse expenses for prospecting events such as seminars for employees, financial advisors, clients and prospective clients. For employees and financial advisors, these events may be held at off-site locations, and the travel, meals and accommodations may be paid for by the product company. Additionally, product companies may occasionally provide business or recreational entertainment or gifts of nominal value to employees and financial advisors. activate the card and meet the initial spend requirements. • Compensation for marketing that leads to your opening of an Ameriprise Bank Checking Account provided you meet the initial funding and other balance duration requirements. • Compensation for the sale or renewal of Ameriprise Certificates. Ameriprise Financial Services or sales leaders may, from time to time, offer contests or incentive programs to individual financial advisors or groups of financial advisors in particular areas. These contests and programs are limited to such targets as new client acquisition, financial plan count, net flows, total assets under management and financial advisor recruiting. Single product or product categories are not eligible for sales contests or incentive programs with the exception of fixed life and disability insurance. These programs and incentives and the receipt of other cash/noncash compensation could affect your financial advisor’s recommendations of products and/or services to you. These programs and incentives and other cash and/or noncash compensation are subject to SEC and FINRA regulations as well as Ameriprise Financial Services’ internal compliance policies. Financial advisor compensation — Insurance and annuity products. Our financial advisors primarily offer life, and disability insurance and annuity products from RiverSource and certain pre-approved, but unaffiliated, insurance companies. However, in some situations where the client’s needs may be met more effectively by another company’s product, and RiverSource and other pre-approved providers do not offer such a product, Ameriprise financial advisors may offer insurance products issued by unaffiliated insurance companies. If an unaffiliated insurance product is offered, the financial advisor is an appointed agent of the insurer and receives, directly or indirectly, compensation from the unaffiliated insurer for the sale and service of that product. The compensation for these nonproprietary products and RiverSource products is separate from, and in addition to, any fee you pay for investment advisory services and may vary depending on the type and size of the life insurance or annuity product that you purchase, the insurer that issues the product, and other factors. This compensation typically will increase as the size of the insurance policy or annuity contract increases, or the amount of the payments that you make on the life insurance or annuity product increases. Generally, the compensation that the financial advisor will receive is calculated by a formula. Compensation may also increase as the financial advisor sells increasing amounts of life and disability income insurance products issued by that insurer. Financial advisor compensation — Recruitment. Ameriprise Financial Services from time to time recruits financial advisors from other firms to join Ameriprise Financial Services. In connection with these recruiting efforts, Ameriprise Financial Services may enter into arrangements with financial advisors for the payment of compensation and/or loans based upon the value of eligible assets or accumulated production of the recruited financial advisor at a pre- determined measurement date. The funds may be payable immediately, over time, as a bonus, or as a loan. These arrangements may have been structured to include a provision requiring that payment of transition compensation and/or loans would be dependent upon the advisor meeting certain agreed-upon production and/or asset level benchmarks. The financial incentives associated with these transition arrangements could influence the type and amount of product and/or service recommended by your financial advisor. Ameriprise Financial Services manages this conflict of interest by supervising the suitability of recommendations made by its financial advisors in accordance with all applicable regulatory requirements. Please review your financial advisor’s Form ADV brochure supplement or ask your advisor if you have questions about whether these transition arrangements apply to them. In instances where a customer already owns a financial product sold by Ameriprise Financial Services, the amount of a financial advisor’s compensation may vary in connection with the sale of an additional or replacement product, due to formulas relating to the cancellation of a product that is already owned. From time to time, Ameriprise Financial Services also provides compensation to financial advisors in connection with the sale of all or a portion of their client base to an Ameriprise financial advisor. Some of this compensation may be dependent on a certain percentage of the client base remaining as clients of Ameriprise Financial Services for a certain period of time. It is also determined based on valuations of the financial advisor’s practice, or book of business. As a result, the financial advisor in such a transaction may have an incentive to recommend the purchase of additional or replacement insurance or annuity products or, conversely, an incentive to recommend that you not purchase additional or replacement insurance or annuity products, depending on the relevant compensation formula. Financial advisor compensation — Credit products and insurance referral. Your financial advisor receives compensation for the marketing that leads to your opening of a co-branded credit card account provided you activate the card and meet initial spend requirements. Ameriprise financial advisors will earn compensation for providing services related to your Ameriprise Preferred Line of Credit based on an annualized fixed percentage of the client’s average daily outstanding balance. The practice valuation formula results in higher compensation for revenues received from Managed Accounts versus Ameriprise brokerage accounts. As a result, your financial advisor has an incentive to recommend the opening of new Managed Accounts or the investment of additional assets into existing Managed Accounts or, conversely, an incentive to recommend that you not open an Ameriprise brokerage account or invest additional assets into a brokerage account. In addition, if your financial advisor is selling all or a portion of their practice to another Ameriprise financial advisor, this program could incent your financial advisor to recommend you remain a client of the acquiring financial advisor and/or Ameriprise Financial Services. Your financial advisor will receive compensation for performing certain activities associated with your mortgage or home equity line of credit if that loan is purchased and serviced by Ameriprise Bank. Ameriprise Financial, Inc. equity programs. We encourage our financial advisors to take an ownership stake in our future by holding stock in our parent company, Ameriprise Financial, Inc. (NYSE: AMP). To make this possible for financial advisors, we have created equity compensation programs for them. Employee financial advisors and independent contractor franchisees may be eligible to receive an annual stock bonus. In addition, independent contractor franchisees may be eligible to defer a certain percentage of their compensation each year. They may choose to invest all or portion of this deferral into a notional account that tracks the performance of Ameriprise Financial, Inc. stock. Your financial advisor receives referral fees when you purchase and maintain Ameriprise Auto and Home insurance products under a long-term distribution agreement between Ameriprise Financial Services, American Family Insurance Group and Ameriprise Auto & Home. Ameriprise Auto & Home is not affiliated with Ameriprise Financial Services and is owned by the American Family Insurance Group. However, Ameriprise Auto & Home Insurance and the associated logo are being used by American Family Insurance Group under a temporary license from Ameriprise Financial. Financial advisors who are independent contractor franchisees may build equity in their practices and may receive payments if they sell all or a part of their practices to other Ameriprise financial advisors. If Ameriprise Bank accepts a trust based upon a referral from your financial advisor, Ameriprise Financial Services will receive a referral fee from the Bank. A portion of this referral fee is shared with your financial advisor. The referral fee is paid by the Bank from the fees earned for its services and is not an additional cost to the trust account. Your financial advisor also receives a referral fee for referrals to non-affiliated structured settlement professionals for both client and non-client referrals. Loan programs. Clients may have access to information about lending products and services through marketing and/or lending relationships Ameriprise Bank has with third-party financial institutions. Financial advisors do not earn compensation related to the origination or referral of lending products (e.g., mortgages, home equity lines of credit) offered and originated by third-party providers. 31 32 • Compensation for providing services related to your Ameriprise Preferred Line of Credit based on an annualized fixed percentage of the client’s average daily outstanding balance. • Compensation for your Ameriprise Bank Savings Account and CD balances based on an annualized fixed percentage of the client’s average monthly balance. • Compensation for marketing that leads to you opening a co-branded credit card account provided you Financial advisor compensation — Incentives, training and education. Product companies with which we have agreements work with Ameriprise Financial Services and our financial advisors to promote their products. They may pay for training and education events or due diligence meetings; and may reimburse expenses for prospecting events such as seminars for employees, financial advisors, clients and prospective clients. For employees and financial advisors, these events may be held at off-site locations, and the travel, meals and accommodations may be paid for by the product company. Additionally, product companies may occasionally provide business or recreational entertainment or gifts of nominal value to employees and financial advisors. activate the card and meet the initial spend requirements. • Compensation for marketing that leads to your opening of an Ameriprise Bank Checking Account provided you meet the initial funding and other balance duration requirements. • Compensation for the sale or renewal of Ameriprise Certificates. Ameriprise Financial Services or sales leaders may, from time to time, offer contests or incentive programs to individual financial advisors or groups of financial advisors in particular areas. These contests and programs are limited to such targets as new client acquisition, financial plan count, net flows, total assets under management and financial advisor recruiting. Single product or product categories are not eligible for sales contests or incentive programs with the exception of fixed life and disability insurance. These programs and incentives and the receipt of other cash/noncash compensation could affect your financial advisor’s recommendations of products and/or services to you. These programs and incentives and other cash and/or noncash compensation are subject to SEC and FINRA regulations as well as Ameriprise Financial Services’ internal compliance policies. Financial advisor compensation — Insurance and annuity products. Our financial advisors primarily offer life, and disability insurance and annuity products from RiverSource and certain pre-approved, but unaffiliated, insurance companies. However, in some situations where the client’s needs may be met more effectively by another company’s product, and RiverSource and other pre-approved providers do not offer such a product, Ameriprise financial advisors may offer insurance products issued by unaffiliated insurance companies. If an unaffiliated insurance product is offered, the financial advisor is an appointed agent of the insurer and receives, directly or indirectly, compensation from the unaffiliated insurer for the sale and service of that product. The compensation for these nonproprietary products and RiverSource products is separate from, and in addition to, any fee you pay for investment advisory services and may vary depending on the type and size of the life insurance or annuity product that you purchase, the insurer that issues the product, and other factors. This compensation typically will increase as the size of the insurance policy or annuity contract increases, or the amount of the payments that you make on the life insurance or annuity product increases. Generally, the compensation that the financial advisor will receive is calculated by a formula. Compensation may also increase as the financial advisor sells increasing amounts of life and disability income insurance products issued by that insurer. Financial advisor compensation — Recruitment. Ameriprise Financial Services from time to time recruits financial advisors from other firms to join Ameriprise Financial Services. In connection with these recruiting efforts, Ameriprise Financial Services may enter into arrangements with financial advisors for the payment of compensation and/or loans based upon the value of eligible assets or accumulated production of the recruited financial advisor at a pre- determined measurement date. The funds may be payable immediately, over time, as a bonus, or as a loan. These arrangements may have been structured to include a provision requiring that payment of transition compensation and/or loans would be dependent upon the advisor meeting certain agreed-upon production and/or asset level benchmarks. The financial incentives associated with these transition arrangements could influence the type and amount of product and/or service recommended by your financial advisor. Ameriprise Financial Services manages this conflict of interest by supervising the suitability of recommendations made by its financial advisors in accordance with all applicable regulatory requirements. Please review your financial advisor’s Form ADV brochure supplement or ask your advisor if you have questions about whether these transition arrangements apply to them. In instances where a customer already owns a financial product sold by Ameriprise Financial Services, the amount of a financial advisor’s compensation may vary in connection with the sale of an additional or replacement product, due to formulas relating to the cancellation of a product that is already owned. From time to time, Ameriprise Financial Services also provides compensation to financial advisors in connection with the sale of all or a portion of their client base to an Ameriprise financial advisor. Some of this compensation may be dependent on a certain percentage of the client base remaining as clients of Ameriprise Financial Services for a certain period of time. It is also determined based on valuations of the financial advisor’s practice, or book of business. As a result, the financial advisor in such a transaction may have an incentive to recommend the purchase of additional or replacement insurance or annuity products or, conversely, an incentive to recommend that you not purchase additional or replacement insurance or annuity products, depending on the relevant compensation formula. Financial advisor compensation — Credit products and insurance referral. Your financial advisor receives compensation for the marketing that leads to your opening of a co-branded credit card account provided you activate the card and meet initial spend requirements. Ameriprise financial advisors will earn compensation for providing services related to your Ameriprise Preferred Line of Credit based on an annualized fixed percentage of the client’s average daily outstanding balance. The practice valuation formula results in higher compensation for revenues received from Managed Accounts versus Ameriprise brokerage accounts. As a result, your financial advisor has an incentive to recommend the opening of new Managed Accounts or the investment of additional assets into existing Managed Accounts or, conversely, an incentive to recommend that you not open an Ameriprise brokerage account or invest additional assets into a brokerage account. In addition, if your financial advisor is selling all or a portion of their practice to another Ameriprise financial advisor, this program could incent your financial advisor to recommend you remain a client of the acquiring financial advisor and/or Ameriprise Financial Services. Your financial advisor will receive compensation for performing certain activities associated with your mortgage or home equity line of credit if that loan is purchased and serviced by Ameriprise Bank. Ameriprise Financial, Inc. equity programs. We encourage our financial advisors to take an ownership stake in our future by holding stock in our parent company, Ameriprise Financial, Inc. (NYSE: AMP). To make this possible for financial advisors, we have created equity compensation programs for them. Employee financial advisors and independent contractor franchisees may be eligible to receive an annual stock bonus. In addition, independent contractor franchisees may be eligible to defer a certain percentage of their compensation each year. They may choose to invest all or portion of this deferral into a notional account that tracks the performance of Ameriprise Financial, Inc. stock. Your financial advisor receives referral fees when you purchase and maintain Ameriprise Auto and Home insurance products under a long-term distribution agreement between Ameriprise Financial Services, American Family Insurance Group and Ameriprise Auto & Home. Ameriprise Auto & Home is not affiliated with Ameriprise Financial Services and is owned by the American Family Insurance Group. However, Ameriprise Auto & Home Insurance and the associated logo are being used by American Family Insurance Group under a temporary license from Ameriprise Financial. Financial advisors who are independent contractor franchisees may build equity in their practices and may receive payments if they sell all or a part of their practices to other Ameriprise financial advisors. If Ameriprise Bank accepts a trust based upon a referral from your financial advisor, Ameriprise Financial Services will receive a referral fee from the Bank. A portion of this referral fee is shared with your financial advisor. The referral fee is paid by the Bank from the fees earned for its services and is not an additional cost to the trust account. Your financial advisor also receives a referral fee for referrals to non-affiliated structured settlement professionals for both client and non-client referrals. Loan programs. Clients may have access to information about lending products and services through marketing and/or lending relationships Ameriprise Bank has with third-party financial institutions. Financial advisors do not earn compensation related to the origination or referral of lending products (e.g., mortgages, home equity lines of credit) offered and originated by third-party providers. 31 32 Services provided may include entering data into financial planning software, proving initial calculation and assistance in creating solutions. Your financial advisor will provide final recommendations to you. For these services your financial advisor may pay a fee or salary to employed staff. Financial advisors and field leaders may share compensation with their registered support assistants or recommend bonuses for their non-registered support staff. Ameriprise Bank partners with Rocket Mortgage, LLC (NMLS#3030) that offers mortgage lending products and services. Ameriprise Financial Services and Ameriprise financial advisors do not accept any mortgage loan applications or offer or negotiate terms of any such loans. Financial advisors do not earn compensation related to the origination or referral of mortgage lending products offered and originated by such third-party providers. Ameriprise Bank may purchase and service some loans originated by Rocket Mortgage, LLC. Ameriprise Financial Services and Ameriprise financial advisors may receive compensation for assisting clients with mortgages serviced by Ameriprise Bank. Ameriprise Financial, Inc. is not affiliated with Rocket Mortgage, LLC. Ameriprise Bank does not guarantee products or services offered by Rocket Mortgage, LLC. Employee financial advisors and selling leaders may receive continuing commissions and fees for the sale of certain products and services for up to five years after leaving the securities industry. Ameriprise Bank has partnered with Elan Financial Services in offering Ameriprise co-branded credit cards. Your financial advisor receives compensation for marketing efforts that lead to your opening of a co-branded credit card account provided you activate the card and make sufficient purchases. Ameriprise offers a Business Development Account (BDA) Program. Eligible employee financial advisors may create a voluntary BDA in a predetermined amount and use this account for business-related expenses above and beyond what the company provides. Ameriprise Bank has partnered with Goldman Sachs to make available the Ameriprise Preferred Line of Credit and Loan. Ameriprise financial advisors will earn compensation for providing services related to your Ameriprise Preferred Line of Credit and Loan based on an annualized fixed percentage of the client’s average daily outstanding balance. Apart from margin lending offered by AEIS, neither your Ameriprise financial advisor nor Ameriprise Financial Services may arrange, promote, suggest or knowingly permit you to use line or loan proceeds to purchase securities or other investment products. Managed Accounts without a financial advisor. In the event that you request Ameriprise Financial Services to remove your current financial advisor from your Managed Account or your financial advisor resigns from Ameriprise Financial Services or your account, is terminated, or, for the SPS Advisor Program, your financial advisor is no longer able to act as your SPS Discretionary Advisor for any reason, the applicable investment advisory account(s) will no longer have an assigned financial advisor. Generally, investments in advisory accounts can only be purchased through an Ameriprise financial advisor. Advisor-to-advisor training programs. Ameriprise Financial Services or its affiliates may also pay its financial advisors for training other financial advisors on specific products and services that we offer. A portion of this payment may be based on incremental sales of these products and services sold by the financial advisor receiving the training. Ameriprise Financial Services may reassign your advisory account to another financial advisor and notify you of the change. If your Managed Account is reassigned to another financial advisor prior to its termination, your Account(s) will continue to be billed but the Wrap Fee rate may change based on the rate you negotiate with your new assigned financial advisor. We will attempt to notify you if your Managed Account is no longer assigned to a financial advisor. If you would like to retain your Account, contact us within the timeframe set out in the notification to have a financial advisor assigned. If the Account remains unassigned after the designated timeframe, it will transfer to an Ameriprise brokerage account in accordance with the applicable Managed Account Client Agreement. If your Managed Account does not have a financial advisor assigned to it and certain client directed trades are permitted, you may contact our Service Center at 1.800.862.7919 for assistance with a transaction. Shared compensation. Financial advisors may also choose to work together as a team to share fees and commissions generated from products and services you purchase. The cost of the product or service you purchase is not affected by the fact that your financial advisor is a member of a team or by the fact that the fee or commission may be split. Your financial advisor may be allowed to share a portion of the Wrap Fee he or she receives with one or more other Ameriprise financial advisor(s), including financial advisors who have not completed the Ameriprise Financial Services-required training to sell the investment advisory service, franchise consultants or registered principals, as described below. We will continue to collect and retain the full amount of any Asset-based Fees paid to us in connection with your Managed Account, less any fees paid to an applicable Advisory Service Provider, until the Account is designated for potential transfer to an Ameriprise brokerage account or terminated. This includes the portion of the Advisory Fee that would have been paid to a financial advisor if one was assigned to your Managed Account(s). The fees retained are used in part to pay other employees and for the technology that supports the services Ameriprise Financial Services provides to you. In cases where two or more financial advisors are assisting you, both financial advisors may share in the Wrap Fee. Your servicing financial advisor will present the Managed Account or AFPS, set the Wrap Fee, and oversee the analysis and advice prepared for you. Your servicing advisor may or may not be the financial advisor authorized to use discretion to purchase and sell securities in your account, e.g., your SPS Discretionary Advisor. In the instance that your servicing advisor is not authorized to use discretion, the financial advisor authorized to use discretion will oversee the analysis and advice prepared for you. Only the financial advisor authorized to use discretion will purchase and sell securities in our Account. Management compensation and bonus programs. Employee compensation and operating goals at all levels of the company are tied to the company’s success. All employees, directly or indirectly, may receive higher compensation and other benefits when the investment products of certain providers, particularly affiliates, are purchased. Management, sales leaders and other employees spend more of their time and resources promoting Ameriprise, Columbia Threadneedle Investments, and RiverSource branded products and services. Field leaders receive a salary and a bonus and are responsible for an operating budget for expenses. Bonus programs for Ameriprise Financial Services field leaders are designed to include an amount based on the aggregate sales of all products sold by financial advisors, including proprietary products, in the regions of the country those leaders are responsible for overseeing. The bonus incentive and expense programs present a potential conflict because they are based in part on sales of these products. Your servicing advisor may or may not be the financial advisor who has completed the required training. A financial advisor who has not completed the required training may refer a client to a financial advisor who has completed the required training for the service or product. The financial advisor who has completed the required training may pay a fee to the financial advisor who has not completed the required training for that referral. The financial advisor who has not completed the required training may provide investment advisory services for services and products that do not require training, however, only the financial advisor who has completed the required training required for a particular service or product will provide the analysis and advice prepared for you with respect to a service or product that requires the training. The financial advisor who has not completed the required training may receive a share of the commission from any services or products sold to you by your financial advisor who has completed the required training. Your financial advisor may work with a franchise consultant. In those situations, the franchise consultant, who is registered with Ameriprise Financial Services, may receive compensation based on services and products that you purchase, and for the training and leadership of your financial advisor. The cost of the product or service you purchase is not affected. Your financial advisor may employ staff or work with other Ameriprise Financial Services staff to assist with creating your financial planning recommendations. This may include leveraging services in geographic locations outside of your financial advisor’s location, including international locations. 33 34 Services provided may include entering data into financial planning software, proving initial calculation and assistance in creating solutions. Your financial advisor will provide final recommendations to you. For these services your financial advisor may pay a fee or salary to employed staff. Financial advisors and field leaders may share compensation with their registered support assistants or recommend bonuses for their non-registered support staff. Ameriprise Bank partners with Rocket Mortgage, LLC (NMLS#3030) that offers mortgage lending products and services. Ameriprise Financial Services and Ameriprise financial advisors do not accept any mortgage loan applications or offer or negotiate terms of any such loans. Financial advisors do not earn compensation related to the origination or referral of mortgage lending products offered and originated by such third-party providers. Ameriprise Bank may purchase and service some loans originated by Rocket Mortgage, LLC. Ameriprise Financial Services and Ameriprise financial advisors may receive compensation for assisting clients with mortgages serviced by Ameriprise Bank. Ameriprise Financial, Inc. is not affiliated with Rocket Mortgage, LLC. Ameriprise Bank does not guarantee products or services offered by Rocket Mortgage, LLC. Employee financial advisors and selling leaders may receive continuing commissions and fees for the sale of certain products and services for up to five years after leaving the securities industry. Ameriprise Bank has partnered with Elan Financial Services in offering Ameriprise co-branded credit cards. Your financial advisor receives compensation for marketing efforts that lead to your opening of a co-branded credit card account provided you activate the card and make sufficient purchases. Ameriprise offers a Business Development Account (BDA) Program. Eligible employee financial advisors may create a voluntary BDA in a predetermined amount and use this account for business-related expenses above and beyond what the company provides. Ameriprise Bank has partnered with Goldman Sachs to make available the Ameriprise Preferred Line of Credit and Loan. Ameriprise financial advisors will earn compensation for providing services related to your Ameriprise Preferred Line of Credit and Loan based on an annualized fixed percentage of the client’s average daily outstanding balance. Apart from margin lending offered by AEIS, neither your Ameriprise financial advisor nor Ameriprise Financial Services may arrange, promote, suggest or knowingly permit you to use line or loan proceeds to purchase securities or other investment products. Managed Accounts without a financial advisor. In the event that you request Ameriprise Financial Services to remove your current financial advisor from your Managed Account or your financial advisor resigns from Ameriprise Financial Services or your account, is terminated, or, for the SPS Advisor Program, your financial advisor is no longer able to act as your SPS Discretionary Advisor for any reason, the applicable investment advisory account(s) will no longer have an assigned financial advisor. Generally, investments in advisory accounts can only be purchased through an Ameriprise financial advisor. Advisor-to-advisor training programs. Ameriprise Financial Services or its affiliates may also pay its financial advisors for training other financial advisors on specific products and services that we offer. A portion of this payment may be based on incremental sales of these products and services sold by the financial advisor receiving the training. Ameriprise Financial Services may reassign your advisory account to another financial advisor and notify you of the change. If your Managed Account is reassigned to another financial advisor prior to its termination, your Account(s) will continue to be billed but the Wrap Fee rate may change based on the rate you negotiate with your new assigned financial advisor. We will attempt to notify you if your Managed Account is no longer assigned to a financial advisor. If you would like to retain your Account, contact us within the timeframe set out in the notification to have a financial advisor assigned. If the Account remains unassigned after the designated timeframe, it will transfer to an Ameriprise brokerage account in accordance with the applicable Managed Account Client Agreement. If your Managed Account does not have a financial advisor assigned to it and certain client directed trades are permitted, you may contact our Service Center at 1.800.862.7919 for assistance with a transaction. Shared compensation. Financial advisors may also choose to work together as a team to share fees and commissions generated from products and services you purchase. The cost of the product or service you purchase is not affected by the fact that your financial advisor is a member of a team or by the fact that the fee or commission may be split. Your financial advisor may be allowed to share a portion of the Wrap Fee he or she receives with one or more other Ameriprise financial advisor(s), including financial advisors who have not completed the Ameriprise Financial Services-required training to sell the investment advisory service, franchise consultants or registered principals, as described below. We will continue to collect and retain the full amount of any Asset-based Fees paid to us in connection with your Managed Account, less any fees paid to an applicable Advisory Service Provider, until the Account is designated for potential transfer to an Ameriprise brokerage account or terminated. This includes the portion of the Advisory Fee that would have been paid to a financial advisor if one was assigned to your Managed Account(s). The fees retained are used in part to pay other employees and for the technology that supports the services Ameriprise Financial Services provides to you. In cases where two or more financial advisors are assisting you, both financial advisors may share in the Wrap Fee. Your servicing financial advisor will present the Managed Account or AFPS, set the Wrap Fee, and oversee the analysis and advice prepared for you. Your servicing advisor may or may not be the financial advisor authorized to use discretion to purchase and sell securities in your account, e.g., your SPS Discretionary Advisor. In the instance that your servicing advisor is not authorized to use discretion, the financial advisor authorized to use discretion will oversee the analysis and advice prepared for you. Only the financial advisor authorized to use discretion will purchase and sell securities in our Account. Management compensation and bonus programs. Employee compensation and operating goals at all levels of the company are tied to the company’s success. All employees, directly or indirectly, may receive higher compensation and other benefits when the investment products of certain providers, particularly affiliates, are purchased. Management, sales leaders and other employees spend more of their time and resources promoting Ameriprise, Columbia Threadneedle Investments, and RiverSource branded products and services. Field leaders receive a salary and a bonus and are responsible for an operating budget for expenses. Bonus programs for Ameriprise Financial Services field leaders are designed to include an amount based on the aggregate sales of all products sold by financial advisors, including proprietary products, in the regions of the country those leaders are responsible for overseeing. The bonus incentive and expense programs present a potential conflict because they are based in part on sales of these products. Your servicing advisor may or may not be the financial advisor who has completed the required training. A financial advisor who has not completed the required training may refer a client to a financial advisor who has completed the required training for the service or product. The financial advisor who has completed the required training may pay a fee to the financial advisor who has not completed the required training for that referral. The financial advisor who has not completed the required training may provide investment advisory services for services and products that do not require training, however, only the financial advisor who has completed the required training required for a particular service or product will provide the analysis and advice prepared for you with respect to a service or product that requires the training. The financial advisor who has not completed the required training may receive a share of the commission from any services or products sold to you by your financial advisor who has completed the required training. Your financial advisor may work with a franchise consultant. In those situations, the franchise consultant, who is registered with Ameriprise Financial Services, may receive compensation based on services and products that you purchase, and for the training and leadership of your financial advisor. The cost of the product or service you purchase is not affected. Your financial advisor may employ staff or work with other Ameriprise Financial Services staff to assist with creating your financial planning recommendations. This may include leveraging services in geographic locations outside of your financial advisor’s location, including international locations. 33 34 benefit of, their clients when following policies and procedures designed to comply with law. Ameriprise Financial Services and its affiliates have adopted an “Insider Trading Policy” in accordance with Section 204A of the Advisers Act that establishes procedures to prevent the misuse of material nonpublic information by Ameriprise Financial Services and its associated persons. Code of Ethics, Participation or Interest in Transactions and Personal Trading Code of ethics Brokerage Practices Ameriprise Financial Services does not receive research or other products or services other than execution from any unaffiliated broker-dealer or other third party for client securities transactions. Ameriprise Financial Services receives and distributes research authored by its affiliate AEIS; however, this research is not provided for client securities transactions or for any other compensation. Nor do we or our affiliates receive client referrals from broker-dealers or third parties that are considered in selecting or recommending broker-dealers. As part of an overall internal compliance program, Ameriprise Financial Services has adopted policies and procedures imposing certain conditions and restrictions on transactions for the account of Ameriprise Financial Services and the accounts of our employees. Such policies and procedures are designed to prevent, among other things, any improper or abusive conduct when potential conflicts of interest may exist with respect to a customer or client. In addition, from time to time, restrictions are imposed to address the potential for self-dealing and conflict of interest which may arise in connection with the business of Ameriprise Financial Services as a broker- dealer. Ameriprise Financial Services has adopted various procedures to guard against insider trading. Participation or interest in client transactions Retail brokerage services are made available through Ameriprise Financial Services. Ameriprise Financial Services and AEIS have an agreement in which Ameriprise Financial Services introduces customer accounts to AEIS on a fully disclosed basis. AEIS serves as Ameriprise Financial Services’ clearing agent in providing, clearing, custody and settlement services for transactions that are executed for customers of Ameriprise Financial Services. Ameriprise Financial Services approves and opens accounts and accepts securities order instructions with respect to the accounts. In exchange for a fee paid by Ameriprise Financial Services, AEIS provides record keeping, custody, and all clearing functions for accounts introduced by Ameriprise Financial Services. Ameriprise Financial Services and/or its affiliates and related persons may invest in the same or related securities that Ameriprise Financial Services and/or its affiliates recommend to clients. Such transactions may occur at or about the same time that such securities are bought or sold for client accounts. Ameriprise Financial Services has adopted policies and procedures imposing certain conditions and restrictions on transactions in these securities, such as trading blackout periods and preclearance requirements. Under certain circumstances, when AEIS deems a transaction to be in the best interests of you and other clients, and to the extent permitted by applicable law and regulation, AEIS is permitted to aggregate multiple client orders to obtain what AEIS believes will be the most favorable price and/or lower execution costs at the time of execution. See the “Financial interest in products” subsection in the “Revenue Sources for Ameriprise Financial Services, LLC” section in this Disclosure Brochure for more information about our financial interest in the sale of certain products and services. Personal trading rules and procedures Review of Accounts Certain supervisory functions are performed by Ameriprise Financial Services corporate office personnel. Corporate registered principals review a sampling of financial advisor’s financial planning relationships, including written financial planning recommendations periodically based on certain key factors. When appropriate, our corporate registered principals may also decide to call you directly to discuss your understanding of AFPS and any related Managed Account(s), including the fees and expenses you will be paying. Our Compliance department also conducts routine surveillance of financial advisor activities. Ameriprise Financial Services has adopted personal trading rules and procedures within the Ameriprise Financial Code of Ethics and Personal Trading Policy. These rules are designed to list standards of business conduct and to mitigate potential conflicts of interest for all persons of Ameriprise Financial Services when they engage in personal securities transactions. You may request a copy of the Ameriprise Financial Code of Ethics and Personal Trading Policy from your financial advisor or by contacting us at 800.290.6663. If you are in a financial planning relationship, including the consolidated advisory fee arrangement, you will receive written reports relating to your financial planning goals from your financial advisor at least annually. An important part of an AFPS engagement involves providing you with the opportunity to engage in periodic reviews with your financial advisor or a designated member of the team servicing your AFPS. In these reviews, you and your financial advisor should discuss any changes to your individual circumstances, financial situations, investment objectives and/or risk tolerance. The standards of business conduct include compliance with applicable laws and regulations and with policies and procedures such as those contained in the Ameriprise Global Code of Conduct. Under the personal trading rules, persons are required to report their personal securities holdings and transactions, including transactions in certain mutual funds; must pre-clear certain investments; are restricted with respect to the timing of certain investments; and are prohibited from making certain investments. In addition, the Personal Trading Policy requires (i) Ameriprise employee financial advisors and their employees, (ii) its independent contractor franchisee financial advisors and their employees, and (iii) its affiliated investment advisers to conduct most personal trades through one of three designated broker-dealers unless an exception has been granted, and to report any changes in their selected broker-dealer. Our supervision and surveillance do not substitute for your continued review and monitoring of your AFPS or any related Managed Account(s). You should review your account statements, trade confirmations, and other information we send to you. If you have any questions, please discuss them with your financial advisor. Insider trading policy Client Referrals and Other Compensation Ameriprise Financial Services and its related persons may, from time to time, come into possession of material nonpublic information that, if disclosed, might affect an investor’s decision to buy, sell or hold a security. Referral arrangements and other economic benefits Ameriprise Financial Services maintains formal and informal arrangements, the terms of which are disclosed to the client, with individual professionals, professional firms, and select corporate, institutional or membership organizations (“Promoters”). For each such arrangement, Ameriprise Financial Services pays the Promoter for referral of their clients or members to Ameriprise Financial Services for its financial advisory services. The manner Under applicable law, Ameriprise Financial Services and its related persons are prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether such other person is a client. Accordingly, should Ameriprise Financial Services or its related persons come into possession of material nonpublic information with respect to any company, they may be prohibited from communicating such information to, or using such information for the benefit of, their respective clients, and have no obligation or responsibility to disclose such information to, nor responsibility to use such information for the 35 36 benefit of, their clients when following policies and procedures designed to comply with law. Ameriprise Financial Services and its affiliates have adopted an “Insider Trading Policy” in accordance with Section 204A of the Advisers Act that establishes procedures to prevent the misuse of material nonpublic information by Ameriprise Financial Services and its associated persons. Code of Ethics, Participation or Interest in Transactions and Personal Trading Code of ethics Brokerage Practices Ameriprise Financial Services does not receive research or other products or services other than execution from any unaffiliated broker-dealer or other third party for client securities transactions. Ameriprise Financial Services receives and distributes research authored by its affiliate AEIS; however, this research is not provided for client securities transactions or for any other compensation. Nor do we or our affiliates receive client referrals from broker-dealers or third parties that are considered in selecting or recommending broker-dealers. As part of an overall internal compliance program, Ameriprise Financial Services has adopted policies and procedures imposing certain conditions and restrictions on transactions for the account of Ameriprise Financial Services and the accounts of our employees. Such policies and procedures are designed to prevent, among other things, any improper or abusive conduct when potential conflicts of interest may exist with respect to a customer or client. In addition, from time to time, restrictions are imposed to address the potential for self-dealing and conflict of interest which may arise in connection with the business of Ameriprise Financial Services as a broker- dealer. Ameriprise Financial Services has adopted various procedures to guard against insider trading. Participation or interest in client transactions Retail brokerage services are made available through Ameriprise Financial Services. Ameriprise Financial Services and AEIS have an agreement in which Ameriprise Financial Services introduces customer accounts to AEIS on a fully disclosed basis. AEIS serves as Ameriprise Financial Services’ clearing agent in providing, clearing, custody and settlement services for transactions that are executed for customers of Ameriprise Financial Services. Ameriprise Financial Services approves and opens accounts and accepts securities order instructions with respect to the accounts. In exchange for a fee paid by Ameriprise Financial Services, AEIS provides record keeping, custody, and all clearing functions for accounts introduced by Ameriprise Financial Services. Ameriprise Financial Services and/or its affiliates and related persons may invest in the same or related securities that Ameriprise Financial Services and/or its affiliates recommend to clients. Such transactions may occur at or about the same time that such securities are bought or sold for client accounts. Ameriprise Financial Services has adopted policies and procedures imposing certain conditions and restrictions on transactions in these securities, such as trading blackout periods and preclearance requirements. Under certain circumstances, when AEIS deems a transaction to be in the best interests of you and other clients, and to the extent permitted by applicable law and regulation, AEIS is permitted to aggregate multiple client orders to obtain what AEIS believes will be the most favorable price and/or lower execution costs at the time of execution. See the “Financial interest in products” subsection in the “Revenue Sources for Ameriprise Financial Services, LLC” section in this Disclosure Brochure for more information about our financial interest in the sale of certain products and services. Personal trading rules and procedures Review of Accounts Certain supervisory functions are performed by Ameriprise Financial Services corporate office personnel. Corporate registered principals review a sampling of financial advisor’s financial planning relationships, including written financial planning recommendations periodically based on certain key factors. When appropriate, our corporate registered principals may also decide to call you directly to discuss your understanding of AFPS and any related Managed Account(s), including the fees and expenses you will be paying. Our Compliance department also conducts routine surveillance of financial advisor activities. Ameriprise Financial Services has adopted personal trading rules and procedures within the Ameriprise Financial Code of Ethics and Personal Trading Policy. These rules are designed to list standards of business conduct and to mitigate potential conflicts of interest for all persons of Ameriprise Financial Services when they engage in personal securities transactions. You may request a copy of the Ameriprise Financial Code of Ethics and Personal Trading Policy from your financial advisor or by contacting us at 800.290.6663. If you are in a financial planning relationship, including the consolidated advisory fee arrangement, you will receive written reports relating to your financial planning goals from your financial advisor at least annually. An important part of an AFPS engagement involves providing you with the opportunity to engage in periodic reviews with your financial advisor or a designated member of the team servicing your AFPS. In these reviews, you and your financial advisor should discuss any changes to your individual circumstances, financial situations, investment objectives and/or risk tolerance. The standards of business conduct include compliance with applicable laws and regulations and with policies and procedures such as those contained in the Ameriprise Global Code of Conduct. Under the personal trading rules, persons are required to report their personal securities holdings and transactions, including transactions in certain mutual funds; must pre-clear certain investments; are restricted with respect to the timing of certain investments; and are prohibited from making certain investments. In addition, the Personal Trading Policy requires (i) Ameriprise employee financial advisors and their employees, (ii) its independent contractor franchisee financial advisors and their employees, and (iii) its affiliated investment advisers to conduct most personal trades through one of three designated broker-dealers unless an exception has been granted, and to report any changes in their selected broker-dealer. Our supervision and surveillance do not substitute for your continued review and monitoring of your AFPS or any related Managed Account(s). You should review your account statements, trade confirmations, and other information we send to you. If you have any questions, please discuss them with your financial advisor. Insider trading policy Client Referrals and Other Compensation Ameriprise Financial Services and its related persons may, from time to time, come into possession of material nonpublic information that, if disclosed, might affect an investor’s decision to buy, sell or hold a security. Referral arrangements and other economic benefits Ameriprise Financial Services maintains formal and informal arrangements, the terms of which are disclosed to the client, with individual professionals, professional firms, and select corporate, institutional or membership organizations (“Promoters”). For each such arrangement, Ameriprise Financial Services pays the Promoter for referral of their clients or members to Ameriprise Financial Services for its financial advisory services. The manner Under applicable law, Ameriprise Financial Services and its related persons are prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether such other person is a client. Accordingly, should Ameriprise Financial Services or its related persons come into possession of material nonpublic information with respect to any company, they may be prohibited from communicating such information to, or using such information for the benefit of, their respective clients, and have no obligation or responsibility to disclose such information to, nor responsibility to use such information for the 35 36 Revenue sources for RiverSource Sales charges. You pay sales and other charges under RiverSource variable annuity contracts and life insurance policies. You may incur transaction costs or fees associated with structured annuities. You may pay a contingent deferred sales charge, or surrender charge, if you withdraw funds during the applicable period. and amount of compensation to be paid in connection with these agreements is subject to negotiation between Ameriprise Financial Services and the applicable Promoter. Prospective clients are provided with the applicable disclosures, including whether the Promoter is a client, the material terms of compensation (if any) and the material conflicts of interest (if any), that results from the Promotor’s relationship with Ameriprise Financial Services. The most common compensation arrangements include a flat fee at the time of the referral, a recurring flat fee, or a sharing of a portion of any total Asset-based Fees. You will not be charged an additional fee as a result of any referral arrangements. Compensation may include a one-time payment or ongoing payments for the duration of the investment advisory relationship. Periodic fees and expenses. You pay certain fees and expenses under RiverSource annuity contracts, life insurance policies and disability income insurance policies, including (depending on the type of contract or policy) mortality and expense, administrative, policy, contract, and cost of insurance fees or charges, in addition to costs associated with certain riders that may be available for both fixed, structured and variable products. Periodic expenses are also paid from product assets, such as 12b-1 fees paid on certain funds that serve as underlying investment options for variable annuities and variable life insurance. 12b-1 fees may be used to pay for marketing, distribution and shareholder service expenses. Investment and interest income. Investment and interest income from insurance company general account assets derived, in part, from the amounts you pay for insurance and annuity benefits. Ameriprise Financial Services may form alliances and networking arrangements with financial institutions such as community banks, credit unions, credit union service organizations, Farm Credit Services and trust service providers (“Third-Party Financial Institutions”) to allow its financial advisors to offer investment advisory services, financial planning services and certain other non-deposit investment and insurance products and services, (described elsewhere in this Brochure), to retail customers or members of the Third Party Financial Institutions. Under the terms of these alliances or networking arrangements, financial advisors may not be able to offer to retail customers or members of the Third-Party Financial Institutions certain products that are otherwise available through Ameriprise Financial Services or its affiliates. Also because of these alliances or networking arrangements, Third-Party Financial Institutions may receive, in the form of a networking payment, a portion of Asset-based Fees and securities and insurance commissions paid to financial advisors for sales to retail customers or members of the Third-Party Financial Institutions. Variable annuity and variable life insurance financial arrangements. RiverSource selects the funds available within your variable annuity contract or variable life insurance policy. In doing so, RiverSource may consider various objective and subjective factors. These factors include compensation RiverSource may receive from fund assets (for those funds with 12b-1 plans); assets of the fund’s adviser, sub-adviser or an affiliate of either; and assets of the fund’s distributor or an affiliate. This compensation benefits RiverSource. Ameriprise Financial Services has entered in partnership with Renaissance Charitable Foundation Inc. (“RCF”) for the referral of clients or prospects that have indicated an interest in establishing and maintaining a donor advised fund made available through RCF. No referral fee is paid by RCF to Ameriprise Financial Services or financial advisors however donor advised funds established by RCF because of the referral generally invest in eligible Managed Account Programs that are advised and serviced by the referring financial advisor. The administration fee that you pay RCF for a donor advised fund solution may be more or less than if you were to purchase the donor advised fund services from RCF or another non-profit organization. Any fees charged by RCF for the administration of the donor advised fund are not shared with Ameriprise Financial Services or financial advisors. The amount of this revenue varies by fund, may be significant and may create potential conflicts of interest for RiverSource. The greatest amount and percentage of revenue that RiverSource receives comes from assets allocated to subaccounts investing in funds managed by its affiliates, CMIA, and Columbia Wanger Asset Management. In general, the revenue directly related to assets under management that RiverSource receives currently ranges up to 0.65% of the average daily net assets invested in the underlying funds through the variable annuity or variable life insurance contracts RiverSource issues. This revenue is in addition to revenues RiverSource receives from the charges you pay when buying, owning or surrendering your variable annuity contract or life insurance policy. In accordance with applicable laws, regulations and the terms of the agreements under which such revenue is paid, RiverSource may receive this compensation for various purposes including financial advisor training and compensation, marketing and distribution, customer servicing, transaction processing, record keeping, and other administrative services. Revenue sources for Columbia Management and Threadneedle Ameriprise Financial Service and your financial advisor will receive Asset-based Fee revenue from a donor advised fund established by RCF and invested in a Managed Account Program and no revenue if donor advised fund assets are invested with a third-party investment adviser, whether through RCF or another non-profit organization. We seek to address this conflict of interest through a combination of disclosure and through our policies, procedures and supervision related to the determination that a referral to RCF is appropriate for you based on your Client Information, and by treating assets in Managed Accounts owned and administered by RCF and assets in Managed Accounts owned directly by you as separate and distinct advisory relationships in accordance with all applicable regulatory requirements. Periodic fees and expenses. Columbia Management and Threadneedle International Limited may receive management fees and certificate advisory and services fees for services, including, with respect to Columbia Management. These revenues may be received from the Columbia Funds, Columbia ETFs, Columbia closed-end funds, Ameriprise certificates and from other affiliated and nonaffiliated advisory clients of Columbia Management and Threadneedle International Limited. Review of issuers of financial products Revenue sources for other Ameriprise Financial, Inc. companies There are several of other Ameriprise Financial, Inc. companies that will receive revenue from the charges and fees you pay, including the following: • Ameriprise Certificate Company receives investment spread income earned on, and any early withdrawal penalty related to, Ameriprise certificates. • Columbia Management Investment Services Corp. receives certain fees and expenses paid from the Columbia Funds and Ameriprise certificates in exchange for the transfer agent services it provides. • American Enterprise Investment Services Inc. is compensated for its services through the brokerage Ameriprise Financial Services and its affiliates have policies and procedures in place to review the issuers of financial products such as alternative investments in non-traded REITs, non-traded BDCs and non-traded CEFs, structured notes, and annuity and insurance products that Ameriprise Financial Services permits its financial advisors to offer to some or all of its clients. This review includes publicly available information and reports issued by third parties and may in some cases include certain nonpublic information provided by the issuer. Ameriprise Financial Services periodically reassesses, but does not continuously monitor, the creditworthiness or financial solvency of third-party issuers. These policies and procedures are reasonably designed to mitigate our clients’ exposure to credit and default risks resulting from an inability of the issuer to repay the principal on a note or fulfill an insurance obligation. However, you should be advised that credit markets can be volatile and the creditworthiness of an issuer may change rapidly. Ameriprise Financial Services, as a seller of these products, is prohibited by regulation from guaranteeing or providing any assurance that an issuer of financial products will be able to fulfill the issuer’s obligation to any purchaser of such a product through Ameriprise Financial Services. commission and other fees charged for each brokerage transaction, which may include transactions made in a Bank trust account, or through the brokerage commission which is included in the overall asset-based fee, depending on the account option you select. 37 38 Revenue sources for RiverSource Sales charges. You pay sales and other charges under RiverSource variable annuity contracts and life insurance policies. You may incur transaction costs or fees associated with structured annuities. You may pay a contingent deferred sales charge, or surrender charge, if you withdraw funds during the applicable period. and amount of compensation to be paid in connection with these agreements is subject to negotiation between Ameriprise Financial Services and the applicable Promoter. Prospective clients are provided with the applicable disclosures, including whether the Promoter is a client, the material terms of compensation (if any) and the material conflicts of interest (if any), that results from the Promotor’s relationship with Ameriprise Financial Services. The most common compensation arrangements include a flat fee at the time of the referral, a recurring flat fee, or a sharing of a portion of any total Asset-based Fees. You will not be charged an additional fee as a result of any referral arrangements. Compensation may include a one-time payment or ongoing payments for the duration of the investment advisory relationship. Periodic fees and expenses. You pay certain fees and expenses under RiverSource annuity contracts, life insurance policies and disability income insurance policies, including (depending on the type of contract or policy) mortality and expense, administrative, policy, contract, and cost of insurance fees or charges, in addition to costs associated with certain riders that may be available for both fixed, structured and variable products. Periodic expenses are also paid from product assets, such as 12b-1 fees paid on certain funds that serve as underlying investment options for variable annuities and variable life insurance. 12b-1 fees may be used to pay for marketing, distribution and shareholder service expenses. Investment and interest income. Investment and interest income from insurance company general account assets derived, in part, from the amounts you pay for insurance and annuity benefits. Ameriprise Financial Services may form alliances and networking arrangements with financial institutions such as community banks, credit unions, credit union service organizations, Farm Credit Services and trust service providers (“Third-Party Financial Institutions”) to allow its financial advisors to offer investment advisory services, financial planning services and certain other non-deposit investment and insurance products and services, (described elsewhere in this Brochure), to retail customers or members of the Third Party Financial Institutions. Under the terms of these alliances or networking arrangements, financial advisors may not be able to offer to retail customers or members of the Third-Party Financial Institutions certain products that are otherwise available through Ameriprise Financial Services or its affiliates. Also because of these alliances or networking arrangements, Third-Party Financial Institutions may receive, in the form of a networking payment, a portion of Asset-based Fees and securities and insurance commissions paid to financial advisors for sales to retail customers or members of the Third-Party Financial Institutions. Variable annuity and variable life insurance financial arrangements. RiverSource selects the funds available within your variable annuity contract or variable life insurance policy. In doing so, RiverSource may consider various objective and subjective factors. These factors include compensation RiverSource may receive from fund assets (for those funds with 12b-1 plans); assets of the fund’s adviser, sub-adviser or an affiliate of either; and assets of the fund’s distributor or an affiliate. This compensation benefits RiverSource. Ameriprise Financial Services has entered in partnership with Renaissance Charitable Foundation Inc. (“RCF”) for the referral of clients or prospects that have indicated an interest in establishing and maintaining a donor advised fund made available through RCF. No referral fee is paid by RCF to Ameriprise Financial Services or financial advisors however donor advised funds established by RCF because of the referral generally invest in eligible Managed Account Programs that are advised and serviced by the referring financial advisor. The administration fee that you pay RCF for a donor advised fund solution may be more or less than if you were to purchase the donor advised fund services from RCF or another non-profit organization. Any fees charged by RCF for the administration of the donor advised fund are not shared with Ameriprise Financial Services or financial advisors. The amount of this revenue varies by fund, may be significant and may create potential conflicts of interest for RiverSource. The greatest amount and percentage of revenue that RiverSource receives comes from assets allocated to subaccounts investing in funds managed by its affiliates, CMIA, and Columbia Wanger Asset Management. In general, the revenue directly related to assets under management that RiverSource receives currently ranges up to 0.65% of the average daily net assets invested in the underlying funds through the variable annuity or variable life insurance contracts RiverSource issues. This revenue is in addition to revenues RiverSource receives from the charges you pay when buying, owning or surrendering your variable annuity contract or life insurance policy. In accordance with applicable laws, regulations and the terms of the agreements under which such revenue is paid, RiverSource may receive this compensation for various purposes including financial advisor training and compensation, marketing and distribution, customer servicing, transaction processing, record keeping, and other administrative services. Revenue sources for Columbia Management and Threadneedle Ameriprise Financial Service and your financial advisor will receive Asset-based Fee revenue from a donor advised fund established by RCF and invested in a Managed Account Program and no revenue if donor advised fund assets are invested with a third-party investment adviser, whether through RCF or another non-profit organization. We seek to address this conflict of interest through a combination of disclosure and through our policies, procedures and supervision related to the determination that a referral to RCF is appropriate for you based on your Client Information, and by treating assets in Managed Accounts owned and administered by RCF and assets in Managed Accounts owned directly by you as separate and distinct advisory relationships in accordance with all applicable regulatory requirements. Periodic fees and expenses. Columbia Management and Threadneedle International Limited may receive management fees and certificate advisory and services fees for services, including, with respect to Columbia Management. These revenues may be received from the Columbia Funds, Columbia ETFs, Columbia closed-end funds, Ameriprise certificates and from other affiliated and nonaffiliated advisory clients of Columbia Management and Threadneedle International Limited. Review of issuers of financial products Revenue sources for other Ameriprise Financial, Inc. companies There are several of other Ameriprise Financial, Inc. companies that will receive revenue from the charges and fees you pay, including the following: • Ameriprise Certificate Company receives investment spread income earned on, and any early withdrawal penalty related to, Ameriprise certificates. • Columbia Management Investment Services Corp. receives certain fees and expenses paid from the Columbia Funds and Ameriprise certificates in exchange for the transfer agent services it provides. • American Enterprise Investment Services Inc. is compensated for its services through the brokerage Ameriprise Financial Services and its affiliates have policies and procedures in place to review the issuers of financial products such as alternative investments in non-traded REITs, non-traded BDCs and non-traded CEFs, structured notes, and annuity and insurance products that Ameriprise Financial Services permits its financial advisors to offer to some or all of its clients. This review includes publicly available information and reports issued by third parties and may in some cases include certain nonpublic information provided by the issuer. Ameriprise Financial Services periodically reassesses, but does not continuously monitor, the creditworthiness or financial solvency of third-party issuers. These policies and procedures are reasonably designed to mitigate our clients’ exposure to credit and default risks resulting from an inability of the issuer to repay the principal on a note or fulfill an insurance obligation. However, you should be advised that credit markets can be volatile and the creditworthiness of an issuer may change rapidly. Ameriprise Financial Services, as a seller of these products, is prohibited by regulation from guaranteeing or providing any assurance that an issuer of financial products will be able to fulfill the issuer’s obligation to any purchaser of such a product through Ameriprise Financial Services. commission and other fees charged for each brokerage transaction, which may include transactions made in a Bank trust account, or through the brokerage commission which is included in the overall asset-based fee, depending on the account option you select. 37 38 • If the Sweep Program for your Account is AIMMA, AEIS receives compensation from the Program Banks based on the cash balance in the AIMMA program. If your account sweeps uninvested cash to ABISA or to Ameriprise Bank as the Program Bank in the AIMMA program, Ameriprise Bank does not compensate AEIS, but reimburses AEIS for its direct out-of-pocket expenses related to the sweep services provided. • AEIS receives compensation in the form of interest charged on your margin account balance as well as from order handling fees. In transaction-based brokerage accounts, AEIS may also engage in principal trading of certain types of fixed income securities for brokerage accounts—that is, it may buy and sell these securities for its own account with the objective of making a profit in certain circumstances, AEIS may buy these securities from you or sell these securities to you on a principal basis, in which case you will pay a markup or markdown on the transaction. • AEIS performs, for the benefit of Ameriprise Financial Services, its financial advisors and clients, cost Custody Ameriprise Financial Services does not maintain custody of client funds or securities or take possession of any assets in any Managed Account. AEIS, one of our broker-dealer affiliates, provides custody and safekeeping services for Managed Account assets and will ordinarily act as the custodian for all assets held in a Managed Account. Because our affiliate maintains custody of our clients’ assets, we are required by SEC rules and regulations to obtain from AEIS at least annually a written internal control report (the “ICR”) prepared by a qualified independent public accountant, and AEIS is required to undergo an independent verification of the assets under its control. The ICR that we receive from AEIS is intended to show that our affiliate has established appropriate custodial controls with respect to client assets under custody. For Retirement Accounts where Ameriprise Trust Company (“ATC”) acts as custodian or trustee, AEIS shall act as an agent or sub-custodian of ATC with respect to custody of assets. reimbursement and marketing support services as described in the “Cost Reimbursement and Marketing Support” section. In recognition of the above, Ameriprise Financial Services will compensate AEIS for these services performed by AEIS. Investment Discretion Your Ameriprise financial advisor does not manage your securities or other investments on your behalf as part of AFPS. However, your financial advisor may offer a discretionary investment advisory service separately as part of our SPS Advisor Program. • The capacity in which AEIS acts in any particular transaction is disclosed on each transaction confirmation you receive. AEIS is also compensated for the shareholder services it provides for certain mutual fund companies. These services include but are not limited to delivering shareholder communications such as updated prospectuses and statements of additional information, transaction confirmations and annual tax reporting, and monitoring compliance with share class, discounted sales charge, market timing and other mutual fund company policies. • Ameriprise Financial, Inc. receives fees paid from Columbia and the Columbia Funds and Ameriprise Voting Client Securities Ameriprise Financial Services does not offer proxy voting services with respect to AFPS. certificates in exchange for the administrative services it provides. • Columbia Management Investment Distributors receives fees paid from the Columbia Funds (other than the Columbia ETFs and Columbia publicly traded closed-end funds) in exchange for the distribution services it provides. Ameriprise Financial Services has a financial interest in the sale of Columbia Funds, Ameriprise certificates and RiverSource products and certain other mutual funds. • Ameriprise Financial Services sells annuity and insurance products manufactured by its RiverSource affiliates, as well as products from unaffiliated providers. RiverSource is permitted to reimburse Ameriprise Financial Services for client/prospect education events and advisor sales meetings, seminars, and training events pertaining to annuity and insurance products, consistent with Ameriprise Financial Services policies and industry regulation. Ameriprise Financial Services and your financial advisor do not take any action or give advice regarding the voting of proxies solicited by or with respect to the issuers of securities in which assets of your Ameriprise brokerage account(s) or Managed Account(s) may be invested, except for certain Select Separate Accounts where you delegate proxy voting authority to Ameriprise Financial Services. For all other Managed Account Programs, Ameriprise Financial Services and your financial advisor do not take any action or give any advice regarding the voting of proxies solicited by or with respect to the issuers of securities in which assets of your managed account(s) may be invested. Ameriprise Financial Services will forward to you or your designated agent all proxy solicitations and materials related to other corporate actions that are received by Ameriprise Financial Services with respect to assets in your managed account(s). You are responsible for voting proxies and effectuating other corporate actions relating to the securities held in your respective managed account(s). • Ameriprise Financial Services may also receive nominal noncash benefits from time to time. Unaffiliated annuity and insurance providers may not provide some services, or the same level of services, to Ameriprise financial advisors. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource annuity and insurance products. For certain discretionary managed account services (Signature Wealth, Active Portfolios®, Select Separate Account, including Select Strategist UMA, Vista Separate Account, Investor Unified Account and Access Account Programs), you have the right to vote proxies on the securities in which your account assets may be invested from time to time, or you may delegate the authority to vote these proxies to the applicable Investment Manager for your managed account. You may alternatively delegate the authority to vote proxies on your behalf to another person. • Ameriprise Bank charges fees, depending on the terms of trust documentation and applicable state laws governing trust administration, for its administrative trust services that are separate from investment management fees charged by financial advisors and are not shared with Ameriprise Financial Services. Neither Ameriprise Financial Services, your financial advisor nor any Advisory Service Provider are responsible for any other corporate actions relating to the assets in your managed account(s) including administrative filings such as proofs of claims related to bankruptcy or claims in class actions. When Ameriprise Bank is a Program Bank in the AIMMA program or ABISA is the Sweep Option, Ameriprise Bank earns income by lending or investing the deposits it receives and charging a higher interest rate to borrowers, or earning a higher yield, than it pays on the deposits held through these sweep programs. The difference is known as the "spread." • Ameriprise Bank earns revenue based on the amount of credit extended and the interest rate on the Ameriprise Preferred Line of Credit and Loan. Ameriprise Financial Services’ proxy voting policies and procedures When Ameriprise Financial Services has proxy voting authority for applicable Select Separate Accounts, Ameriprise Financial Services will apply the following general principles to meet its proxy voting responsibilities: • Seek to ensure that proxies are voted in the best economic interest of clients; • Address material conflicts of interest that may arise; and • Comply with disclosure and other requirements as required by law. 39 40 • If the Sweep Program for your Account is AIMMA, AEIS receives compensation from the Program Banks based on the cash balance in the AIMMA program. If your account sweeps uninvested cash to ABISA or to Ameriprise Bank as the Program Bank in the AIMMA program, Ameriprise Bank does not compensate AEIS, but reimburses AEIS for its direct out-of-pocket expenses related to the sweep services provided. • AEIS receives compensation in the form of interest charged on your margin account balance as well as from order handling fees. In transaction-based brokerage accounts, AEIS may also engage in principal trading of certain types of fixed income securities for brokerage accounts—that is, it may buy and sell these securities for its own account with the objective of making a profit in certain circumstances, AEIS may buy these securities from you or sell these securities to you on a principal basis, in which case you will pay a markup or markdown on the transaction. • AEIS performs, for the benefit of Ameriprise Financial Services, its financial advisors and clients, cost Custody Ameriprise Financial Services does not maintain custody of client funds or securities or take possession of any assets in any Managed Account. AEIS, one of our broker-dealer affiliates, provides custody and safekeeping services for Managed Account assets and will ordinarily act as the custodian for all assets held in a Managed Account. Because our affiliate maintains custody of our clients’ assets, we are required by SEC rules and regulations to obtain from AEIS at least annually a written internal control report (the “ICR”) prepared by a qualified independent public accountant, and AEIS is required to undergo an independent verification of the assets under its control. The ICR that we receive from AEIS is intended to show that our affiliate has established appropriate custodial controls with respect to client assets under custody. For Retirement Accounts where Ameriprise Trust Company (“ATC”) acts as custodian or trustee, AEIS shall act as an agent or sub-custodian of ATC with respect to custody of assets. reimbursement and marketing support services as described in the “Cost Reimbursement and Marketing Support” section. In recognition of the above, Ameriprise Financial Services will compensate AEIS for these services performed by AEIS. Investment Discretion Your Ameriprise financial advisor does not manage your securities or other investments on your behalf as part of AFPS. However, your financial advisor may offer a discretionary investment advisory service separately as part of our SPS Advisor Program. • The capacity in which AEIS acts in any particular transaction is disclosed on each transaction confirmation you receive. AEIS is also compensated for the shareholder services it provides for certain mutual fund companies. These services include but are not limited to delivering shareholder communications such as updated prospectuses and statements of additional information, transaction confirmations and annual tax reporting, and monitoring compliance with share class, discounted sales charge, market timing and other mutual fund company policies. • Ameriprise Financial, Inc. receives fees paid from Columbia and the Columbia Funds and Ameriprise Voting Client Securities Ameriprise Financial Services does not offer proxy voting services with respect to AFPS. certificates in exchange for the administrative services it provides. • Columbia Management Investment Distributors receives fees paid from the Columbia Funds (other than the Columbia ETFs and Columbia publicly traded closed-end funds) in exchange for the distribution services it provides. Ameriprise Financial Services has a financial interest in the sale of Columbia Funds, Ameriprise certificates and RiverSource products and certain other mutual funds. • Ameriprise Financial Services sells annuity and insurance products manufactured by its RiverSource affiliates, as well as products from unaffiliated providers. RiverSource is permitted to reimburse Ameriprise Financial Services for client/prospect education events and advisor sales meetings, seminars, and training events pertaining to annuity and insurance products, consistent with Ameriprise Financial Services policies and industry regulation. Ameriprise Financial Services and your financial advisor do not take any action or give advice regarding the voting of proxies solicited by or with respect to the issuers of securities in which assets of your Ameriprise brokerage account(s) or Managed Account(s) may be invested, except for certain Select Separate Accounts where you delegate proxy voting authority to Ameriprise Financial Services. For all other Managed Account Programs, Ameriprise Financial Services and your financial advisor do not take any action or give any advice regarding the voting of proxies solicited by or with respect to the issuers of securities in which assets of your managed account(s) may be invested. Ameriprise Financial Services will forward to you or your designated agent all proxy solicitations and materials related to other corporate actions that are received by Ameriprise Financial Services with respect to assets in your managed account(s). You are responsible for voting proxies and effectuating other corporate actions relating to the securities held in your respective managed account(s). • Ameriprise Financial Services may also receive nominal noncash benefits from time to time. Unaffiliated annuity and insurance providers may not provide some services, or the same level of services, to Ameriprise financial advisors. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource annuity and insurance products. For certain discretionary managed account services (Signature Wealth, Active Portfolios®, Select Separate Account, including Select Strategist UMA, Vista Separate Account, Investor Unified Account and Access Account Programs), you have the right to vote proxies on the securities in which your account assets may be invested from time to time, or you may delegate the authority to vote these proxies to the applicable Investment Manager for your managed account. You may alternatively delegate the authority to vote proxies on your behalf to another person. • Ameriprise Bank charges fees, depending on the terms of trust documentation and applicable state laws governing trust administration, for its administrative trust services that are separate from investment management fees charged by financial advisors and are not shared with Ameriprise Financial Services. Neither Ameriprise Financial Services, your financial advisor nor any Advisory Service Provider are responsible for any other corporate actions relating to the assets in your managed account(s) including administrative filings such as proofs of claims related to bankruptcy or claims in class actions. When Ameriprise Bank is a Program Bank in the AIMMA program or ABISA is the Sweep Option, Ameriprise Bank earns income by lending or investing the deposits it receives and charging a higher interest rate to borrowers, or earning a higher yield, than it pays on the deposits held through these sweep programs. The difference is known as the "spread." • Ameriprise Bank earns revenue based on the amount of credit extended and the interest rate on the Ameriprise Preferred Line of Credit and Loan. Ameriprise Financial Services’ proxy voting policies and procedures When Ameriprise Financial Services has proxy voting authority for applicable Select Separate Accounts, Ameriprise Financial Services will apply the following general principles to meet its proxy voting responsibilities: • Seek to ensure that proxies are voted in the best economic interest of clients; • Address material conflicts of interest that may arise; and • Comply with disclosure and other requirements as required by law. 39 40 Ameriprise Financial Services intends to vote all proxies of which it becomes aware prior to the vote deadline. However, in certain limited circumstances, Ameriprise Financial Services may determine to refrain from voting. Ameriprise Financial Services will use an independent third-party proxy service for its fundamental research on proxy questions and subsequent recommendations and has adopted the third-party provider’s proxy voting guidelines covering certain types of proposals. The guidelines indicate whether to vote for, against or abstain from a particular proposal. In circumstances where proposals are not covered by the guidelines or a voting determination must be made on a case-by-case basis, the Oversight Committee will make the voting determination. The Oversight Committee may consider the voting recommendations of analysts, Investment Managers and information obtained from outside resources. The Oversight Committee reserves the right to consider each proxy vote, whether covered by the guidelines or a third-party recommendation, based on the facts and circumstances of the proposal presented, and submit a vote that it believes is in the best economic interest of its clients. Report of Independent Registered Public Accounting Firm Ameriprise Financial Services has implemented policies reasonably designed to identify potential material conflicts of interest to help us vote proxies without undue influence from individuals or groups who may have an economic interest in the outcome of a proxy vote. These policies include: To the Board of Directors and Member of Ameriprise Financial Services, LLC • Employing predetermined voting guidelines; Opinion on the Financial Statement – Statement of Financial Condition • Causing proxies to be voted in accordance with recommendations of an independent third party; • Causing the proxies to be delegated to an Independent third party, which may include Ameriprise Financial Serices’ proxy voting service provider; or • We have audited the accompanying Statement of Financial Condition of Ameriprise Financial Services, LLC (the “Company”) as of December 31, 2025, including the related notes (collectively referred to as the “financial statement”). In our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company as of December 31, 2025 in conformity with accounting principles generally accepted in the United States of America. In unusual cases, with the client’s consent and upon ample notice, forwarding the proxies to Ameriprise Financial Services’ clients so that they may vote the proxies directly. Basis for Opinion The financial statement is the responsibility of the Company’s management. Our responsibility is to express an opinion on the Company’s financial statement based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. • Each Investment Manager to which you delegate voting authority will vote proxies according to its own applicable voting policies and procedures. When you own both a Select Separate Account and another discretionary Managed Account and both Accounts invest in the same SMA strategy managed by the same Investment Manager, this may result in different voting determinations by the Ameriprise Financial Services and the Investment Manager for the same particular proposal. We maintain proxy voting records to meet our obligations under applicable law. You may obtain a copy of our proxy voting policy, and other information regarding how your proxies were voted, upon request by writing to us at the address set forth on the first page of this brochure or calling the phone number that appears on that page. We conducted our audit of this financial statement in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statement is free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statement, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statement. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statement. We believe that our audit provides a reasonable basis for our opinion. February 19, 2026 We have served as the Company’s auditor since 2010. www.pwc.com PricewaterhouseCoopers LLP, 45 S 7th Street, Suite #3400, Minneapolis, MN 55402 +1 (612) 596 6000 1 . 41 42 Ameriprise Financial Services intends to vote all proxies of which it becomes aware prior to the vote deadline. However, in certain limited circumstances, Ameriprise Financial Services may determine to refrain from voting. Ameriprise Financial Services will use an independent third-party proxy service for its fundamental research on proxy questions and subsequent recommendations and has adopted the third-party provider’s proxy voting guidelines covering certain types of proposals. The guidelines indicate whether to vote for, against or abstain from a particular proposal. In circumstances where proposals are not covered by the guidelines or a voting determination must be made on a case-by-case basis, the Oversight Committee will make the voting determination. The Oversight Committee may consider the voting recommendations of analysts, Investment Managers and information obtained from outside resources. The Oversight Committee reserves the right to consider each proxy vote, whether covered by the guidelines or a third-party recommendation, based on the facts and circumstances of the proposal presented, and submit a vote that it believes is in the best economic interest of its clients. Report of Independent Registered Public Accounting Firm Ameriprise Financial Services has implemented policies reasonably designed to identify potential material conflicts of interest to help us vote proxies without undue influence from individuals or groups who may have an economic interest in the outcome of a proxy vote. These policies include: To the Board of Directors and Member of Ameriprise Financial Services, LLC • Employing predetermined voting guidelines; Opinion on the Financial Statement – Statement of Financial Condition • Causing proxies to be voted in accordance with recommendations of an independent third party; • Causing the proxies to be delegated to an Independent third party, which may include Ameriprise Financial Serices’ proxy voting service provider; or • We have audited the accompanying Statement of Financial Condition of Ameriprise Financial Services, LLC (the “Company”) as of December 31, 2025, including the related notes (collectively referred to as the “financial statement”). In our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company as of December 31, 2025 in conformity with accounting principles generally accepted in the United States of America. In unusual cases, with the client’s consent and upon ample notice, forwarding the proxies to Ameriprise Financial Services’ clients so that they may vote the proxies directly. Basis for Opinion The financial statement is the responsibility of the Company’s management. Our responsibility is to express an opinion on the Company’s financial statement based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. • Each Investment Manager to which you delegate voting authority will vote proxies according to its own applicable voting policies and procedures. When you own both a Select Separate Account and another discretionary Managed Account and both Accounts invest in the same SMA strategy managed by the same Investment Manager, this may result in different voting determinations by the Ameriprise Financial Services and the Investment Manager for the same particular proposal. We maintain proxy voting records to meet our obligations under applicable law. You may obtain a copy of our proxy voting policy, and other information regarding how your proxies were voted, upon request by writing to us at the address set forth on the first page of this brochure or calling the phone number that appears on that page. We conducted our audit of this financial statement in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statement is free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statement, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statement. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statement. We believe that our audit provides a reasonable basis for our opinion. February 19, 2026 We have served as the Company’s auditor since 2010. www.pwc.com PricewaterhouseCoopers LLP, 45 S 7th Street, Suite #3400, Minneapolis, MN 55402 +1 (612) 596 6000 1 . 41 42 Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 1. Organization, Basis of Presentation, and Summary of Significant Accounting Policies Ameriprise Financial Services, LLC Statement of Financial Condition December 31, 2025 (In thousands) Organization Ameriprise Financial Services, LLC (the Company) is a wholly owned subsidiary of AMPF Holding, LLC. AMPF Holding, LLC is a wholly owned subsidiary of Ameriprise Financial, Inc. (the Parent). The Company was previously known as Ameriprise Financial Services, Inc., but was converted to a limited liability company effective January 2020. The Company is registered with the Securities and Exchange Commission (SEC) and the various states in which the Company conducts business as an introducing broker-dealer and is a member of the Financial Industry Regulatory Authority, Inc. (FINRA) and the Securities Investor Protection Corporation (SIPC). In addition, the Company is a registered investment adviser with the SEC pursuant to the Investment Advisers Act of 1940. The Company is registered as a Commodity Trading Advisor (CTA) with the U.S. Commodity Futures Trading Commission (CFTC) and is a member of, and the corresponding services function is regulated by, the National Futures Association (NFA). The Company is required to comply with all applicable rules and regulations of the SEC, FINRA, CFTC, NFA and SIPC. The Company clears most transactions with an affiliate, American Enterprise Investment Services, Inc. (AEIS), which under a clearing agreement charges the Company clearing fees on a per trade basis or based on assets under management. AEIS is primarily dependent on the Company for the introduction of clients and gathering of client assets which generates AEIS’s revenues. As a result, the Company charges a distribution access fee based on a fixed contractual amount to provide AEIS with ongoing access to the Company’s financial advisors, client servicing and product distribution efforts. The Company offers financial planning and investment advisory services to retail clients for which it charges a fee through an advisor-based distribution channel. These services are designed to provide comprehensive advice, when appropriate, to address clients’ cash and liquidity, asset accumulation, income, protection, and estate and wealth transfer needs. To complete their advice services, the Company’s financial advisors provide clients with recommendations from more than one hundred products distributed by subsidiaries and affiliates of the Parent, as well as products of approved third parties. The financial advisors are either non-employee independent contractors operating through a nationwide franchise system, or they may choose to be employees of the Company. Due to differing levels of support provided to advisors operating in these various platforms, advisors are compensated at different percentages of the gross dealer concessions allowed for the various product offerings. To complement its advisor-based channel, the Company also offers an integrated direct retail distribution channel. Direct distribution services are provided through the Company’s online brokerage offering, which allows clients to purchase and sell securities online, obtain research and information about a wide variety of securities, use asset allocation and financial planning tools, contact advisors, as well as access a wide range of proprietary and non-proprietary mutual funds. The Company’s operations constitute a single operating segment and therefore a single reportable segment, because the chief operating decision maker (“CODM”) manages the business activities using information of the Company as a whole. As its CODM, the Company’s President utilizes the Statements of Operations and its net income metric to allocate resources and assess performance of the Company. The accounting policies used to measure the profit and loss of the segment are the same as those described in the summary of significant accounting policies. Basis of Presentation The preparation of the financial statement in conformity with accounting principles generally accepted in the United States (U.S. GAAP) requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities, disclosure of contingent assets and liabilities, and the reported amounts of revenues and expenses. These accounting estimates reflect the best judgment of management and actual amounts could differ significantly from those estimates. The accompanying notes are an integral part of this financial statement. 2 3 43 44 Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 1. Organization, Basis of Presentation, and Summary of Significant Accounting Policies Ameriprise Financial Services, LLC Statement of Financial Condition December 31, 2025 (In thousands) Organization Ameriprise Financial Services, LLC (the Company) is a wholly owned subsidiary of AMPF Holding, LLC. AMPF Holding, LLC is a wholly owned subsidiary of Ameriprise Financial, Inc. (the Parent). The Company was previously known as Ameriprise Financial Services, Inc., but was converted to a limited liability company effective January 2020. The Company is registered with the Securities and Exchange Commission (SEC) and the various states in which the Company conducts business as an introducing broker-dealer and is a member of the Financial Industry Regulatory Authority, Inc. (FINRA) and the Securities Investor Protection Corporation (SIPC). In addition, the Company is a registered investment adviser with the SEC pursuant to the Investment Advisers Act of 1940. The Company is registered as a Commodity Trading Advisor (CTA) with the U.S. Commodity Futures Trading Commission (CFTC) and is a member of, and the corresponding services function is regulated by, the National Futures Association (NFA). The Company is required to comply with all applicable rules and regulations of the SEC, FINRA, CFTC, NFA and SIPC. The Company clears most transactions with an affiliate, American Enterprise Investment Services, Inc. (AEIS), which under a clearing agreement charges the Company clearing fees on a per trade basis or based on assets under management. AEIS is primarily dependent on the Company for the introduction of clients and gathering of client assets which generates AEIS’s revenues. As a result, the Company charges a distribution access fee based on a fixed contractual amount to provide AEIS with ongoing access to the Company’s financial advisors, client servicing and product distribution efforts. The Company offers financial planning and investment advisory services to retail clients for which it charges a fee through an advisor-based distribution channel. These services are designed to provide comprehensive advice, when appropriate, to address clients’ cash and liquidity, asset accumulation, income, protection, and estate and wealth transfer needs. To complete their advice services, the Company’s financial advisors provide clients with recommendations from more than one hundred products distributed by subsidiaries and affiliates of the Parent, as well as products of approved third parties. The financial advisors are either non-employee independent contractors operating through a nationwide franchise system, or they may choose to be employees of the Company. Due to differing levels of support provided to advisors operating in these various platforms, advisors are compensated at different percentages of the gross dealer concessions allowed for the various product offerings. To complement its advisor-based channel, the Company also offers an integrated direct retail distribution channel. Direct distribution services are provided through the Company’s online brokerage offering, which allows clients to purchase and sell securities online, obtain research and information about a wide variety of securities, use asset allocation and financial planning tools, contact advisors, as well as access a wide range of proprietary and non-proprietary mutual funds. The Company’s operations constitute a single operating segment and therefore a single reportable segment, because the chief operating decision maker (“CODM”) manages the business activities using information of the Company as a whole. As its CODM, the Company’s President utilizes the Statements of Operations and its net income metric to allocate resources and assess performance of the Company. The accounting policies used to measure the profit and loss of the segment are the same as those described in the summary of significant accounting policies. Basis of Presentation The preparation of the financial statement in conformity with accounting principles generally accepted in the United States (U.S. GAAP) requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities, disclosure of contingent assets and liabilities, and the reported amounts of revenues and expenses. These accounting estimates reflect the best judgment of management and actual amounts could differ significantly from those estimates. The accompanying notes are an integral part of this financial statement. 2 3 43 44 Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 Significant Accounting Policies 3. Goodwill and Other Intangibles Goodwill is not amortized but is instead subject to impairment tests. During the year ended December 31, 2025, the tests did not indicate impairment. Cash and cash equivalents: The Company has defined cash and cash equivalents to include money market funds, commercial paper, time deposits, and other highly liquid investments with original or remaining maturities at the time of purchase of 90 days or less. The Company has evaluated the cash equivalents for credit risk and has determined it is negligible due to the short-term nature of the investment. Definite lived intangible assets acquired for the year ended December 31, 2025, represent the acquisition of advisors, customer relationships, and non-compete agreements were $50,787, with a weighted average amortization period of five years. For the year ended December 31, 2025, the impairment tests on definite lived intangible assets did not indicate impairment. Cash segregated under federal and other regulations: Pursuant to Rule 15c3-3 Section (k)(2)(i), cash received that is not related to the securities business, is deposited into segregated bank accounts maintained solely for the benefit of customers until forwarded to affiliates. Cash received that is related to the securities business, is deposited directly into accounts maintained by its affiliate, AEIS. On November 6, 2023, the Company and Comerica, Inc. closed an arrangement in which the Company became Comerica’s new investment program provider. The Company acquired Comerica customer lists for $110,000. The acquisition resulted in a definite-lived intangible asset of $110,000, which is included in the total acquisitions disclosed above, with a straight- line amortization period of 10 years. The agreement includes provisions for terminations at the discretion of either Comerica or the Company subject to recoveries of previous amounts paid and other make-whole provisions. Allowance for credit losses: The Company measures credit losses using the current expected credit loss (CECL) method, when applicable. The Company recognizes an allowance for credit losses for financial assets carried at amortized cost to present the net amount expected to be collected. The allowance is based on the credit losses expected to arise over the life of the asset and is adjusted each period for changes in expected lifetime credit losses. Definite lived intangible assets consisted of the following: Goodwill and intangible assets: Goodwill represents the amount of an acquired company’s acquisition cost in excess of the fair value of assets acquired and liabilities assumed. The Company evaluates goodwill for impairment annually on the measurement date of July 1 and whenever events and circumstances indicate that an impairment may have occurred, such as a significant adverse change in the business climate or a decision to sell or dispose of a reporting unit. Impairment is the amount that the carrying value exceeds fair value and is evaluated at the reporting unit level. The Company assesses various qualitative factors to determine whether impairment is likely to have occurred. If impairment were to occur, the Company would use the discounted cash flow method, a variation of the income approach. 4. Business Owned Life Insurance Intangible assets generally represent customer and independent contractor relationships and non-compete agreements. Intangible assets are amortized over their estimated useful lives unless they are deemed to have indefinite useful lives. The Company evaluates the definite lived intangible assets remaining useful lives annually and tests for impairment whenever events and circumstances indicate that an impairment may have occurred, such as a significant adverse change in the business climate. For definite lived intangible assets, impairment to fair value is recognized if the carrying amount is not recoverable. Indefinite lived intangibles are also tested for impairment annually or whenever circumstances indicate an impairment may have occurred. The Company holds cash value life insurance policies as a means of offsetting market fluctuations in certain deferred compensation liabilities. As of December 31, 2025, the cash surrender value, which approximates fair value, of this life insurance was $39,848, and is included in the other assets line in the statement of financial condition. Prepaid commissions: Commissions paid by the Company to advisors in connection with the sales of financial plans are deferred until the plan is delivered and the corresponding revenue is recognized. 5. Secured Demand Note Receivable and Subordinated Liabilities 2. Recent Accounting Pronouncements In December 2014, a subordinated loan agreement in the form of a secured demand note was entered into with the Parent. Adoption of New Accounting Standards The borrowing available under the subordination agreement on December 31, 2025, is as follows: Secured demand note collateral agreement, 0.10 percent, due December 15, 2026 $200,000 Segment Reporting – Improvements to Reportable Segment Disclosures The subordinated borrowing with the Parent is available in computing net capital under the SEC’s uniform net capital rule. Under the terms of the subordinated loan agreement, to the extent that such borrowings are required for the Company’s continued compliance with minimum net capital requirements, the Company is prohibited from making payments on the subordinated note agreement. The Company has the option to renew the current agreement in one-year increments in perpetuity. Pursuant to the agreement, the Parent must notify the Company on or before the day seven months preceding the maturity date if they do not intend to extend the maturity date of the agreement. The Company and the Parent have elected to not terminate the agreement for fiscal year 2026. In November 2023, the Financial Accounting Standards Board (“FASB”) issued Accounting Standards Update (“ASU”) 2023-07, Improvements to Reportable Segment Disclosures, updating reportable segment disclosure requirements in accordance with Topic 280, Segment Reporting (“Topic 280”), primarily through enhanced disclosures about significant segment expenses. The amendments also expand Topic 280 disclosures to public entities with one reportable segment, clarify circumstances in which an entity can disclose multiple segment measures of profit or loss, and contain other disclosure requirements. The amendments are effective for annual periods beginning after December 15, 2023. The Company adopted the standard on January 1, 2024. The adoption of the standard did not have an impact on the Company’s financial condition and results of operations as the standard is disclosure-related only. On December 31, 2025, the secured demand note was collateralized by securities with an aggregate fair value of $220,556. Based on the character and fair value of the securities collateralizing the secured demand note receivable, the entire $200,000 is available in computing net capital in accordance with SEC’s uniform net capital rule. The securities collateral has been deposited by the Parent in a separate custodial account for the exclusive benefit of the Company. In the event the Company draws on the secured demand note receivable, the maximum payment to the Company in accordance with the 4 5 45 46 Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 Significant Accounting Policies 3. Goodwill and Other Intangibles Goodwill is not amortized but is instead subject to impairment tests. During the year ended December 31, 2025, the tests did not indicate impairment. Cash and cash equivalents: The Company has defined cash and cash equivalents to include money market funds, commercial paper, time deposits, and other highly liquid investments with original or remaining maturities at the time of purchase of 90 days or less. The Company has evaluated the cash equivalents for credit risk and has determined it is negligible due to the short-term nature of the investment. Definite lived intangible assets acquired for the year ended December 31, 2025, represent the acquisition of advisors, customer relationships, and non-compete agreements were $50,787, with a weighted average amortization period of five years. For the year ended December 31, 2025, the impairment tests on definite lived intangible assets did not indicate impairment. Cash segregated under federal and other regulations: Pursuant to Rule 15c3-3 Section (k)(2)(i), cash received that is not related to the securities business, is deposited into segregated bank accounts maintained solely for the benefit of customers until forwarded to affiliates. Cash received that is related to the securities business, is deposited directly into accounts maintained by its affiliate, AEIS. On November 6, 2023, the Company and Comerica, Inc. closed an arrangement in which the Company became Comerica’s new investment program provider. The Company acquired Comerica customer lists for $110,000. The acquisition resulted in a definite-lived intangible asset of $110,000, which is included in the total acquisitions disclosed above, with a straight- line amortization period of 10 years. The agreement includes provisions for terminations at the discretion of either Comerica or the Company subject to recoveries of previous amounts paid and other make-whole provisions. Allowance for credit losses: The Company measures credit losses using the current expected credit loss (CECL) method, when applicable. The Company recognizes an allowance for credit losses for financial assets carried at amortized cost to present the net amount expected to be collected. The allowance is based on the credit losses expected to arise over the life of the asset and is adjusted each period for changes in expected lifetime credit losses. Definite lived intangible assets consisted of the following: Goodwill and intangible assets: Goodwill represents the amount of an acquired company’s acquisition cost in excess of the fair value of assets acquired and liabilities assumed. The Company evaluates goodwill for impairment annually on the measurement date of July 1 and whenever events and circumstances indicate that an impairment may have occurred, such as a significant adverse change in the business climate or a decision to sell or dispose of a reporting unit. Impairment is the amount that the carrying value exceeds fair value and is evaluated at the reporting unit level. The Company assesses various qualitative factors to determine whether impairment is likely to have occurred. If impairment were to occur, the Company would use the discounted cash flow method, a variation of the income approach. 4. Business Owned Life Insurance Intangible assets generally represent customer and independent contractor relationships and non-compete agreements. Intangible assets are amortized over their estimated useful lives unless they are deemed to have indefinite useful lives. The Company evaluates the definite lived intangible assets remaining useful lives annually and tests for impairment whenever events and circumstances indicate that an impairment may have occurred, such as a significant adverse change in the business climate. For definite lived intangible assets, impairment to fair value is recognized if the carrying amount is not recoverable. Indefinite lived intangibles are also tested for impairment annually or whenever circumstances indicate an impairment may have occurred. The Company holds cash value life insurance policies as a means of offsetting market fluctuations in certain deferred compensation liabilities. As of December 31, 2025, the cash surrender value, which approximates fair value, of this life insurance was $39,848, and is included in the other assets line in the statement of financial condition. Prepaid commissions: Commissions paid by the Company to advisors in connection with the sales of financial plans are deferred until the plan is delivered and the corresponding revenue is recognized. 5. Secured Demand Note Receivable and Subordinated Liabilities 2. Recent Accounting Pronouncements In December 2014, a subordinated loan agreement in the form of a secured demand note was entered into with the Parent. Adoption of New Accounting Standards The borrowing available under the subordination agreement on December 31, 2025, is as follows: Secured demand note collateral agreement, 0.10 percent, due December 15, 2026 $200,000 Segment Reporting – Improvements to Reportable Segment Disclosures The subordinated borrowing with the Parent is available in computing net capital under the SEC’s uniform net capital rule. Under the terms of the subordinated loan agreement, to the extent that such borrowings are required for the Company’s continued compliance with minimum net capital requirements, the Company is prohibited from making payments on the subordinated note agreement. The Company has the option to renew the current agreement in one-year increments in perpetuity. Pursuant to the agreement, the Parent must notify the Company on or before the day seven months preceding the maturity date if they do not intend to extend the maturity date of the agreement. The Company and the Parent have elected to not terminate the agreement for fiscal year 2026. In November 2023, the Financial Accounting Standards Board (“FASB”) issued Accounting Standards Update (“ASU”) 2023-07, Improvements to Reportable Segment Disclosures, updating reportable segment disclosure requirements in accordance with Topic 280, Segment Reporting (“Topic 280”), primarily through enhanced disclosures about significant segment expenses. The amendments also expand Topic 280 disclosures to public entities with one reportable segment, clarify circumstances in which an entity can disclose multiple segment measures of profit or loss, and contain other disclosure requirements. The amendments are effective for annual periods beginning after December 15, 2023. The Company adopted the standard on January 1, 2024. The adoption of the standard did not have an impact on the Company’s financial condition and results of operations as the standard is disclosure-related only. On December 31, 2025, the secured demand note was collateralized by securities with an aggregate fair value of $220,556. Based on the character and fair value of the securities collateralizing the secured demand note receivable, the entire $200,000 is available in computing net capital in accordance with SEC’s uniform net capital rule. The securities collateral has been deposited by the Parent in a separate custodial account for the exclusive benefit of the Company. In the event the Company draws on the secured demand note receivable, the maximum payment to the Company in accordance with the 4 5 45 46 Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 The following table presents balances of assets and liabilities measured at fair value on a recurring basis: terms of the collateral agreement is $200,000. Effective June 1, 2023, the Company and Lender agreed to amend the subordinated agreement by modifying the interest rate from LIBOR plus 90 basis points to Daily Simple SOFR plus 100 basis points (SOFR + 1.00%) per annum. The subordinated loan agreement and the associated secured demand note agreement entered with the Parent was approved by FINRA prior to the respective effective dates. 6. Fair Values of Assets and Liabilities U.S. GAAP defines fair value as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date; that is, an exit price. The exit price assumes the asset or liability is not exchanged subject to a forced liquidation or distressed sale. Valuation Hierarchy The Company categorizes its fair value measurements according to a three-level hierarchy. The hierarchy prioritizes the input used by the Company’s valuation techniques. A level is assigned to each fair value measurement based on the lowest level input that is significant to the fair value measurement in its entirety. The three levels of the fair value hierarchy are defined as follows: Level 1 Level 2 During the reporting period, there were no material assets or liabilities measured at fair value on a nonrecurring basis. There were no transfers between levels during the periods. The following table provides a summary of changes in Level 3 liabilities measured at fair value on a recurring basis: Level 3 Unadjusted quoted prices for identical assets or liabilities in active markets that are accessible at the measurement date. Prices or valuations based on observable inputs other than quoted prices in active markets for identical assets and liabilities. Prices or valuations that require inputs that are both significant to the fair value measurement and unobservable. Determination of Fair Value The Company uses valuation techniques consistent with the market and income approaches to measure the fair value of its assets and liabilities. The Company’s market approach uses prices and other relevant information generated by market transactions involving identical or comparable assets or liabilities. The Company’s income approach uses valuation techniques to convert future projected cash flows to a single discounted present value amount. When applying either approach, the Company maximizes the use of observable inputs and minimizes the use of unobservable inputs. The following is a description of the valuation techniques used to measure fair value and the general classification of these instruments pursuant to the fair value hierarchy. Fair Value of Financial Instruments In general, the Company’s financial assets and liabilities are carried at fair value or at amounts which, because of their short-term nature and based on market interest rates available to the Company on December 31, 2025, approximate fair value. Included in receivables from financial advisors and employees in the statement of financial condition are loans receivable from financial advisors. As of December 31, 2025, the carrying value of the loans is $3,133, which approximates fair value. These receivables, not included in the table of assets and liabilities measured at fair value on a recurring basis, are considered Level 3 fair value. As of December 31, 2025, the fair value of the secured demand notes receivable and the subordinated liability approximate book value of $200,000. This receivable and liability, not included in the table above, are both considered Level 2 fair value. As of December 31, 2025, the secured demand note collateral consisted of corporate bonds and agency mortgage- backed securities and is considered Level 2 fair value. Cash Equivalents, Other Assets and Liabilities When available, the fair value of securities is based on quoted prices in active markets. If quoted prices are not available, fair values are obtained from third party pricing services, non-binding broker quotes, or other model-based valuation techniques. The Company’s cash equivalents, consisting of commercial paper and time deposits, are classified as Level 2 and are measured at amortized cost, which approximates fair value because of the short time between the purchase of the instrument and its expected realization. Level 1 money market funds and other assets consist of common stock and government treasury bills and notes. Level 2 other assets consist of unitary investment trusts (UITs), municipal bonds, and limited market securities. Level 2 liabilities consist of UITs, non-convertible debt securities, municipal bonds, government securities and agencies, and limited market securities. Level 3 contingent consideration liabilities consist of earn outs and/or deferred payments related to the Company’s acquisitions. Contingent consideration liabilities are recorded at fair value utilizing a discounted cash flow model using an unobservable input (discount rate). Significant increases (decreases) in the discount rate used in the fair value measurement of the contingent consideration liability in isolation would have resulted in a significantly lower (higher) fair value measurement. Given the use of a significant unobservable input, the fair value of contingent consideration liabilities is classified as Level 3 within the fair value hierarchy. 6 7 47 48 Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 The following table presents balances of assets and liabilities measured at fair value on a recurring basis: terms of the collateral agreement is $200,000. Effective June 1, 2023, the Company and Lender agreed to amend the subordinated agreement by modifying the interest rate from LIBOR plus 90 basis points to Daily Simple SOFR plus 100 basis points (SOFR + 1.00%) per annum. The subordinated loan agreement and the associated secured demand note agreement entered with the Parent was approved by FINRA prior to the respective effective dates. 6. Fair Values of Assets and Liabilities U.S. GAAP defines fair value as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date; that is, an exit price. The exit price assumes the asset or liability is not exchanged subject to a forced liquidation or distressed sale. Valuation Hierarchy The Company categorizes its fair value measurements according to a three-level hierarchy. The hierarchy prioritizes the input used by the Company’s valuation techniques. A level is assigned to each fair value measurement based on the lowest level input that is significant to the fair value measurement in its entirety. The three levels of the fair value hierarchy are defined as follows: Level 1 Level 2 During the reporting period, there were no material assets or liabilities measured at fair value on a nonrecurring basis. There were no transfers between levels during the periods. The following table provides a summary of changes in Level 3 liabilities measured at fair value on a recurring basis: Level 3 Unadjusted quoted prices for identical assets or liabilities in active markets that are accessible at the measurement date. Prices or valuations based on observable inputs other than quoted prices in active markets for identical assets and liabilities. Prices or valuations that require inputs that are both significant to the fair value measurement and unobservable. Determination of Fair Value The Company uses valuation techniques consistent with the market and income approaches to measure the fair value of its assets and liabilities. The Company’s market approach uses prices and other relevant information generated by market transactions involving identical or comparable assets or liabilities. The Company’s income approach uses valuation techniques to convert future projected cash flows to a single discounted present value amount. When applying either approach, the Company maximizes the use of observable inputs and minimizes the use of unobservable inputs. The following is a description of the valuation techniques used to measure fair value and the general classification of these instruments pursuant to the fair value hierarchy. Fair Value of Financial Instruments In general, the Company’s financial assets and liabilities are carried at fair value or at amounts which, because of their short-term nature and based on market interest rates available to the Company on December 31, 2025, approximate fair value. Included in receivables from financial advisors and employees in the statement of financial condition are loans receivable from financial advisors. As of December 31, 2025, the carrying value of the loans is $3,133, which approximates fair value. These receivables, not included in the table of assets and liabilities measured at fair value on a recurring basis, are considered Level 3 fair value. As of December 31, 2025, the fair value of the secured demand notes receivable and the subordinated liability approximate book value of $200,000. This receivable and liability, not included in the table above, are both considered Level 2 fair value. As of December 31, 2025, the secured demand note collateral consisted of corporate bonds and agency mortgage- backed securities and is considered Level 2 fair value. Cash Equivalents, Other Assets and Liabilities When available, the fair value of securities is based on quoted prices in active markets. If quoted prices are not available, fair values are obtained from third party pricing services, non-binding broker quotes, or other model-based valuation techniques. The Company’s cash equivalents, consisting of commercial paper and time deposits, are classified as Level 2 and are measured at amortized cost, which approximates fair value because of the short time between the purchase of the instrument and its expected realization. Level 1 money market funds and other assets consist of common stock and government treasury bills and notes. Level 2 other assets consist of unitary investment trusts (UITs), municipal bonds, and limited market securities. Level 2 liabilities consist of UITs, non-convertible debt securities, municipal bonds, government securities and agencies, and limited market securities. Level 3 contingent consideration liabilities consist of earn outs and/or deferred payments related to the Company’s acquisitions. Contingent consideration liabilities are recorded at fair value utilizing a discounted cash flow model using an unobservable input (discount rate). Significant increases (decreases) in the discount rate used in the fair value measurement of the contingent consideration liability in isolation would have resulted in a significantly lower (higher) fair value measurement. Given the use of a significant unobservable input, the fair value of contingent consideration liabilities is classified as Level 3 within the fair value hierarchy. 6 7 47 48 Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 7. Net Capital Provision and Regulatory Requirements As a registered broker dealer, the Company is subject to the SEC’s uniform net capital rule (SEA Rule 15c3-1). adverse outcome in one or more proceedings could eventually result in adverse judgments, settlements, fines, penalties, or other sanctions, in addition to further claims, examinations, or adverse publicity that could have a material adverse effect on the Company’s financial condition or results of operations. The Company computes its net capital requirements under the alternative method provided for in SEA Rule 15c3-1, which requires the Company to maintain net capital equal to 2% of combined aggregate customer-related debit items, as defined (or $250, if greater). On December 31, 2025, the Company had net capital of $137,699 which was $137,449 more than the amount required to be maintained at those dates. Advances to affiliates, dividend payments, and other equity withdrawals are subject to certain notifications and other provisions of the net capital rule of the SEC and other regulatory bodies. In accordance with applicable accounting standards, the Company establishes an accrued liability for contingent litigation and regulatory matters when those matters present loss contingencies that are both probable and can be reasonably estimated. In such cases, there still may be exposure to loss more than any amount reasonably estimated and accrued. When a loss contingency is not both probable and estimable, the Company does not establish an accrued liability, but continues to monitor, in conjunction with any outside counsel handling a matter, further developments that would make such loss contingency both probable and reasonably estimable. Once the Company establishes accrued liability with respect to a loss contingency, the Company continues to monitor the matter for further developments that could affect the amount of the accrued liability that has been previously established, and any appropriate adjustments are made each quarter. The Company has claimed exemption from SEA Rule 15c3-3 of the SEC under paragraphs (k)(2)(i) and (k)(2)(ii) of that rule. 9. Income Taxes 8. Commitments and Contingencies Effective January 1, 2020, the Company adopted guidance simplifying the accounting for income taxes. As a result of the adoption and the Company’s conversion to a limited liability company in 2020 which resulted in it becoming a disregarded entity, income tax expense, income tax receivables and payables, and deferred tax assets and liabilities are no longer recognized in the financial statement for the Company. See Notes 1 and 2. In the normal course of business, the Company may indemnify and guarantee certain service providers against potential losses in connection with their acting as service providers to the Company. The maximum potential future payments the Company could be required to make under these indemnifications cannot be estimated; however, the Company believes that it is unlikely it will have to make material payments under these arrangements and has not recorded a contingent liability in the financial statement for any indemnifications. The Company has agreed to indemnify an affiliate, AEIS, for any losses that it may sustain from the customer accounts introduced by the Company. The Company reserves for these potential losses. On December 31, 2025, the reserve was $3,020 and is reflected in the other liabilities line in the statement of financial condition. The Company files its federal income tax return as part of the consolidated income tax return of the Parent in the U.S. federal jurisdiction. The Company files as a separate entity and as part of unitary or combined returns with the Parent and other affiliates in various state jurisdictions. The federal statutes of limitations are closed on years through 2018, except for two issues for 2016 which were claimed on an amended return. During the second quarter of 2025, the Internal Revenue Service (IRS) finalized the audit of the Parent’s U.S. income tax returns for tax years 2019 and 2020, except for one issue for 2020, which remains open. The IRS is currently auditing the Parent’s U.S. income tax returns for 2021 through 2023. The state income tax returns of the Parent or its subsidiaries, including the Company, are currently under examination by various jurisdictions for years ranging from 2018 through 2023. 10. Related Party Transactions Receivables due from affiliates in the statement of financial condition primarily consist of distribution fees of $66,406, trading concessions of $7,233, marketing support fees of $8,411, and an insurance recoverable of $19,600 on December 31, 2025. The Company is involved in the normal course of business in legal, regulatory and arbitration proceedings, including class actions, concerning matters arising in connection with the conduct of its activities as a diversified financial services firm. These include proceedings specific to the Company as well as proceedings generally applicable to business practices in the industries in which it operates. The Company can also be subject to litigation arising out of its general business activities, such as its investments, contracts, leases, and employment relationships. Uncertain economic conditions heightened and sustained volatility in the financial markets and significant financial reform legislation may increase the likelihood that clients and other people or regulators may present or threaten legal claims or that regulators increase the scope or frequency of examinations of the Company or the financial services industry generally. Payables due to affiliates in the statement of financial condition primarily consist of administrative expenses of $139,825, use of property and equipment maintenance for $4,859, cash for affiliated product purchases of $1,202 due to various affiliates for investments in products and clearing charges for $39,235 on December 31, 2025. The Company clears most transactions with AEIS, which charges the Company clearing fees on a trade basis or on assets under management on a trade basis. As with other financial services firms, the level of regulatory activity and inquiry concerning the Company’s businesses remains elevated. From time to time, the Company receives requests for information from, and/or has been subject to examination or claims by, the SEC, FINRA, state insurance and securities regulators, state attorneys general and various other governmental and quasi-governmental authorities on behalf of themselves or clients concerning the Company’s business activities and practices, and the practices of the Company’s financial advisors. The Company has numerous pending matters which include information requests, exams or inquiries that the Company has received during recent periods regarding certain matters, including: sales and distribution of mutual funds, exchange traded funds, annuities, equity and fixed income securities, real estate investment trusts, insurance products, and financial advice offerings, including managed accounts; supervision of the Company’s financial advisors; security of client information; and transaction monitoring systems and controls. The Company has cooperated and will continue to cooperate with the applicable regulators. The Company participates in the Parent’s Retirement Plan (the Plan), which covers all permanent employees aged 21 and over who have met certain employment requirements. Effective April 2020, the Parent no longer enrolled employees in the plan. The Plan includes a cash balance formula and a lump sum distribution option. Pension benefit contributions to the Plan are based on participants’ age, years of service and total compensation for the year. Funding of retirement costs for the Plan complies with the applicable minimum funding requirements specified by the Employee Retirement Income Security Act (ERISA). The Company also participates in defined contribution pension plans of the Parent that cover all employees who have met certain employment requirements. The Company’s contributions to the plans are a percentage of either each employee’s eligible compensation or basic contributions. These legal and regulatory proceedings and disputes are subject to uncertainties and, as such, it is inherently difficult to determine whether any loss is probable or even reasonably possible, or to reasonably estimate the amount of any loss. The Company cannot predict with certainty whether or when any such proceedings will be initiated or resolved or what the eventual settlement, fine, penalty or other relief, if any, may be, particularly for proceedings that are in their early stages of development or where plaintiffs seek indeterminate damages. Numerous issues may need to be resolved, including through potentially lengthy discovery and determination of important factual matters, and by addressing unsettled legal questions relevant to the proceedings in question, before a loss or range of loss can be reasonably estimated for any proceeding. An Effective October 2011, the Company entered into two separate revolving credit agreements with the Parent, whereby in one, the Company can borrow up to $100,000 from the Parent and in the second the Parent can borrow up to $100,000 from the Company. Effective June 1, 2023, the Company and Lender hereby agreed to amend the agreements by modifying the 8 9 49 50 Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 7. Net Capital Provision and Regulatory Requirements As a registered broker dealer, the Company is subject to the SEC’s uniform net capital rule (SEA Rule 15c3-1). adverse outcome in one or more proceedings could eventually result in adverse judgments, settlements, fines, penalties, or other sanctions, in addition to further claims, examinations, or adverse publicity that could have a material adverse effect on the Company’s financial condition or results of operations. The Company computes its net capital requirements under the alternative method provided for in SEA Rule 15c3-1, which requires the Company to maintain net capital equal to 2% of combined aggregate customer-related debit items, as defined (or $250, if greater). On December 31, 2025, the Company had net capital of $137,699 which was $137,449 more than the amount required to be maintained at those dates. Advances to affiliates, dividend payments, and other equity withdrawals are subject to certain notifications and other provisions of the net capital rule of the SEC and other regulatory bodies. In accordance with applicable accounting standards, the Company establishes an accrued liability for contingent litigation and regulatory matters when those matters present loss contingencies that are both probable and can be reasonably estimated. In such cases, there still may be exposure to loss more than any amount reasonably estimated and accrued. When a loss contingency is not both probable and estimable, the Company does not establish an accrued liability, but continues to monitor, in conjunction with any outside counsel handling a matter, further developments that would make such loss contingency both probable and reasonably estimable. Once the Company establishes accrued liability with respect to a loss contingency, the Company continues to monitor the matter for further developments that could affect the amount of the accrued liability that has been previously established, and any appropriate adjustments are made each quarter. The Company has claimed exemption from SEA Rule 15c3-3 of the SEC under paragraphs (k)(2)(i) and (k)(2)(ii) of that rule. 9. Income Taxes 8. Commitments and Contingencies Effective January 1, 2020, the Company adopted guidance simplifying the accounting for income taxes. As a result of the adoption and the Company’s conversion to a limited liability company in 2020 which resulted in it becoming a disregarded entity, income tax expense, income tax receivables and payables, and deferred tax assets and liabilities are no longer recognized in the financial statement for the Company. See Notes 1 and 2. In the normal course of business, the Company may indemnify and guarantee certain service providers against potential losses in connection with their acting as service providers to the Company. The maximum potential future payments the Company could be required to make under these indemnifications cannot be estimated; however, the Company believes that it is unlikely it will have to make material payments under these arrangements and has not recorded a contingent liability in the financial statement for any indemnifications. The Company has agreed to indemnify an affiliate, AEIS, for any losses that it may sustain from the customer accounts introduced by the Company. The Company reserves for these potential losses. On December 31, 2025, the reserve was $3,020 and is reflected in the other liabilities line in the statement of financial condition. The Company files its federal income tax return as part of the consolidated income tax return of the Parent in the U.S. federal jurisdiction. The Company files as a separate entity and as part of unitary or combined returns with the Parent and other affiliates in various state jurisdictions. The federal statutes of limitations are closed on years through 2018, except for two issues for 2016 which were claimed on an amended return. During the second quarter of 2025, the Internal Revenue Service (IRS) finalized the audit of the Parent’s U.S. income tax returns for tax years 2019 and 2020, except for one issue for 2020, which remains open. The IRS is currently auditing the Parent’s U.S. income tax returns for 2021 through 2023. The state income tax returns of the Parent or its subsidiaries, including the Company, are currently under examination by various jurisdictions for years ranging from 2018 through 2023. 10. Related Party Transactions Receivables due from affiliates in the statement of financial condition primarily consist of distribution fees of $66,406, trading concessions of $7,233, marketing support fees of $8,411, and an insurance recoverable of $19,600 on December 31, 2025. The Company is involved in the normal course of business in legal, regulatory and arbitration proceedings, including class actions, concerning matters arising in connection with the conduct of its activities as a diversified financial services firm. These include proceedings specific to the Company as well as proceedings generally applicable to business practices in the industries in which it operates. The Company can also be subject to litigation arising out of its general business activities, such as its investments, contracts, leases, and employment relationships. Uncertain economic conditions heightened and sustained volatility in the financial markets and significant financial reform legislation may increase the likelihood that clients and other people or regulators may present or threaten legal claims or that regulators increase the scope or frequency of examinations of the Company or the financial services industry generally. Payables due to affiliates in the statement of financial condition primarily consist of administrative expenses of $139,825, use of property and equipment maintenance for $4,859, cash for affiliated product purchases of $1,202 due to various affiliates for investments in products and clearing charges for $39,235 on December 31, 2025. The Company clears most transactions with AEIS, which charges the Company clearing fees on a trade basis or on assets under management on a trade basis. As with other financial services firms, the level of regulatory activity and inquiry concerning the Company’s businesses remains elevated. From time to time, the Company receives requests for information from, and/or has been subject to examination or claims by, the SEC, FINRA, state insurance and securities regulators, state attorneys general and various other governmental and quasi-governmental authorities on behalf of themselves or clients concerning the Company’s business activities and practices, and the practices of the Company’s financial advisors. The Company has numerous pending matters which include information requests, exams or inquiries that the Company has received during recent periods regarding certain matters, including: sales and distribution of mutual funds, exchange traded funds, annuities, equity and fixed income securities, real estate investment trusts, insurance products, and financial advice offerings, including managed accounts; supervision of the Company’s financial advisors; security of client information; and transaction monitoring systems and controls. The Company has cooperated and will continue to cooperate with the applicable regulators. The Company participates in the Parent’s Retirement Plan (the Plan), which covers all permanent employees aged 21 and over who have met certain employment requirements. Effective April 2020, the Parent no longer enrolled employees in the plan. The Plan includes a cash balance formula and a lump sum distribution option. Pension benefit contributions to the Plan are based on participants’ age, years of service and total compensation for the year. Funding of retirement costs for the Plan complies with the applicable minimum funding requirements specified by the Employee Retirement Income Security Act (ERISA). The Company also participates in defined contribution pension plans of the Parent that cover all employees who have met certain employment requirements. The Company’s contributions to the plans are a percentage of either each employee’s eligible compensation or basic contributions. These legal and regulatory proceedings and disputes are subject to uncertainties and, as such, it is inherently difficult to determine whether any loss is probable or even reasonably possible, or to reasonably estimate the amount of any loss. The Company cannot predict with certainty whether or when any such proceedings will be initiated or resolved or what the eventual settlement, fine, penalty or other relief, if any, may be, particularly for proceedings that are in their early stages of development or where plaintiffs seek indeterminate damages. Numerous issues may need to be resolved, including through potentially lengthy discovery and determination of important factual matters, and by addressing unsettled legal questions relevant to the proceedings in question, before a loss or range of loss can be reasonably estimated for any proceeding. An Effective October 2011, the Company entered into two separate revolving credit agreements with the Parent, whereby in one, the Company can borrow up to $100,000 from the Parent and in the second the Parent can borrow up to $100,000 from the Company. Effective June 1, 2023, the Company and Lender hereby agreed to amend the agreements by modifying the 8 9 49 50 Terms and Conditions of Your AFPS Agreement By signing the AFPS Agreement, you agree that the following terms and conditions are incorporated by reference and, together, form the Agreement governing your AFPS engagement with Ameriprise Financial Services. The Agreement will help ensure that you and your financial advisor receive the information required to begin your financial planning relationship. Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 Entire agreement interest rate from LIBOR plus 90 basis points to Daily Simple SOFR plus 100 basis points (SOFR + 1.00%) per annum. As of December 31, 2025, there were no draws on these lines of credit. The agreements remain in effect until the expiration date (October 19th of each year), which shall be automatically extended without amendment of the agreements for one year, or any date annually thereafter. Either party may terminate the agreements prior to the expiration date by providing written notice to the other party at least thirty (30) days prior to the expiration date. The agreements were in place for all of 2025 and were renewed for 2026. The AFPS Agreement, together with any Fee Amendments signed by you and/or your financial advisor as required, represents the entire Agreement between you and Ameriprise Financial Services. Ameriprise Financial Services may amend the Agreement by providing written notice to you of the amendment. Unless you object to the amendment after receiving written notice of the changes, the amendment will become a part of the Agreement. Notwithstanding the foregoing, any increase to the fee you pay for AFPS must be in writing and signed by you and Ameriprise Financial Services. Effective December 2014, the Company and the Parent entered a secured demand note collateral and subordinated loan agreement for $200,000 at a stated interest rate of 0.10% due to mature on December 15, 2026, with the option to renew in one-year increments in perpetuity. The secured demand note collateral and subordinated loan agreement was renewed for 2026. The AFPS Agreement does not need to be re-signed to reflect changes except as noted below. A new AFPS Agreement is required in these instances: The Company paid dividends to the Parent of $1,365,000 in 2025. • You and your financial advisor determine to restart the initial year of service. • There is a change in owners or parties to the AFPS Agreement, except when there is a death of one of the joint owners. • There is a lapse of a prior AFPS Agreement (for example, if fees have not been paid for more than one year). The Parent’s Incentive Compensation Plan primarily grants restricted stock awards and stock units that generally vest ratably over three to four years to the Company’s employees. Vesting of restricted awards and units may be accelerated based on age and length of service. Compensation expense for restricted stock awards is based on the market price of the Parent’s stock on the date of grant and is amortized on a straight-line basis over the vesting period. Quarterly dividends are paid on restricted stock and stock units during the vesting period and are not subject to forfeiture. A summary of the Company's restricted stock award and stock unit activity is presented below: About estate or trust beneficiaries as AFPS clients — If you are an AFPS client and a beneficiary of an estate or trust that is also an AFPS client serviced by your financial advisor, you understand, acknowledge and agree that (1) there may be a conflict when your financial advisor is providing advice to you as the beneficiary of an estate or trust, as the estate’s or trust’s interest may not be the same as your interest as beneficiary; and (2) when servicing the estate or trust, your financial advisor cannot put your interest as beneficiary ahead of his or her obligation to act in the best interests of the estate or trust. About power of attorney appointments — If you are an Attorney-in-Fact pursuant to a Power of Attorney for the client, you understand, acknowledge and agree that: (1) the financial planning services will be based on the information provided to us by the client and/or you as attorney-in-fact regarding the client’s financial situation; (2) you will provide us with complete and accurate information, to the best of your knowledge; and (3) with the service the client or you as attorney-in-fact purchases the financial advisor is not obligated to make recommendations or give financial advice that, in the sole judgment of the financial advisor, would be impracticable, unsuitable, unattainable or undesirable for the client. We strongly recommend you seek advice from legal and tax counsel before implementing suggested planning strategies that involve disposition of assets. We reserve the right to decline business. When servicing the client’s account, the financial advisor cannot put your interests as attorney-in- fact ahead of his or her obligations to act in the best interest of the client. The Parent’s Advisor Group Deferral Plan, which was created in April 2009, allows for employee advisors to receive share- based bonus awards which are subject to future service requirements and forfeitures. The Advisor Group Deferral Plan is an unfunded non-qualified deferred compensation plan under section 409A of the Internal Revenue Code. The Advisor Group Deferral Plan also gives qualifying employee advisors the choice to defer a portion of their base salary or commissions. This deferral can be in the form of share-based awards or other investment options. Deferrals are not subject to future service requirements or forfeitures. Awards granted under the Advisor Group Deferral Plan may be settled in cash and/or shares of the Parent's common stock according to the award's terms. Disclosure of interest and capacity As of December 31, 2025, there were approximately 877,000 shares outstanding under the Advisor Group Deferral Plan, of which 206,210 were fully vested. 11. Subsequent Events As of February 19, 2026, which is the date the financial statements were available to be issued, the Company evaluated events or transactions that may have occurred after the statement of financial condition date for potential recognition or disclosure. No subsequent events or transactions requiring recognition of disclosure were identified. About advisor compensation — Your financial advisor may recommend that you purchase or sell investments, recommend that you enter into other financial transactions, or provide financial advice regarding financial decisions. You have no obligation to follow any such recommendations or advice. If you implement any such recommendations through Ameriprise Financial Services, then in addition to the AFPS fee described above, your financial advisor will receive fees, commissions or other financial compensation as a result of the transaction and/or advice, as described in the “How our financial advisors get paid” section elsewhere in this Brochure. Such transactions may result in tax consequences for non-qualified accounts. About your agreement — No assignment of the Agreement by Ameriprise Financial Services will be effective without your consent. 10 About your initial proposal and ongoing service — Your financial advisor’s initial recommendations may address only the areas that you have identified as your most immediate needs and priorities. 51 52 Terms and Conditions of Your AFPS Agreement By signing the AFPS Agreement, you agree that the following terms and conditions are incorporated by reference and, together, form the Agreement governing your AFPS engagement with Ameriprise Financial Services. The Agreement will help ensure that you and your financial advisor receive the information required to begin your financial planning relationship. Ameriprise Financial Services, LLC Notes to Statement of Financial Condition (In thousands, except share amounts) December 31, 2025 Entire agreement interest rate from LIBOR plus 90 basis points to Daily Simple SOFR plus 100 basis points (SOFR + 1.00%) per annum. As of December 31, 2025, there were no draws on these lines of credit. The agreements remain in effect until the expiration date (October 19th of each year), which shall be automatically extended without amendment of the agreements for one year, or any date annually thereafter. Either party may terminate the agreements prior to the expiration date by providing written notice to the other party at least thirty (30) days prior to the expiration date. The agreements were in place for all of 2025 and were renewed for 2026. The AFPS Agreement, together with any Fee Amendments signed by you and/or your financial advisor as required, represents the entire Agreement between you and Ameriprise Financial Services. Ameriprise Financial Services may amend the Agreement by providing written notice to you of the amendment. Unless you object to the amendment after receiving written notice of the changes, the amendment will become a part of the Agreement. Notwithstanding the foregoing, any increase to the fee you pay for AFPS must be in writing and signed by you and Ameriprise Financial Services. Effective December 2014, the Company and the Parent entered a secured demand note collateral and subordinated loan agreement for $200,000 at a stated interest rate of 0.10% due to mature on December 15, 2026, with the option to renew in one-year increments in perpetuity. The secured demand note collateral and subordinated loan agreement was renewed for 2026. The AFPS Agreement does not need to be re-signed to reflect changes except as noted below. A new AFPS Agreement is required in these instances: The Company paid dividends to the Parent of $1,365,000 in 2025. • You and your financial advisor determine to restart the initial year of service. • There is a change in owners or parties to the AFPS Agreement, except when there is a death of one of the joint owners. • There is a lapse of a prior AFPS Agreement (for example, if fees have not been paid for more than one year). The Parent’s Incentive Compensation Plan primarily grants restricted stock awards and stock units that generally vest ratably over three to four years to the Company’s employees. Vesting of restricted awards and units may be accelerated based on age and length of service. Compensation expense for restricted stock awards is based on the market price of the Parent’s stock on the date of grant and is amortized on a straight-line basis over the vesting period. Quarterly dividends are paid on restricted stock and stock units during the vesting period and are not subject to forfeiture. A summary of the Company's restricted stock award and stock unit activity is presented below: About estate or trust beneficiaries as AFPS clients — If you are an AFPS client and a beneficiary of an estate or trust that is also an AFPS client serviced by your financial advisor, you understand, acknowledge and agree that (1) there may be a conflict when your financial advisor is providing advice to you as the beneficiary of an estate or trust, as the estate’s or trust’s interest may not be the same as your interest as beneficiary; and (2) when servicing the estate or trust, your financial advisor cannot put your interest as beneficiary ahead of his or her obligation to act in the best interests of the estate or trust. About power of attorney appointments — If you are an Attorney-in-Fact pursuant to a Power of Attorney for the client, you understand, acknowledge and agree that: (1) the financial planning services will be based on the information provided to us by the client and/or you as attorney-in-fact regarding the client’s financial situation; (2) you will provide us with complete and accurate information, to the best of your knowledge; and (3) with the service the client or you as attorney-in-fact purchases the financial advisor is not obligated to make recommendations or give financial advice that, in the sole judgment of the financial advisor, would be impracticable, unsuitable, unattainable or undesirable for the client. We strongly recommend you seek advice from legal and tax counsel before implementing suggested planning strategies that involve disposition of assets. We reserve the right to decline business. When servicing the client’s account, the financial advisor cannot put your interests as attorney-in- fact ahead of his or her obligations to act in the best interest of the client. The Parent’s Advisor Group Deferral Plan, which was created in April 2009, allows for employee advisors to receive share- based bonus awards which are subject to future service requirements and forfeitures. The Advisor Group Deferral Plan is an unfunded non-qualified deferred compensation plan under section 409A of the Internal Revenue Code. The Advisor Group Deferral Plan also gives qualifying employee advisors the choice to defer a portion of their base salary or commissions. This deferral can be in the form of share-based awards or other investment options. Deferrals are not subject to future service requirements or forfeitures. Awards granted under the Advisor Group Deferral Plan may be settled in cash and/or shares of the Parent's common stock according to the award's terms. Disclosure of interest and capacity As of December 31, 2025, there were approximately 877,000 shares outstanding under the Advisor Group Deferral Plan, of which 206,210 were fully vested. 11. Subsequent Events As of February 19, 2026, which is the date the financial statements were available to be issued, the Company evaluated events or transactions that may have occurred after the statement of financial condition date for potential recognition or disclosure. No subsequent events or transactions requiring recognition of disclosure were identified. About advisor compensation — Your financial advisor may recommend that you purchase or sell investments, recommend that you enter into other financial transactions, or provide financial advice regarding financial decisions. You have no obligation to follow any such recommendations or advice. If you implement any such recommendations through Ameriprise Financial Services, then in addition to the AFPS fee described above, your financial advisor will receive fees, commissions or other financial compensation as a result of the transaction and/or advice, as described in the “How our financial advisors get paid” section elsewhere in this Brochure. Such transactions may result in tax consequences for non-qualified accounts. About your agreement — No assignment of the Agreement by Ameriprise Financial Services will be effective without your consent. 10 About your initial proposal and ongoing service — Your financial advisor’s initial recommendations may address only the areas that you have identified as your most immediate needs and priorities. 51 52 Your financial advisor is not obligated to make any recommendations or give any financial advice to you that, in the sole judgment of the financial advisor, would be impracticable, unsuitable, unattainable or undesirable. Your financial advisor provides financial services of the type contemplated in the Agreement, as well as other financial services for a number of clients. Your financial advisor will review the fundamentals of your financial situation; this may include an analysis of your insurance protection coverages. Ameriprise Financial Services does not provide insurance consulting, tax advice, legal advice or document preparation as part of AFPS. Ameriprise Financial Services does not monitor the day-to-day performance of your specific investments. Neither your financial advisor nor Ameriprise Financial Services shall have any liability for your failure to promptly inform your financial advisor of material changes in your financial and economic situation, your investment objectives or results, and any restrictions you wish to propose that may affect the development of your financial plan. About retirement accounts — You agree that your financial advisor may discuss, present or offer ideas for you to consider related to the allocation of your retirement assets and that such communications are offered solely as education, marketing and examples for the purposes of discussion and for your independent consideration, and should not be viewed, construed or relied upon, as investment or fiduciary recommendations or advice under the Employee Retirement Income Security Act of 1974 ("ERISA") or Section 4975 of the Internal Revenue Code of 1986, as amended (the “Internal Revenue Code”). You understand that such communications should not be (and are not intended to be) relied upon as a primary basis for your investment decisions with respect to your retirement assets. Also, if we provide you with a sample or proposed asset allocation, including one that identifies specific securities or other investments, such asset allocation is merely an example of, or a proposal for, the fiduciary advice and recommendations that may potentially be available and should not be relied upon as investment or fiduciary advice or a recommendation under ERISA or the Internal Revenue Code. Also, to the extent an asset allocation service identifies any specific investment alternative for your retirement assets, please note that other investment alternatives with similar risk and return characteristics may be available to you. Arbitration/Class Action Waiver Any consumer dispute, controversy or claim arising out of the investment advisory services offered or delivered pursuant to this Agreement (including any disputes, controversies or claims involving the employees, franchisees or independent contractors of Ameriprise Financial Services, whether past or present) shall be resolved solely by arbitration on an individual basis in accordance with the Rules of the American Arbitration Association (“AAA”) for consumers disputes or the most applicable type of dispute, and the arbitrator(s) will decide all issues related to any such controversy or claim, including whether any controversy or claim is subject to this arbitration agreement. Judgment upon the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof. The parties agree that venue and personal jurisdiction for such an action upon the arbitration award is proper in Minneapolis, Minnesota. Unless otherwise agreed to by all of the parties to the arbitration (including without limitation Ameriprise Financial Services and you), AAA shall be the sole venue for resolving claims arising out of or relating to the investment advisory services, and all of the parties to the arbitration (including without limitation Ameriprise Financial Services and you) irrevocably waive trial by jury or by judge in any action, proceeding or counterclaim, whether at law or in equity. About Sweep Programs — If you decide to implement the recommendations you receive through Ameriprise Financial Services, you understand and agree that cash balances in your Managed Account(s) or Ameriprise brokerage account(s), as applicable, will be held in the money settlement option made available to you by Ameriprise Financial and that you agreed to in your Relationship Application for Managed Accounts or the Brokerage Application for Ameriprise brokerage accounts, as applicable. These money settlement options are further described in the Disclosure Brochure and include a free credit balance (Ameriprise Cash) held in your account or a program that provides for the automatic deposit or “sweep” of uninvested cash balances in your account (each, a “Sweep Program”). You understand we offer a Sweep Program as a short-term feature that is intended to hold cash for the purposes described in the Disclosure Brochure. You agree that you will not maintain a cash balance in your Ameriprise account(s) solely for the purpose of receiving interest or obtaining FDIC insurance or SIPC coverage. You understand that Ameriprise Financial offers other investments products that offer capital preservation with a higher rate of return than a Sweep Program and are a more appropriate place to invest cash than maintaining a significant cash balance in your account for an extended period. You understand and acknowledge that if your Sweep Program consists of money market mutual funds then your Sweep Program will have its own expenses. You further understand and acknowledge that the banks that participate in the FDIC insured interest-bearing bank deposit Sweep Programs offered by our affiliated clearing firm, AEIS, compensate AEIS for deposits placed at the bank(s) or reimburse AEIS for expenses it incurs in providing the Sweep Program, and that our affiliate, Ameriprise Bank, FSB, is a participant in these programs. AEIS receives marketing support payments from the underlying money market mutual funds, if eligible, used as the Sweep Program for your account. The availability of each Sweep Program depends on your account type and ownership. You acknowledge that you have received and have had the opportunity to review the (i) Sweep Program and Expenses section of the Disclosure Brochure; (ii) Money Settlement Options section of the Ameriprise Brokerage Client Agreement, and (iii) Other Important Brokerage Disclosures document, which fully describe our insured bank deposit programs. You can always obtain the current version of the Disclosure Brochure, Brokerage Client Agreement and the Other Important Brokerage Disclosures by visiting our website at ameriprise.com/disclosures or by calling our service line at 800.862.7919. Federal and state statutes of limitation, repose, and/or other rules, laws, or regulations impose time limits for bringing claims in federal and state court actions and proceedings, and the parties agree that such time limits shall apply to any arbitration proceeding filed pursuant to this provision. The parties agree that the time limits applicable to the arbitration will be the time limits that would be applied by the courts in the state in which the arbitration hearing will be held. However, if you do not reside in the United States, the statutes of limitation, repose, and/or other rules, laws or regulations imposing time limits applicable to the arbitration will be those that would be applied in the state where the Ameriprise Financial Services office servicing your account(s) is located. Any disputes related to these time limits will be determined by the arbitrator(s). This paragraph does not constitute a waiver of any right of private claim or cause of action provided by the Investment Advisers Act of 1940, as amended. All parties to this Agreement are giving up the right to sue each other in court, including any right to trial by jury. Arbitration of a claim under this Paragraph shall be only on an individual basis. There shall be no right or authority for any claims to be arbitrated or litigated on a class action basis or bases involving claims brought in a purported representative capacity on behalf of the general public, clients or other persons similarly situated. The arbitrator’s authority to resolve claims is limited to claims between the parties to the arbitration (including you and Ameriprise Financial Services) alone, and the arbitrator’s authority to make awards is limited to the parties to the arbitration (including to you and Ameriprise Financial Services) alone. Furthermore, claims brought by you against Ameriprise Financial Services, its employees, franchisees, or independent contractors, or by Ameriprise Financial Services against you, may not be joined or consolidated in arbitration or in a court action with claims brought by or against someone other than you, unless agreed to in writing by both you and Ameriprise Financial Services. The parties agree that this predispute arbitration provision is governed by the Federal Arbitration Act. About insurance and annuity products — You understand and acknowledge that with the sale of life, disability income and long-term care insurance and annuity products, Ameriprise Financial Services and the financial advisor from whom you purchase the product are the appointed agents of the insurer and receive compensation from the insurer for the sale and servicing of that product. This compensation is separate from and in addition to the AFPS fee you pay for AFPS and may vary depending on the type or size of the insurance or annuity product that you purchase, the insurer that issues the product, the total number of life, disability income and long-term care insurance and annuity products sold by Ameriprise Financial Services and/or your financial advisor for that insurer, and other factors. This compensation typically will increase based on the size of the product that you purchase, or as the total payments that you make on that product increase. Generally, the compensation that Ameriprise Financial Services and your financial advisor will receive depends on a relative compensation formula. That is, compensation received from the sale of life, disability income and long-term care insurance and annuity products is often greater than from the sale of other financial products such as mutual funds. As a result, Ameriprise Financial Services and your financial advisor typically will have a financial incentive to recommend that you purchase a life, disability income or long-term care insurance product or annuity product instead of another financial product such as a mutual fund. You are not obligated to purchase an insurance product from Ameriprise Financial Services or your financial advisor. 53 54 Your financial advisor is not obligated to make any recommendations or give any financial advice to you that, in the sole judgment of the financial advisor, would be impracticable, unsuitable, unattainable or undesirable. Your financial advisor provides financial services of the type contemplated in the Agreement, as well as other financial services for a number of clients. Your financial advisor will review the fundamentals of your financial situation; this may include an analysis of your insurance protection coverages. Ameriprise Financial Services does not provide insurance consulting, tax advice, legal advice or document preparation as part of AFPS. Ameriprise Financial Services does not monitor the day-to-day performance of your specific investments. Neither your financial advisor nor Ameriprise Financial Services shall have any liability for your failure to promptly inform your financial advisor of material changes in your financial and economic situation, your investment objectives or results, and any restrictions you wish to propose that may affect the development of your financial plan. About retirement accounts — You agree that your financial advisor may discuss, present or offer ideas for you to consider related to the allocation of your retirement assets and that such communications are offered solely as education, marketing and examples for the purposes of discussion and for your independent consideration, and should not be viewed, construed or relied upon, as investment or fiduciary recommendations or advice under the Employee Retirement Income Security Act of 1974 ("ERISA") or Section 4975 of the Internal Revenue Code of 1986, as amended (the “Internal Revenue Code”). You understand that such communications should not be (and are not intended to be) relied upon as a primary basis for your investment decisions with respect to your retirement assets. Also, if we provide you with a sample or proposed asset allocation, including one that identifies specific securities or other investments, such asset allocation is merely an example of, or a proposal for, the fiduciary advice and recommendations that may potentially be available and should not be relied upon as investment or fiduciary advice or a recommendation under ERISA or the Internal Revenue Code. Also, to the extent an asset allocation service identifies any specific investment alternative for your retirement assets, please note that other investment alternatives with similar risk and return characteristics may be available to you. Arbitration/Class Action Waiver Any consumer dispute, controversy or claim arising out of the investment advisory services offered or delivered pursuant to this Agreement (including any disputes, controversies or claims involving the employees, franchisees or independent contractors of Ameriprise Financial Services, whether past or present) shall be resolved solely by arbitration on an individual basis in accordance with the Rules of the American Arbitration Association (“AAA”) for consumers disputes or the most applicable type of dispute, and the arbitrator(s) will decide all issues related to any such controversy or claim, including whether any controversy or claim is subject to this arbitration agreement. Judgment upon the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof. The parties agree that venue and personal jurisdiction for such an action upon the arbitration award is proper in Minneapolis, Minnesota. Unless otherwise agreed to by all of the parties to the arbitration (including without limitation Ameriprise Financial Services and you), AAA shall be the sole venue for resolving claims arising out of or relating to the investment advisory services, and all of the parties to the arbitration (including without limitation Ameriprise Financial Services and you) irrevocably waive trial by jury or by judge in any action, proceeding or counterclaim, whether at law or in equity. About Sweep Programs — If you decide to implement the recommendations you receive through Ameriprise Financial Services, you understand and agree that cash balances in your Managed Account(s) or Ameriprise brokerage account(s), as applicable, will be held in the money settlement option made available to you by Ameriprise Financial and that you agreed to in your Relationship Application for Managed Accounts or the Brokerage Application for Ameriprise brokerage accounts, as applicable. These money settlement options are further described in the Disclosure Brochure and include a free credit balance (Ameriprise Cash) held in your account or a program that provides for the automatic deposit or “sweep” of uninvested cash balances in your account (each, a “Sweep Program”). You understand we offer a Sweep Program as a short-term feature that is intended to hold cash for the purposes described in the Disclosure Brochure. You agree that you will not maintain a cash balance in your Ameriprise account(s) solely for the purpose of receiving interest or obtaining FDIC insurance or SIPC coverage. You understand that Ameriprise Financial offers other investments products that offer capital preservation with a higher rate of return than a Sweep Program and are a more appropriate place to invest cash than maintaining a significant cash balance in your account for an extended period. You understand and acknowledge that if your Sweep Program consists of money market mutual funds then your Sweep Program will have its own expenses. You further understand and acknowledge that the banks that participate in the FDIC insured interest-bearing bank deposit Sweep Programs offered by our affiliated clearing firm, AEIS, compensate AEIS for deposits placed at the bank(s) or reimburse AEIS for expenses it incurs in providing the Sweep Program, and that our affiliate, Ameriprise Bank, FSB, is a participant in these programs. AEIS receives marketing support payments from the underlying money market mutual funds, if eligible, used as the Sweep Program for your account. The availability of each Sweep Program depends on your account type and ownership. You acknowledge that you have received and have had the opportunity to review the (i) Sweep Program and Expenses section of the Disclosure Brochure; (ii) Money Settlement Options section of the Ameriprise Brokerage Client Agreement, and (iii) Other Important Brokerage Disclosures document, which fully describe our insured bank deposit programs. You can always obtain the current version of the Disclosure Brochure, Brokerage Client Agreement and the Other Important Brokerage Disclosures by visiting our website at ameriprise.com/disclosures or by calling our service line at 800.862.7919. Federal and state statutes of limitation, repose, and/or other rules, laws, or regulations impose time limits for bringing claims in federal and state court actions and proceedings, and the parties agree that such time limits shall apply to any arbitration proceeding filed pursuant to this provision. The parties agree that the time limits applicable to the arbitration will be the time limits that would be applied by the courts in the state in which the arbitration hearing will be held. However, if you do not reside in the United States, the statutes of limitation, repose, and/or other rules, laws or regulations imposing time limits applicable to the arbitration will be those that would be applied in the state where the Ameriprise Financial Services office servicing your account(s) is located. Any disputes related to these time limits will be determined by the arbitrator(s). This paragraph does not constitute a waiver of any right of private claim or cause of action provided by the Investment Advisers Act of 1940, as amended. All parties to this Agreement are giving up the right to sue each other in court, including any right to trial by jury. Arbitration of a claim under this Paragraph shall be only on an individual basis. There shall be no right or authority for any claims to be arbitrated or litigated on a class action basis or bases involving claims brought in a purported representative capacity on behalf of the general public, clients or other persons similarly situated. The arbitrator’s authority to resolve claims is limited to claims between the parties to the arbitration (including you and Ameriprise Financial Services) alone, and the arbitrator’s authority to make awards is limited to the parties to the arbitration (including to you and Ameriprise Financial Services) alone. Furthermore, claims brought by you against Ameriprise Financial Services, its employees, franchisees, or independent contractors, or by Ameriprise Financial Services against you, may not be joined or consolidated in arbitration or in a court action with claims brought by or against someone other than you, unless agreed to in writing by both you and Ameriprise Financial Services. The parties agree that this predispute arbitration provision is governed by the Federal Arbitration Act. About insurance and annuity products — You understand and acknowledge that with the sale of life, disability income and long-term care insurance and annuity products, Ameriprise Financial Services and the financial advisor from whom you purchase the product are the appointed agents of the insurer and receive compensation from the insurer for the sale and servicing of that product. This compensation is separate from and in addition to the AFPS fee you pay for AFPS and may vary depending on the type or size of the insurance or annuity product that you purchase, the insurer that issues the product, the total number of life, disability income and long-term care insurance and annuity products sold by Ameriprise Financial Services and/or your financial advisor for that insurer, and other factors. This compensation typically will increase based on the size of the product that you purchase, or as the total payments that you make on that product increase. Generally, the compensation that Ameriprise Financial Services and your financial advisor will receive depends on a relative compensation formula. That is, compensation received from the sale of life, disability income and long-term care insurance and annuity products is often greater than from the sale of other financial products such as mutual funds. As a result, Ameriprise Financial Services and your financial advisor typically will have a financial incentive to recommend that you purchase a life, disability income or long-term care insurance product or annuity product instead of another financial product such as a mutual fund. You are not obligated to purchase an insurance product from Ameriprise Financial Services or your financial advisor. 53 54 Privacy Notices “ABISA” means Ameriprise Bank Insured Sweep Account. Glossary • Protecting your privacy is a top priority. Visit our Privacy, Security & Fraud Center at Ameriprise.com to understand our notices for how we collect, use, share and protect your personal information as well as to get answers to privacy-related questions. • “Account” or “Managed Account” means an Ameriprise investment advisory account for which you pay an ongoing Asset-based Fee. “Advisers Act” means the Investment Advisers Act of 1940, as amended. • Married person as AFPS individual client: If you are married and participating in an AFPS engagement as an individual, your spouse is not a party to the Agreement. Your analysis and recommendations will be based on information that you provide regarding your financial goals, needs, and priorities. • “Advisory Shares” means advisory, institutional or other share classes that do not have a sales load, do not have a sales load and do not assess 12b-1 shareholder servicing fees. “AEIS” means American Enterprise Investment Services Inc. • “AFIG” means Ameriprise Financial Institutions Group. • “AFPS” means Ameriprise Financial Planning Service. • • “AFPS Agreement” means the applicable financial planning service agreement, as it may be amended from time to time, that includes the specific terms under which the client will receive those services. “AFPS fee” means the financial planning fee you pay for AFPS. • • “AIMMA” means Ameriprise Insured Money Market Account, an interest-bearing product sweeping cash into FDIC-insured depository institutions. “Ameriprise” means Ameriprise Financial, Inc. • • “Ameriprise Financial Services,” “Ameriprise Financial,” “AFSI,” “we,” “us” or “our” means Ameriprise Financial Services, LLC. “ATC” means Ameriprise Trust Company. • • “Available for Sale Firms” are firms that sponsor or manage mutual fund options to whom IRG will proceed to look for if a suitable mutual fund recommendation for a particular asset class cannot be found within the Full Participation Firms’ offerings. “Bank” means Ameriprise Bank, FSB. • • “Brochure” or “Disclosure Brochure” means Ameriprise Financial Planning Service Client Disclosure Brochure. “CD” means a Certificate of Deposit. • “CFP®” means Certified Financial Planner™ professional. • “CFTC” means the Commodity Futures Trading Commission. • • “CMIA” or “Columbia Management Investment Advisers” means Columbia Management Investment Advisers, LLC. • “Columbia” or “Columbia Management” refers, collectively, to Columbia Management Investment Advisers, LLC and Columbia Wanger Asset Management, LLC. • “Columbia Funds” means investment companies and other funds advised by affiliated companies, Columbia Management Investment Advisers, LLC and Columbia Wanger Asset Management, LLC. “CTA” means Commodity Trading Advisor. • “Effective Date” means the effective date of the AFPS Agreement. • “Engagement Period” means a new twelve-month period for the financial planning service. • “ERISA” means the Employee Retirement Income Security Act of 1974, as amended. • “FASB” means the Financial Accounting Standards Board. • “FDIC” means the Federal Deposit Insurance Corporation. • 55 56 Privacy Notices “ABISA” means Ameriprise Bank Insured Sweep Account. Glossary • Protecting your privacy is a top priority. Visit our Privacy, Security & Fraud Center at Ameriprise.com to understand our notices for how we collect, use, share and protect your personal information as well as to get answers to privacy-related questions. • “Account” or “Managed Account” means an Ameriprise investment advisory account for which you pay an ongoing Asset-based Fee. “Advisers Act” means the Investment Advisers Act of 1940, as amended. • Married person as AFPS individual client: If you are married and participating in an AFPS engagement as an individual, your spouse is not a party to the Agreement. Your analysis and recommendations will be based on information that you provide regarding your financial goals, needs, and priorities. • “Advisory Shares” means advisory, institutional or other share classes that do not have a sales load, do not have a sales load and do not assess 12b-1 shareholder servicing fees. “AEIS” means American Enterprise Investment Services Inc. • “AFIG” means Ameriprise Financial Institutions Group. • “AFPS” means Ameriprise Financial Planning Service. • • “AFPS Agreement” means the applicable financial planning service agreement, as it may be amended from time to time, that includes the specific terms under which the client will receive those services. “AFPS fee” means the financial planning fee you pay for AFPS. • • “AIMMA” means Ameriprise Insured Money Market Account, an interest-bearing product sweeping cash into FDIC-insured depository institutions. “Ameriprise” means Ameriprise Financial, Inc. • • “Ameriprise Financial Services,” “Ameriprise Financial,” “AFSI,” “we,” “us” or “our” means Ameriprise Financial Services, LLC. “ATC” means Ameriprise Trust Company. • • “Available for Sale Firms” are firms that sponsor or manage mutual fund options to whom IRG will proceed to look for if a suitable mutual fund recommendation for a particular asset class cannot be found within the Full Participation Firms’ offerings. “Bank” means Ameriprise Bank, FSB. • • “Brochure” or “Disclosure Brochure” means Ameriprise Financial Planning Service Client Disclosure Brochure. “CD” means a Certificate of Deposit. • “CFP®” means Certified Financial Planner™ professional. • “CFTC” means the Commodity Futures Trading Commission. • • “CMIA” or “Columbia Management Investment Advisers” means Columbia Management Investment Advisers, LLC. • “Columbia” or “Columbia Management” refers, collectively, to Columbia Management Investment Advisers, LLC and Columbia Wanger Asset Management, LLC. • “Columbia Funds” means investment companies and other funds advised by affiliated companies, Columbia Management Investment Advisers, LLC and Columbia Wanger Asset Management, LLC. “CTA” means Commodity Trading Advisor. • “Effective Date” means the effective date of the AFPS Agreement. • “Engagement Period” means a new twelve-month period for the financial planning service. • “ERISA” means the Employee Retirement Income Security Act of 1974, as amended. • “FASB” means the Financial Accounting Standards Board. • “FDIC” means the Federal Deposit Insurance Corporation. • 55 56 “FINRA” means the Financial Industry Regulatory Authority. • “Full Participation Firms” are mutual fund firms that fully participate in the Mutual Fund Program. • • “Health Savings Account” refers to a participant-directed tax-advantaged savings account used to pay eligible health care costs. “Internal Revenue Code” means the Internal Revenue Code of 1986, as amended. • “IRA” means an individual retirement account. • “IRG” means Ameriprise Investment Research Group. • • “Mutual Fund Program” means Ameriprise Financial Mutual Fund Program, the structure formed by the payment of the mutual fund and 529 plan marketing and sales support payments that are received from certain mutual fund firms. “NFA” means National Futures Association. • • “Non-Advisory Shares” refer to mutual fund share classes that do not match the Advisory Share class offered by Sponsor for a particular mutual fund. “NYSE: AMP” means Ameriprise Financial, Inc. stock symbol on the New York Stock Exchange. • • “Outside Workplace Retirement Plan” means additional retirement plan assets held outside of Ameriprise Financial Services in a participant-directed defined contribution plan. “Program” means each investment advisory program offered by Ameriprise Financial Services. • • “RiverSource” refers, collectively, to RiverSource Life Insurance Company and RiverSource Life Insurance Co. of New York. “SEC” means the United States Securities and Exchange Commission. • “SIPC” means the Securities Investor Protection Corporation. • PAGE INTENTIONALLY LEFT BLANK • “Solicitor” means individual professional, professional firm, and select corporate, institutional or membership organization to whom compensation is paid for referral of clients or members to Ameriprise Financial Services for its financial advisory services. • “Sponsor” refers to Ameriprise Financial Services when acting as sponsor of an Investment Advisory Program in connection with a Managed Account. “Starting Point List” means mutual funds and ETF recommended list developed by IRG. • • “Sweep Program” means money settlement feature offered by Ameriprise Financial Services that is intended to hold cash. • “Third Party Financial Institutions” means third-party financial institutions such as community banks, credit unions, credit union service organizations and Farm Credit Services with whom Ameriprise Financial Services may form alliances and networking arrangements with to allow its financial advisors to offer financial planning services and certain other non-deposit investment and insurance products and services, to retail customers/members of the Third Party Financial Institutions. • “Third Party Payments” means the portion of investment costs paid to AEIS by third parties who manage, sponsor or distribute investment products held in your Managed Account. 57 5 7 “FINRA” means the Financial Industry Regulatory Authority. • “Full Participation Firms” are mutual fund firms that fully participate in the Mutual Fund Program. • • “Health Savings Account” refers to a participant-directed tax-advantaged savings account used to pay eligible health care costs. “Internal Revenue Code” means the Internal Revenue Code of 1986, as amended. • “IRA” means an individual retirement account. • “IRG” means Ameriprise Investment Research Group. • • “Mutual Fund Program” means Ameriprise Financial Mutual Fund Program, the structure formed by the payment of the mutual fund and 529 plan marketing and sales support payments that are received from certain mutual fund firms. “NFA” means National Futures Association. • • “Non-Advisory Shares” refer to mutual fund share classes that do not match the Advisory Share class offered by Sponsor for a particular mutual fund. “NYSE: AMP” means Ameriprise Financial, Inc. stock symbol on the New York Stock Exchange. • • “Outside Workplace Retirement Plan” means additional retirement plan assets held outside of Ameriprise Financial Services in a participant-directed defined contribution plan. “Program” means each investment advisory program offered by Ameriprise Financial Services. • • “RiverSource” refers, collectively, to RiverSource Life Insurance Company and RiverSource Life Insurance Co. of New York. “SEC” means the United States Securities and Exchange Commission. • “SIPC” means the Securities Investor Protection Corporation. • PAGE INTENTIONALLY LEFT BLANK • “Solicitor” means individual professional, professional firm, and select corporate, institutional or membership organization to whom compensation is paid for referral of clients or members to Ameriprise Financial Services for its financial advisory services. • “Sponsor” refers to Ameriprise Financial Services when acting as sponsor of an Investment Advisory Program in connection with a Managed Account. “Starting Point List” means mutual funds and ETF recommended list developed by IRG. • • “Sweep Program” means money settlement feature offered by Ameriprise Financial Services that is intended to hold cash. • “Third Party Financial Institutions” means third-party financial institutions such as community banks, credit unions, credit union service organizations and Farm Credit Services with whom Ameriprise Financial Services may form alliances and networking arrangements with to allow its financial advisors to offer financial planning services and certain other non-deposit investment and insurance products and services, to retail customers/members of the Third Party Financial Institutions. • “Third Party Payments” means the portion of investment costs paid to AEIS by third parties who manage, sponsor or distribute investment products held in your Managed Account. 57 5 7 About Ameriprise A tradition of commitment since 1894. A legacy of putting clients first. For more than 130 years, Ameriprise has been committed to putting our clients' needs first. Our advisors develop ongoing one-to-one relationships and take time to understand what's truly important to clients and their families. We offer a comprehensive approach to financial planning that helps our clients feel confident, connected and in control of their financial life. Ameriprise® Financial Planning Service Client Disclosure Brochure (Form ADV Part 2A) March 2026 This Brochure provides information about the qualifications and business practices of Ameriprise Financial Services, LLC. If you have any questions about the contents of this Brochure, please consult with your financial advisor or contact us at 800.862.7919 between 7 a.m. and 6 p.m. Central time. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Ameriprise Financial Services, LLC’s California insurance license number is 0684538. Additional information about Ameriprise Financial Services, LLC also is available on the SEC’s website at adviserinfo.sec.gov. Ameriprise Financial Services, LLC 70400 Ameriprise Financial Center Minneapolis, MN 55474 ameriprise.com Financial Planning | Retirement | Investments | Insurance | Banking Ameriprise Financial 70400 Ameriprise Financial Center, Minneapolis, MN 55474 This Brochure provides information about the qualifications and business practices of Ameriprise Financial Services, LLC and the Ameriprise Financial Planning Service. If you have any questions about the contents of this Brochure, please consult with your financial advisor or contact us at 800.862.7919 between 7 a.m. and 6 p.m. Central time. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Investment advisory services and products are made available through Ameriprise Financial Services, LLC, a registered investment adviser. Ameriprise Financial Services, LLC. Member FINRA and SIPC. Additional information about Ameriprise Financial Services, LLC also is available on the SEC’s website at adviserinfo.sec.gov. © 2026 Ameriprise Financial, Inc. All rights reserved 94003 AM (03/26) 8

Additional Brochure: AMERIPRISE FINANCIAL PLANNING SERVICES - FLEXIBLE SERVICE SUPPLEMENT (2026-03-27)

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Flexible Service Supplement to Ameriprise® Financial Planning Service Client Disclosure Brochure (Form ADV Part 2A) Dated March 2026 Update Dated March 2026 The Flexible Service Program is offered in addition to those services described in the Ameriprise® Financial Planning Service Client Disclosure Brochure (Form ADV Part 2A). All information contained in the Brochure remains the same with exception of the language noted below. To help you better understand this information, headings and subheadings in this update generally coincide with those in the Brochure. If there is any conflict between this update and the Brochure, the update supersedes the Brochure. Under the heading “AFPS planning goals” (On page 2, add the following language to the end of the last paragraph.) Certain Flexible Services (defined below) that you receive may not require your financial advisor to review the financial fundamentals. Under the heading “Additional financial planning areas” (On page 2, add the following language) Ameriprise Financial Services offers a flexible services program (“Program” or “Flexible Services”) tailored to high-net-worth individuals and other individuals with complex needs; businesses; and nonprofit organizations. These customized, flexible services are provided by a select number of financial advisors who meet certain eligibility and suitability standards, and who are authorized to participate in the Program. Not all Ameriprise financial advisors are approved to offer Flexible Services. The breadth and nature of the Flexible Services provided will depend on your specific needs as discussed and agreed to with you. Flexible Services for high-net-worth individuals and other individuals with complex needs include services such as outsourcing lifestyle management, expense management, administrative accounting, bookkeeping and other personal (non- investment advisory) services. Flexible Services for businesses and nonprofit organizations may include services such as: Business Operations Planning – Analyzing go-to market strategies for start-up businesses; identifying business-client service models; assessing staffing and technology needs; and helping to develop business plans and marketing strategies. Consulting Services – Consulting Services may be one-time or project-based business consulting and financial planning services and may include engaging other professionals to provide additional services you may require. Under the heading “Initial Recommendations” (On page 3, replace the first sentence of the first paragraph with the following language) In the first year following the effective date of the Agreement, described below, your financial advisor will work with you to identify and prioritize your objectives, and gather and analyze information. Throughout the year, you and your financial advisor may focus on tracking progress to goals, addressing other financial planning topics, and beginning to act on recommendations as appropriate. (On page 3, add the following sentence to the end of the second paragraph) For Flexible Services, the scope of the services you receive will be agreed upon by you and your financial advisor and reflected in an engagement letter you receive from your advisor. Depending on the arrangement, the services you receive may not include the entire financial planning process, such as written recommendations or address the fundamentals of your financial situation. Under the heading “Ongoing relationship” (On page 4, add the following language) Some Flexible Services, such as Consulting Services, are not ongoing. You and your advisor should terminate the Agreement upon final consultation or at the conclusion of a specified project. Under the heading “Changing your planning goals” (On page 4, add the following language) Your financial advisor may provide additional Flexible Services over time, depending on your needs and circumstances. Under the heading “Implementation of your financial planning recommendations” (On page 4, add the following language) The Flexible Services you receive may include engaging other professionals and service providers. In certain situations, this may require you to enter a separate agreement with the professional or service provider. Under the heading “Fees and Compensation” (On page 8, replace the second paragraph with the following language) Typically, the minimum annual fee for each Agreement Engagement Period for Flexible Services is $10,000. The minimum annual fee may vary depending on several factors, including the complexity of your needs and services. Your fee for Consulting Services may be a one-time charge based on the project. Depending on the nature of the Flexible Service, the fee may cover investment advisory and non- investment advisory services. You may also pay fees to other professionals or service providers with whom you have a separate arrangement. (On page 9, add the following language to the end of the first paragraph) The Flexible Services program is not available as part of a consolidated advisory fee relationship offered in the Combined Disclosure Brochure. Under the heading “Types of Clients” (On page 13, add the following paragraph) The Flexible Services Program is designed for high-net-worth and other individuals who have complex needs, businesses and nonprofit organizations. Please keep this Supplement with your copy of the Brochure, service agreement and amendments. © 2026 Ameriprise Financial, Inc. All rights reserved. 94003-Flex (03/26)

Additional Brochure: AMERIPRISE MANAGED ACCOUNTS (2026-03-27)

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Ameriprise ® Managed Accounts Client Disclosure Brochure (Wrap Fee Program) (Part 2A Appendix 1 of Form ADV) This Wrap Fee Program Client Disclosure Brochure provides clients with information about the qualifications and business practices of Ameriprise Financial Services, LLC and Ameriprise® Managed Accounts services. If you have any questions about the contents of this Disclosure Brochure, please contact us at 800.862.7919. The information in this Disclosure Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration with the SEC or any state securities authority does not imply a certain level of skill or training. Additional information about Ameriprise Financial Services, LLC is available on the SEC website at www.advisorinfo.sec.gov. March 2026 Sponsor: Ameriprise Financial Services, LLC 70400 Ameriprise Financial Center Minneapolis, MN 55474 ameriprise.com SEC Registration No. 801-28543 413021 AY (03/26) Material Changes This Brochure dated March 2026 is filed as the annual update to the Form ADV Part 2A, Appendix 1 and includes material changes that have occurred since the last annual update of our Brochure in March 2025. Following is a summary of the material changes: June 2025 • The “Fee Information for Managed Account Programs” sub-section of the “Fees and Compensation” section has been updated to include that effective August 2025, Ameriprise Financial Services began charging a Platform Fee on SPS Advantage, SPS Advisor and Active Portfolios® Programs. September 2025 • The “Types of Advisory Service Providers” sub-section of the “Overview of Ameriprise Managed Accounts” section has been updated to add the following definition: o Investment Providers (effective December 2025). Investment Providers for the Active Portfolios® Program construct the recommended holdings for a model investment portfolio according to their specific investment strategy and may include their proprietary mutual funds and/or ETFs in the model investment portfolios. Our affiliate CMIA also participates in the Active Portfolios® Program as an Investment Provider. Each Investment Provider’s disclosure document (Part 2A of Form ADV) is available to you at ameriprise.com/investmentproviders. The Investment Providers provide non- discretionary investment and asset allocation recommendations to the Investment Manager. Investment Providers do not have any investment discretion or trading authority to purchase or sell securities in your Account. The Investment Manager exercises investment discretion for the Active Portfolios® Accounts. Different Investment Providers may arrive at different investment and asset allocation recommendations regarding investments in a certain sector, market capitalization, or other category of investments, depending on the model portfolio’s investment objective. Oversight of the discretionary Investment Manager, Investment Provider and the model portfolio’s investment strategy is provided by the Oversight Committee, as described above. • The “Signature Wealth” sub-section of the “Managed Account Programs and Services” section has been updated to reflect that SMA model investment portfolios will become available in the Program effective on or around December 1, 2025. • The “Signature Wealth” and “Select Separate Account” sub-sections of the “Managed Account Programs and Services” section have each been updated to reflect that concurrent with the addition of SMA model investment portfolios to the Signature Wealth Program in late 2025, certain SMA strategies that are currently available in the Select Separate Account Program will become available in our Signature Wealth Program as our initial step to transition such SMA strategies from the Select Separate Account Program into the Signature Wealth Program. The full transition process will include the following steps: Ameriprise Financial Services will (i) first close the SMA strategy in the Select Separate Account Program to new investments prior to offering the SMA strategy in the Signature Wealth Program; (ii) generally allow pending new accounts for the SMA strategy to continue to be processed in the Select Separate Account Program; and (iii) subsequently migrate existing accounts investing in the SMA strategy from the Select Separate Account Program into the Signature Wealth Program. During this transition, if you currently hold an impacted SMA strategy in an existing Select Separate Account the Platform Fee rate you pay is higher for your Select Separate Account than it would be if you held the same SMA strategy in the Signature Wealth Program. If your Select Separate SMA strategy will go through this transition, Ameriprise Financial Services will notify you. This creates a conflict of interest as Ameriprise Financial Services receives a higher Platform Fee for Select Separate Accounts than we receive for Signature Wealth Accounts, including the transition period when the same SMA strategy is held in both Programs. Ameriprise Financial Services addresses this conflict through a combination of disclosures and by closing any duplicative SMA strategies through the transition process described above. Additionally, the transition process does not impact the Manager Fee that compensates the Advisory Service Provider and does not affect the portion of the Asset-based Fee received by your financial advisor. However, the transition process will result, for a limited period of time, in Sponsor receiving a higher Platform Fee from impacted SMA strategies held within Select Separate Accounts than it would from the same SMA strategy invested in Signature Wealth Accounts. Beginning in the second half of 2026, Ameriprise Financial Services plans to eliminate this conflict of interest by migrating any Select Separate Account with an impacted SMA strategy from the Select Separate Account Program to the Signature Wealth Program, in accordance with the Relationship Agreement. As noted above, if your Select Separate Account SMA strategy is a part of this transition, Ameriprise Financial Services will notify you so that you may work with your financial advisor to transition your Select Separate SMA Account to the Signature Wealth Program at a date of your choosing so that you can benefit sooner from the reduced Platform Fee rate the Signature Wealth Program provides. • The “Active Portfolios®” sub-section of the “Managed Account Programs and Services” section has been updated to reflect that effective on or around December 1, 2025, your current Investment Manager will begin providing investment advisory services as a non-discretionary Investment Provider and will no longer have discretionary authority. All discretionary investment management will be provided by the Signature Wealth Investment Manager, a non-affiliated third-party Advisory Service Provider, which will also become the Investment Manager for all Active Portfolios® Accounts. Investment Providers will provide asset allocation and investment selection recommendations for their specific portfolio(s) to the new Investment Manager. The new Investment Manager will have the discretionary authority to purchase or sell securities or make other investments for your Account, however, you directly own the underlying securities in the portfolio. The new Investment Manager will invest your Account assets into the portfolio you select with your financial advisor and will be responsible for the ongoing investment management and trading of your Active Portfolios® Account, subject to any Reasonable Restrictions or other instructions provided by you. Your financial advisor will continue to provide recommendations regarding which portfolio to hold in your Active Portfolios® Account. The new Investment Manager, not your financial advisor or the Investment Provider, will provide you with discretionary investment management services for your Active Portfolios® Account according to your Account’s target asset allocation and the portfolio you select. March 2026 • The “Cost Reimbursement Services and Third-Party Payments” section was updated to include the following sub-section: o Payments from Investment Providers offering SMA investment portfolios within the Signature Wealth Program. AEIS receives cost reimbursement payments for the sale of SMA investment portfolios offered within the Signature Wealth Program. AEIS receives an asset-based payment of up to 0.04% per year on Ameriprise Financial Services clients’ assets invested in the SMA investment portfolios. If an Investment Provider ceases to make such cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the firm. • The “How our financial advisors get paid” section was retitled “Financial Advisor Compensation and Benefits” and was updated in general for clarity and overall readability as well as the addition of the following sub-section: o Information for certain clients investing in Manager Directed Programs. Your financial advisor must make recommendations based on your best interests without regard to their compensation. The portion of the Advisory Fee shared with your financial advisor is determined by several factors including the total assets their clients (or clients within an advisor team) have invested in Managed Accounts. Independent contractor franchisees (each a "Franchisee") and certain financial institution financial advisors that contract with Ameriprise Financial Services on an independent contractor basis ("AFIG Independent Contractors") will be allocated a larger portion of the Advisory Fee for the Manager Directed Programs than for the SPS Advantage and SPS Advisor Programs. This difference in allocation is a conflict of interest for Franchisee financial advisors, their associate financial advisors and AFIG Independent Contractor financial advisors because there is a greater incentive to recommend the Manager Directed Programs. Ameriprise Financial Services manages this conflict of interest through a combination of policies, training, and disclosure and by supervising the suitability of recommendations made by its financial advisors in accordance with all applicable regulatory requirements. You may request at any time a current copy of this Disclosure Brochure, and if applicable, Part 2A of your Investment Manager’s Form ADV Brochure (as defined below in the Overview of Ameriprise Managed Accounts section of this Disclosure Brochure) from your financial advisor. The current Brochure replaces any earlier version you receive. You may also request copies of the Disclosure Brochure(s) by writing Ameriprise Financial Services, LLC at 2661 Ameriprise Financial Center, Minneapolis, MN 55474, or by calling 800.297.6663. Please retain a copy of this Brochure for your records. Table of Contents Managed Accounts services, fees and compensation ................................................................................. 5-60 Appropriateness of a Managed Account for you ............................................................................................ 5-8 Overview of Ameriprise Managed Accounts ............................................................................................. 8-15 • Advisory Service Providers ...................................................................................................... 15-19 The Ameriprise Custom Advisory Relationship .......................................................................................... 19 Advisory Solution Programs and Services for Managed Accounts ........................................................... 19-38 • SPS Advantage ....................................................................................................................... 24-27 • SPS Advisor ........................................................................................................................... 27-29 • Signature Wealth .................................................................................................................... 29-33 • Active Portfolios® ................................................................................................................... 33-35 • Select Separate Account ......................................................................................................... 35-38 Managed Accounts offered with Envestnet Asset Management, Inc. ........................................................ 39-40 • Vista Separate Account ............................................................................................................... 39 • Investor Unified Account ......................................................................................................... 39-40 • Access Account .......................................................................................................................... 40 Supplementary Managed Accounts Information ..................................................................................... 40-47 Fees and Compensation ...................................................................................................................... 47-55 • Sweep Program and Expenses ................................................................................................. 55-59 Account requirements and types of clients ............................................................................................. 59-60 • Establishing and maintaining Accounts .................................................................................... 59-60 • Terminating a Relationship Agreement ......................................................................................... 60 Client Information provided to Advisory Service Providers ....................................................................... 60-61 Additional Information .............................................................................................................................. 61 • Disciplinary Information .............................................................................................................. 61 • Other financial industry activities and affiliations ...................................................................... 61-64 How we get paid ................................................................................................................................... 64-73 • Cost Reimbursement Services and Third Party Payments ........................................................... 64-71 • Revenue Sources for Ameriprise Financial Services, LLC Financial planning and advisory service fees. ....................................................................................................... 71-72 • Economic benefits of affiliates’ products and services .............................................................. 72-73 Financial Advisor Compensation and Benefits ......................................................................................... 73-81 • Code of Ethics, Participation or Interest in Transactions and Personal Trading ............................ 79-81 Client Referrals and Other Compensation ................................................................................................... 81 • Referral arrangements and other economic benefits ..................................................................... 81 • Review of issuers of financial products .................................................................................... 81-82 • Revenue Sources for RiverSource ................................................................................................ 82 • Revenue Sources for Columbia Management and Threadneedle ..................................................... 82 • Revenue Sources for other Ameriprise Financial, Inc. companies .............................................. 82-83 • Custody ................................................................................................................................ 83-84 • Investment Discretion ................................................................................................................. 84 • Voting Client Securities ............................................................................................................... 84 • Ameriprise Financial Services’ Proxy Voting Policies and Procedures .......................................... 84-85 • Financial Information .................................................................................................................. 85 Glossary ............................................................................................................................................... 86-89 • Ameriprise ® Managed Accounts Services, Fees and Compensation Appropriateness of a Managed Account for you Advisory Solutions allow you to receive ongoing investment advice and feature an asset-based fee structure. The annual Asset-based Fee you pay for your Managed Account is a percentage of the total value of the assets in your Managed Account and as a result, the total amount you pay will increase if the asset value of your Managed Account increases, and vice versa. The Asset-based Fee is assessed monthly and deducted from your Managed Account in advance. This allows you to implement your investment strategy, generally without paying individual trading costs for each trade placed within the Managed Account. Many of the Programs under our Advisory Solutions feature professional portfolio management including asset allocation, risk management, investment selection, tax- harvesting and dynamic account rebalancing. Your financial advisor will provide you with Managed Account monitoring and ongoing advice to develop and maintain your Managed Account(s) investment portfolio, which will be designed to help you meet your financial goals and investment objectives. • Ameriprise Financial Services, LLC (“Ameriprise Financial Services”, “Sponsor,” or “we”) sponsors a wrap fee program (“Advisory Solutions”) offering a variety of investment advisory programs (each a “Program” and collectively the “Programs”). Each Program available within Advisory Solutions has different features and services, supporting a wide array of investment strategies. When you decide upon a Program, you may open an investment advisory account, (“Managed Account”). You will pay an ongoing asset-based fee (“Asset-based Fee"). The Asset-based Fee is a wrap fee. Prior to establishing an Ameriprise® Managed Account, you should carefully review this Wrap Fee Client Disclosure Brochure (“Disclosure Brochure”). If there is any conflict in the description of the investment advisory services or the details regarding fee information between the Ameriprise® Custom Advisory Relationship Agreement (“Relationship Agreement”) and this Disclosure Brochure, the Disclosure Brochure will control. Common terms used throughout this Disclosure Brochure are defined in the “Glossary” section. Ameriprise Financial Services offers the following Programs: Ameriprise brokerage accounts feature a commission-based fee structure where investors typically pay commissions, sales charges and/or other fees on products purchased and sold in your brokerage account. Brokerage accounts enable you to invest in many different types of investments including mutual funds, stocks, bonds, exchange- traded products, unit investment trusts, annuities and alternative investments. Your financial advisor may provide you with point-in-time recommendations related to your investment portfolio and may review your Ameriprise brokerage account; however, your brokerage relationship does not include account monitoring. The performance of your Managed Account(s) will not be monitored on a day-to-day basis. Past performance is no guarantee of future performance. In addition, forecasting of future performance of financial markets may prove to be incorrect. – Ameriprise® Strategic Portfolio Service (SPS) Advantage – Ameriprise® SPS Advisor – Ameriprise® Signature Wealth – Ameriprise® Active Portfolios® – Ameriprise® Select Separate Account – Ameriprise® Investor Unified Account – Ameriprise® Vista Separate Account – Ameriprise® Access Account Information to help you evaluate the benefits, risks, and costs of the investments and services we offer as part of a brokerage relationship, as well as information about material conflicts of interest associated with recommendations we or our financial advisors make to our retail brokerage clients may be found at https://www.ameriprise.com/bestinterest. More detail about the differences between Advisory Solutions and brokerage accounts may be viewed online by visiting www.ameriprise.com/disclosures and expanding the sub- heading “Managed Account Client Disclosure Brochures” and then clicking on “Evaluating differences between brokerage and managed accounts”. Ameriprise Financial Services also offers Ameriprise brokerage accounts. Selecting the account type(s) that best meet your needs is an important decision. There are circumstances where you may benefit from both a Managed Account and a brokerage account for different portions of your investment portfolio. When evaluating the differences between an Ameriprise brokerage account and an Advisory Solution, you should consider the following key differences: 5 for a Program and any Managed Account you open with us can be found in the Managed Account application and Relationship Agreement, the Ameriprise Brokerage Client Agreement, the Other Important Disclosures Document, Working in Your Best Interest – Regulation Best Interest Disclosure, and any other related disclosures and documents, all of which are available from your financial advisor. Please review all applicable information carefully before you make an investment decision and contact your financial advisor if you have any questions about the types of fees and expenses that may be associated with your Managed Account. The costs associated with a Managed Account that you should consider include: The Asset-based Fee that you pay for a Managed Account may be more or less than if you were to purchase the investment products and investment advisory services separately or in a transaction-fee based brokerage account paying commissions and sales-loads. Depending on your individual situation and the frequency and volume of trading, a Managed Account may cost more than a brokerage account, but the reverse could be true as well. Generally, Ameriprise Financial Services, our affiliates, and your financial advisor will receive more revenue from a Managed Account that generates an ongoing revenue stream than a transaction fee-based brokerage account. At the time of Managed Account opening and throughout your relationship we seek to address this conflict of interest through a combination of disclosure and through our policies, procedures and supervision related to the review and determination that a Managed Account is appropriate for you based on your financial and risk profile information and investment objectives (“Client Information”) in accordance with all applicable regulatory requirements. The same or similar services provided to you under the Asset-based Fee may be available to you at a lower fee from another service provider. • Asset-based Fee. This is the ongoing wrap fee you pay for (i) investment advisory services provided by Ameriprise Financial Services and your financial advisor; and (ii) investment management fees charged by the Advisory Service Provider providing advisory services to SMA strategies held in your Managed Account, if applicable. The components of the Asset-based Fee are separately itemized as an Advisory Fee, a Platform Fee and a Manager Fee as further described in the “Fees and Compensation” section. Based on the Program you select, the components of your Asset-based Fee will vary. • Before selecting a Managed Account, you should consider, among other things, the costs and expenses, your investment objectives, and the types of investments you hold and intend to purchase. Discuss with your financial advisor any accounts you may hold elsewhere. Investments and Infrastructure Support Fee and Credit for SPS Advisor Accounts. In addition to your Asset-based Fee, for SPS Advisor Accounts, Ameriprise Financial Services assesses a quarterly asset-based fee of 0.03% of the total advisory assets in your Managed Account. Our affiliate AEIS credits to clients all sub-transfer agency fees and networking fees AEIS receives for SPS Advisor Accounts from mutual fund firms, as further described in the “Fees and Compensation” section. This Investments and Infrastructure Support Credit may be more or less than the Investments and Infrastructure Support Fee. • The total cost to you of a Managed Account will include (1) the Asset-based Fee, a portion of which you negotiate with your financial advisor, and which includes any investment management fees charged by Advisory Service Providers for SMA strategies; (2) for SPS Advisor Accounts, the Investments and Infrastructure Support Fee; (3) Investment Costs; and (4) Additional Fees and Expenses which are any additional transaction related fees that may be incurred in connection with your Managed Account based on the nature of your investments. These costs are summarized below and are discussed in more detail and in the “Fees and Compensation” section. Investment Costs. These are the underlying fees related to investment products you purchase within your Managed Account. These may include investment management fees and distribution fees charged by mutual fund firms and other fees that are disclosed in the fund prospectus or other offering document. These costs are in addition to the Asset- based Fee that you pay directly from your Managed Account. They are paid indirectly by you, for example, as a shareholder in a mutual fund, through the product. They are not a direct fee deducted from your Managed Account. Investment Costs reduce the value of your investment in the product and reduce the investment performance of your Managed Account. Before opening a Managed Account or investing in any Program or investment product, it is your responsibility to understand and consider all fees, expenses and other charges. Specific information concerning the fees and other charges of each investment product in which your Managed Account invests is available in the product’s prospectus or other offering document. Additional fee information 6 the nature of your investments; for example, for Select Separate Account and Managed Accounts offered with Envestnet, if the Investment Manager for the investment strategy you select engages in “step- out trades” you will be assessed any Third Party Execution Fees for these trades as defined and described in the “Brokerage Practices” section; these fees will be in addition to the Asset-Based Fee that you pay to Ameriprise Financial Services and are not compensation to Ameriprise Financial Services or AEIS. In determining whether a Managed Account is appropriate for you at the time of opening the Managed Account and throughout your relationship with Ameriprise Financial Services, you should also consider: • Impact of the total costs of a Managed Account described above on the overall value and net performance of your Managed Account; • Investment Costs apply whether the investment product is sponsored or managed by an unaffiliated third party or by an affiliate of Ameriprise Financial Services, such as CMIA, a wholly owned subsidiary of Ameriprise Financial, Inc., Ameriprise Financial Services’ parent company. When you invest in investment products managed by CMIA, CMIA or its affiliates will receive compensation for managing those investments and for other services they provide based on the amount you invest, just as they would if you invested in CMIA investment products through another service provider. Investment Costs received by CMIA are not direct compensation to Ameriprise Financial Services, however, Ameriprise Financial Services, CMIA and their affiliates receive more revenue, in aggregate, from the purchase of affiliated investment products offered by CMIA than from the purchase of investment products offered by firms that are not affiliated with Ameriprise Financial, Inc. and therefore it is more profitable for Ameriprise Financial Services’ parent company when you purchase or own a CMIA investment product in your Managed Account. Total cost of purchasing and holding any underlying securities, products and services outside of a Managed Account or at another firm, including the anticipated amount of trading; • That you will typically not recover any front-end loads previously paid on mutual funds that are transferred into a Managed Account and you may be possibly subject to contingent-deferred sales charges on mutual funds that charge such a fee if sold or exchanged after they are transferred into a Managed Account. The cost basis on any mutual fund with front-end loads will carry over to any mutual fund positions converted in a tax-free exchange and will be included in the tax calculation of gains and losses for those converted positions held in non-qualified Managed Accounts; • A Managed Account may not be appropriate for you if you prefer a long-term buy-and-hold investment strategy or otherwise purchase mutual funds and other securities infrequently. • Your preferences to be involved in individual investment decisions and your comfort with granting discretion to your financial advisor or other investment managers for investment decisions. • Custodial services provided. • Amount of Assets in your Managed Account. • Third Party Payments. A portion of Investment Costs that you pay indirectly to third parties are subsequently received by our affiliated clearing agent, American Enterprise Investment Services Inc. (“AEIS”), from those third parties as certain cost reimbursement payments and other servicing and account maintenance fees (e.g., sub-transfer agent or networking fees) related to your Managed Account. AEIS also receives marketing support and distribution support payments. For qualified SPS Advisor Accounts, inherited IRAs in qualified SPS Advantage Accounts where a trust has inherited the IRA and Ameriprise Bank acts as trustee of the trust and eligible trustee-directed retirement plans in Select Separate Accounts AEIS either does not collect Third Party Payments or credits them back to client Accounts as described in the “Fees and Compensation” section. Third Party Payments and cost reimbursement services and payments are further described in the “Mutual Fund Share Classes in Managed Accounts”, “Fees and Compensation”, and “Cost Reimbursement Services and Third- Party Payments” sections. These payments are generally funded directly, or indirectly, from Investment Costs. • Your ability to independently select and retain professional asset management services. • You should consider this total compensation • Terms and conditions of the Relationship Agreement. • received by Ameriprise Financial Services and AEIS when evaluating the reasonableness of our fees. The type of investment products (including mutual fund share classes) that are available for purchase in each Advisory Solutions Program. • Additional Fees and Expenses are any additional transaction related fees that may be incurred in connection with your Managed Account based on • How much of your assets you expect to be allocated to cash. Because cash is included in the Asset- 7 (v) for settling transactions in your Managed Account. Available money settlement options include either a free credit balance held in your Managed Account covered by SIPC, or a program that provides for the automatic movement or “sweep” of uninvested cash balances in your Managed Account into the money settlement program (each, a “Sweep Program”). A Sweep Program is not an investment strategy and is not intended as an investment option for you to maintain a significant cash balance for an extended period of time. As noted above, Ameriprise Financial Services offers investment products that offer capital preservation that generally have a higher rate of return for the cash component of your asset allocation than a Sweep Program. The terms of our cash sweep programs can be found in the “Other Important Brokerage Disclosures” document you received when you set up your Managed Account or Relationship, as applicable. For a copy of this document, visit our website at ameriprise.com/disclosures or call our service line at 800.862.7919. • In addition, it is important that you review any applicable mutual fund or ETF prospectus and/or other product offering documents prior to investing to learn about fund expenses, investment minimums, availability of sales charge breakpoints or rights of accumulation and other benefits and costs when purchased outside of a Managed Account. You should consider whether you will be eligible for the sales charge breakpoints, rights of accumulation and other benefits before purchasing or transferring mutual funds into a Managed Account. Overview of Ameriprise® Managed Accounts based Fee for your Managed Account, it will cost you more and Ameriprise Financial Services and our financial advisors will receive more revenue when you hold cash in a Managed Account rather than an Ameriprise brokerage account. It is not recommended to hold large amounts of cash and/or positional money market funds in a Managed Account for extended periods of time. Prior to establishing a Managed Account or as you consider remaining in a Managed Account, and particularly for the SPS Advantage and SPS Advisor Programs, consider whether you have a short-term investment horizon, or whether you are holding cash for asset safety purposes (such as during periods of volatile or uncertain market conditions). In those cases, you should consider and discuss with your financial advisor other investment products within an Ameriprise brokerage account or other commission-based account that may offer capital preservation with a higher rate of return for the cash component of your asset allocation. These investment products include Ameriprise Certificates, brokered certificates of deposit, treasuries and positional money market mutual funds and are a more appropriate choice for investing cash than maintaining a significant cash balance in your Managed Account for an extended period. Not all of these investment products are available or appropriate to hold in large amounts within Managed Accounts. Your financial advisor can provide you with information about the cash management products available to you, including whether it may be appropriate to allocate assets between your Managed Account and an Ameriprise brokerage account. We offer tools on our client website that permit you to transfer cash between your Managed Account and certain other brokerage accounts you maintain at Ameriprise. This may help you avoid the ongoing Asset-based Fee. All Programs, except SPS Advantage, are discretionary investment advisory Programs. Advisory Service Providers with investment selection discretion and SPS Discretionary Advisors (“Discretionary Managers”) have discretionary authority granted by you to (i) select investments for your Managed Account; and (ii) purchase or sell securities or make other investments for your Managed Account without your prior authorization. • You should also review the available money settlement option available to you in your Managed Account. A money settlement option is a feature offered by Ameriprise Financial Services that is primarily intended to hold cash (i) pending investment into your Managed Account; (ii) to cover your Asset-based Fee and if applicable, SPS Advisor Investments and Infrastructure Support Fee; (iii) to cover systematic cash withdrawals you have established for your Managed Account(s); (iv) for certain pre-existing non- qualified SPS Advantage Accounts check writing or debit card activity and to make bill payments (cash management activities); and For the SPS Advisor Program, you authorize one or more financial advisors to exercise discretion regarding the investment selection and asset allocation strategy in your SPS Advisor Account as an SPS Discretionary Advisor. For all other discretionary Programs, specifically Signature Wealth, Active Portfolios® investments, Select Separate Account, Vista Separate Account, Investor Unified Account and Access Account Programs (the “Manager Directed Programs”) use the discretionary investment advisory services of Advisory Service Providers, as described below, which may or may not be 8 Client Rights and Responsibilities affiliated with Ameriprise Financial Services depending upon the Program offered and selected. • • You may impose reasonable security and mutual fund restrictions on any discretionary Managed Account(s) and reasonable sector restrictions (“Reasonable Restrictions”) on Manager Directed Managed Account(s) that you select by completing and signing the appropriate documents and when accepted by Ameriprise Financial Services, your financial advisor or the Investment Manager as described in each Program description within this Disclosure Brochure. • You may not impose restrictions which apply to underlying securities held in any mutual fund, exchange traded fund (“ETF”), closed end fund (“CEF”), unit investment trust (“UIT”) or other pooled investment products. • You are responsible for promptly notifying Ameriprise Financial Services in writing of any changes to these Reasonable Restrictions. Ameriprise Financial Services will determine whether a Managed Account is appropriate for you at the time you seek to open a Managed Account based on information you provide then and thereafter as described in this Disclosure Brochure. Ameriprise Financial Services also reserves the right to limit or close any Managed Account that is used for excessive securities trading. At both Account opening and on an ongoing basis, Ameriprise Financial Services conducts additional monitoring and supervision regarding the appropriateness of a Managed Account for you, including the internal transfer of securities from an existing Ameriprise brokerage account into the Account and the transfer of securities from an external account into the Account. • • You are responsible for providing Ameriprise Financial Services with accurate Client Information when you establish a Custom Advisory Relationship (as described below) and open any Managed Account. Your financial advisor will conduct an annual review of Account appropriateness and document at least annually whether each Managed Account continues to be appropriate. • • Periodically, you will be notified in writing to contact Ameriprise Financial Services if there have been any changes in your Client Information and/or Reasonable Restrictions. It is your responsibility to promptly notify Ameriprise Financial Services, in writing or by contacting your financial advisor, of any changes. Failure to do so could affect the services provided to you. If at any time we determine that your Managed Account or a position(s) within your Managed Account is no longer appropriate for you, your Managed Account may be closed and/or transferred into an Ameriprise brokerage account with thirty (30) days prior notice. See the “Terminating a Managed Account Client Agreement” section for more detail and for information regarding your right to terminate your Managed Account(s). • • Review this Disclosure Brochure and, if applicable, the Advisory Service Provider’s, as defined below, disclosure document (Part 2A of Form ADV) and the investment strategy/portfolio fact sheets prior to investing. • Review available information about the trading practices of the Investment Manager including the average cost of step-out trades for the investment strategy as defined and discussed in the “Brokerage Practices” section. • In SPS Advantage Accounts, review any applicable mutual fund or ETF prospectus, as well as any other offering or disclosure document prior to investing. Overview of Services and Fees You will pay Asset-based Fees and certain other fees and incur expenses and costs when you select a Service, as summarized above. These fees, expenses and costs are further detailed and described in the Managed Accounts charts later in this section and in the “Fees and Compensation” and the “Brokerage Practices” sections. Ameriprise Financial Services and its affiliates receive revenue as described in the “How We Get Paid” section. Your Ameriprise financial advisor receives compensation for investment advisory services provided to you. Importantly, the compensation we pay your financial advisor does not vary depending upon the investment(s) recommended to you within a Managed Account. The sources of financial advisor compensation are described in the “Financial Advisors Compensation & Benefits” section. Ameriprise Financial Services is a registered investment adviser under the Investment Advisers Act of 1940 (the “Advisers Act”) and a broker-dealer under the Securities Exchange Act of 1934 (“Exchange Act”). Investment advisory services are provided by Ameriprise Financial Services as an investment adviser and brokerage 9 • services are provided by Ameriprise Financial Services as an introducing broker. Ameriprise Financial Services and/or its affiliates provide the following services: For Managed Accounts invested in Signature Wealth, providing portfolio construction recommendations using a portfolio proposal that is designed to assist with aligning the recommended portfolio to your Client Information. • • Acting as wrap program sponsor and introducing broker-dealer for the Programs described in this Disclosure Brochure; Potentially serving as a liaison between you and any Advisory Service Provider via Ameriprise Financial Services; • • Providing brokerage services through our affiliate, American Enterprise Investment Services Inc. (“AEIS”), in connection with your Managed Account(s), as described in the Relationship Agreement and the Ameriprise brokerage agreement, Other Important Brokerage and Schedule of Account & Service Fees Documents (collectively referred to as the “Brokerage Agreement”); • Training to and supervision of the Ameriprise financial advisor authorized to use discretion in SPS Advisor (“SPS Discretionary Advisor”); Annually, reviewing your Client Information, investment objectives and any applicable Reasonable Restrictions with you to determine if, based on information you provided, they are still accurate, reviewing with you whether your Managed Account(s) and the investment strategy are still suitable for you, and reviewing with you whether the Asset-based Fee is still appropriate based on the services provided. In the event an Account has more than one owner, this review may occur with one or more of the owners. If applicable, your Attorney-in-Fact may also participate in this review. • Research and/or due diligence regarding the • Periodically reviewing and assessing your Managed Account(s) to answer any questions that you may have. Advisory Service Providers (as defined below) you select to provide discretionary investment advisory services in Manager Directed Programs; • Where requested and as part of your services, • Due diligence of investment products or investment strategies available through the Programs including initial and ongoing analysis based on a quantitative and qualitative process through Ameriprise Financial Services or its affiliates; • The execution of brokerage transactions on an agency or, in limited circumstances, principal basis through Ameriprise Financial Services’ clearing agent, AEIS; • Custodial services; custody of the securities and other assets you hold within a Managed Account and consolidated account reporting regarding those assets; • Regular reports to clients; and • Year-end tax information reporting. Your financial advisor performs certain services on behalf of Ameriprise Financial Services in connection with your Managed Account. A financial advisor will be assigned to each Managed Account and will provide services including: • Assisting you by defining the parameters that will form the basis for the management of your Managed Account(s), including your Client Information; • For Managed Accounts invested in SPS Advantage and SPS Advisor, providing advice in consideration of an asset allocation strategy for the Account; providing guidance relating to both your Managed Account and your additional retirement plan assets not included in the Managed Account and that are held outside of Ameriprise Financial Services in a participant-directed defined contribution plan (e.g., 401(k) plans) (“Outside Workplace Retirement Plan”). Any guidance provided to you is based on information provided by you about your Outside Workplace Retirement Plan and is limited to investments offered through the core line up of funds established by your retirement plan sponsor. Your Outside Workplace Retirement Plan may include investment options not available in our Programs or for which your financial advisor may not have access to detailed information. Neither Ameriprise Financial Services nor your financial advisor is responsible for the selection of the available investment options in your Outside Workplace Retirement Plan. Your financial advisor may not make recommendations related to employer stock that may be available within your Outside Workplace Retirement Plan or with respect to any current portfolio holdings or investment options available through a self- directed brokerage account associated with your Outside Workplace Retirement Plan. You are responsible for placing any transactions recommended by your financial advisor. If you desire ongoing guidance on your Outside Workplace Retirement Plan, it is important that you provide your financial advisor with updated information, including statements and a list 10 they are not always the least expensive share class made available by the mutual fund. of funds available in your Outside Workplace Retirement Plan, on a regular basis. Your investment objectives and risk tolerance for your Outside Workplace Retirement Plan may differ from those of your Managed Account, however any guidance provided for your Outside Workplace Retirement Plan is provided in consideration of the overall investment objectives and risk tolerance of any Managed Accounts you hold. Your financial advisor is instructed to inform Ameriprise Financial Services if your personal and/or financial information have changed. Mutual Fund Share Classes in Managed Accounts Many mutual funds offer institutional shares or other types of shares for a mutual fund that are less expensive than the Advisory Share or other share class we offer for that particular fund in our Advisory Solutions Programs. All share classes of a particular mutual fund represent the same underlying investments, and you may be eligible to purchase a less expensive share class of that mutual fund outside of Ameriprise Financial Services. Because Ameriprise Financial Services chooses to offer only one share class per mutual fund in our Managed Accounts Programs, we limit the availability of other share classes of those mutual funds that you may otherwise be eligible to purchase at a lower cost. For SPS Advantage and SPS Advisor Accounts, you can hold, but not purchase, share classes that are less expensive than the Advisory or other share class we offer for purchase in a particular mutual fund (each, an “Eligible to Hold Share Class”). You may choose to reinvest, or receive in cash, fund dividends and capital gains distributions in such funds if available. An Eligible to Hold Share Class is assessed the Asset-based Fee while held in your Managed Account. Upon transfer into your Managed Account, you can (i) transfer the Eligible to Hold Share Class to an Ameriprise brokerage account; (ii) liquidate the Eligible to Hold Share Class and purchase an Eligible Investment; or (iii) continue to hold the Eligible to Hold Share Class in your Managed Account. When determining which share class to offer as the only share class available for purchases in a particular mutual fund, if a mutual fund offers multiple share classes that do not have a sales-load and do not charge a 12b-1 fee, Ameriprise Financial Services will choose to utilize the share class that permits, pursuant to the fund’s prospectus, the payment of Third Party Payments such as cost reimbursement and other servicing and account maintenance fees, even though certain clients may hold an Eligible to Hold Share Class in a Managed Account or our clients in general are currently eligible for a less expensive share class or may become eligible in the future, including when a mutual fund introduces a lower- cost share class into an existing mutual fund. None of the mutual funds currently offered in Ameriprise Managed Accounts Programs impose a front-end sales charge. For most mutual funds, a share class that does not have a sales-load and does not assess 12b-1 fees (collectively “Advisory Shares”) is offered in all Programs within Advisory Solutions as the only mutual fund share class available for purchase, where available to us through a selling agreement. If not available to us through a selling agreement or if the mutual fund does not offer an Advisory Share class, we offer Class A shares that may pay a 12b-1 fee or a no-load share class that does not have a sales-load but that may pay a 12b-1 fee. 12b-1 fees are paid by a mutual fund out of fund assets to cover distribution expenses and sometimes shareholder service expenses. The share class offered for purchase by Ameriprise Financial Services for a particular mutual fund is the only share class we allow for additional purchase within your Managed Account. As discussed below, any 12b-1 fees received by Ameriprise Financial Services will be promptly rebated to your Managed Account. The share class offered for purchase by Ameriprise Financial Services for each applicable fund is listed in our Mutual Fund Screener Tool. Access the tool by logging into your Ameriprise Secure Site account and navigating to “Trade & Research” and then, “Screeners” followed by “Mutual Fund”. From there, apply the Product Type filter and choose either SPS Advantage or SPS Advisor to view the funds and share classes available for purchase. Specifically, we prefer to offer a share class that makes Third Party Payments that will (i) reimburse our affiliate AEIS for certain services it provides for the benefit of clients such as record keeping, administration, shareholder servicing, and client telephonic and other servicing; and (ii) help increase profitability for the firm. As a result, in almost all instances our affiliate earns higher revenues from the share class available to purchase in Advisory Solution Programs than from Eligible to Hold Share Class positions. Ameriprise Financial Services seeks to make available to client’s mutual funds, and share classes of those mutual funds, that Ameriprise Financial Services believes are suitable for investment. We take mutual fund expenses into account in determining which mutual funds to offer in our Programs, as further discussed in the “Investment Product Due Diligence Services” paragraphs of this section. Advisory Shares are less expensive than share classes that charge investors a 12b-1 fee or assess a sales charge, but 11 marketplace for a given mutual fund, please refer to the mutual fund’s prospectus or statement of additional information. Please review the mutual fund prospectus and contact your financial advisor for information about any limitations on share classes available for purchase through a Managed Account. For more information on fund families and mutual funds offered in our Advisory Solution Programs, including the applicable Advisory Share class or other share class utilized, please refer to our Mutual Fund Screener Tool available by logging into your Ameriprise Secure Site account and selecting Trade & Research and then Screeners and select the “Availability” tab. Please refer to the mutual fund’s prospectus(es) or website to determine whether your investment would qualify for an institutional or other share class outside a managed account service, with corresponding lower expenses and fees. Class A share and Class C share positions, as well as other share classes that pay a 12b-1 fee and that do not match the Advisory Share class or other share class offered by Ameriprise Financial Services for a particular mutual fund (“Non-Matching Shares”) are processed as follows: Our determination of which share class to offer as the only share class available for purchase in a particular mutual fund presents a conflict of interest for Ameriprise Financial Services due to a financial incentive to place you in the higher-cost share class that pays AEIS for cost reimbursement services as described in the “Cost Reimbursement Services and Third Party Payments” section. Ameriprise Financial Services addresses this conflict of interest through a combination of disclosure and policies, procedures and related controls designed to ensure that the fees we charge to clients are fair and reasonable. We also permit clients to hold Eligible to Hold Share Class positions at a lower cost to you and, in almost all instances, we do not receive Third Party Payments for such positions. Another way we address this conflict is by not sharing Third Party Payments with your financial advisor in connection with the investment products recommended for your Managed Account, which eliminates any personal financial incentive for your financial advisor to make recommendations based on whether Third Party Payments are received. Your financial advisor may receive compensation based on the profitability of the firm, as further described in the “Financial Advisor Compensation and Benefits” section. Before selecting a Managed Account Program, you should consider, among other things, that the total compensation received by Ameriprise Financial Services and our affiliate in the aggregate includes Third Party Payments received for cost reimbursement services as discussed in the “Appropriateness of a Managed Account for you” section. • Where Non-Matching Share classes that pay a 12b- 1 fee are held in or transferred into your Managed Account, we will convert such shares to an Advisory Share class where one is available to us through a selling agreement provided the mutual fund company allows the conversion to be processed on a tax-free exchange basis for non-qualified account holdings. We will not assess transaction fees or other charges in connection with conversions to Advisory Shares. For Manager Directed Programs the conversion to the Advisory Share class of the same mutual fund may occur on a non-exchange basis. Such transactions generally result in tax consequences in non- qualified Accounts. You authorize Ameriprise Financial Services to convert applicable Non-Matching Shares to an Advisory Share class of the same mutual fund by establishing a new Relationship or by continuing to accept the services in the Program after we notify you of an upcoming conversion. Our decision to offer a particular share class that may not be the least expensive share class and a financial advisor’s recommendation that you participate in a Program will cause you to pay higher internal expenses for certain mutual funds than you would otherwise pay (i) if participating in another provider’s managed account service which uses a lower-cost share class; (ii) if holding a lower-cost share class as an Eligible to Hold Share Class; or (iii) by buying the mutual funds directly from the distributor outside of a managed account service, if possible. This difference in internal expenses between share classes of a particular mutual fund will also affect the investment performance of your Managed Account by reducing returns over time. Your participation in a Program that does not offer or allow additional purchases of the least expensive share class may still be an appropriate choice depending on the facts and circumstances of your individual situation and in light of the features and benefits of the particular Program. For a listing of all share classes that may be available in the • Non-Matching Share classes that pay a 12b-1 fee in SPS Advantage Accounts and SPS Advisor Accounts will not be converted to the corresponding Advisory Share if Ameriprise Financial Services is not able to complete the exchange (e.g., the mutual fund company does not allow it or a corresponding Advisory Share class is not offered), the exchange cannot be processed on a tax-free basis, or if Ameriprise Financial Services determines they are subject to a short- term redemption fee or deferred sales charge. Instead, to the extent 12 identified by Ameriprise Financial Services, those Non-Matching Shares will generally be transferred to an Ameriprise brokerage account in accordance with the Relationship Agreement. Similarly, Class C share positions that Ameriprise Financial Services is unable to convert to Advisory Shares for any reason will be transferred to an Ameriprise brokerage account. Any such positions pending transfer to an Ameriprise brokerage account will be subject to the Asset-based Fee. • the entire 12b-1 fee rebate will be considered miscellaneous income if the originating Account is a non- qualified Account. Account holders receiving aggregate miscellaneous income of $600 or more annually will receive an IRS Form 1099-MISC, Miscellaneous Information, from AEIS. Account holders receiving miscellaneous income amounts under $600 annually generally will not receive an IRS Form 1099-MISC from AEIS but will be responsible for reporting the income to the IRS. Holders of IRAs and qualified retirement plan Accounts will not experience a taxable event as a result of a rebate and will instead be taxed only on amounts when they are distributed from the Account. SPS Advantage and SPS Advisor Accounts are more likely to hold Class A shares or no-load share class mutual fund positions. Investment Product Due Diligence Services and Investment Availability for Purchases. Prior to initially offering any mutual fund, ETF, exchange traded note (“ETN”), CEF or UIT in the Programs and on at least an annual basis thereafter the Ameriprise Investment Research Group (“IRG”) manager research and due diligence team conducts research and quantitative analysis, and may also conduct qualitative analysis, of investment products. For the Signature Wealth Program, Ameriprise Financial Services further defines the mutual funds and ETFs available for use in the Program. As with full Account transfers to an Ameriprise brokerage account, if you do not have an Ameriprise brokerage account with the same account registration, beneficiaries and other account level attributes as your Managed Account, a new brokerage account will be opened for you with the same attributes. The Brokerage Agreement will govern your Ameriprise brokerage account relationship including fees charged in connection with maintaining a brokerage account, transaction fees and applicable terms and conditions such as mandatory pre-dispute arbitration. Advisory Shares and certain other share classes used as the only share class available for a particular mutual fund are not available for purchase in an Ameriprise brokerage account. Such share classes can be held in an Ameriprise brokerage account subject to any restrictions or conversion requests received from the mutual fund company. 12b-1 Fee Rebates This process, depending on the type of investment, may include evaluation of the historical performance or tracking difference, amount of assets with Ameriprise Financial Services, expenses, premium, offering documents, financial statements, portfolio holdings and other information requested from the product manufacturer. Investments Available for Purchase. Advisory Shares typically do not pay 12b-1 fees. As described above, where Ameriprise Financial Services does not offer an Advisory Share class for a particular mutual fund, we offer either a Class A share or a no- load share class that may pay a 12b-1 fee. To the extent that Ameriprise receives 12b-1 fees for share classes held in any Managed Accounts, they will be rebated to clients. Rebates are generally deposited into the applicable client Accounts within a week after we receive the 12b-1 fees. Investment products (i) that meet Ameriprise Financial Services’ due diligence standards; and (ii) for which we have a selling or distribution agreement in place are offered and are available for purchase in SPS Advantage Accounts, SPS Advisor Accounts, Signature Wealth Accounts, Vista Separate Accounts and Investor Unified Accounts (“Eligible Investments”). In circumstances where the aggregate value of these rebates exceeds the Asset-based Fees paid from your non-qualified account, the excess will be considered miscellaneous income for tax reporting purposes. For Accounts with alternative fee billing arrangements, Signature Wealth Accounts may only hold Eligible Investments. Eligible to Hold Share Classes, Eligible to Hold Investments and Ineligible Investments are not permitted. 13 Investments Eligible to Hold but Not Purchase. The types of investments that can be held, but not purchased, in SPS Advantage and SPS Advisor Accounts are summarized in the chart below and further described below and in the “Mutual Fund Share Classes in Managed Accounts” paragraphs of this section. Type of Investment SPS Advantage and SPS Advisor Account Activity Ameriprise Financial Institutions Group (“AFIG”) financial advisors may transfer Eligible to Hold Investments and Ineligible Investments from an Ameriprise brokerage account into your Managed Account at account opening and for initial transition purposes only. After the initial transition is complete such assets may no longer be transferred from an Ameriprise brokerage account to a Managed Account. Any Ineligible Investments that are either transferred into your Managed Account from non- Ameriprise accounts or reclassified as an Ineligible Investment may be either sold or transferred to an Ameriprise brokerage account, however if no action is taken with respect to Ineligible Investments held in your Managed Accounts by 180 days after transfer, or 180 days after the position was reclassified, as applicable, the position(s) will be automatically transferred into an Ameriprise brokerage account in accordance with the Relationship Agreement. This process may be delayed for certain position(s) where Ameriprise Financial Services requires coordination with the applicable mutual fund firm for the orderly processing of the transfer to an Ameriprise brokerage account. While not available for purchase, you may only transfer in from an external account and hold these investments. Positions will be billable while held in eligible Programs. While not available for purchase, you may only transfer in from an external account and hold these investments. Positions will be billable while held in eligible Programs. Occasionally, Ineligible Investments may be reclassified as Eligible to Hold Investments, for example when an investment product meets our due diligence standards but is otherwise unavailable for purchase in Advisory Solution Programs. In this case, you will be permitted to continue to hold such investments in eligible Programs. Eligible to Hold Share Class Share class that is less expensive than the advisory or other share class offered for purchase in a given mutual fund in our Programs. Eligible to Hold Investments Investment products for which our due diligence standards are met but either: (i) we do not have a selling or distribution agreement in place; or (ii) the investment is not otherwise available for purchase in Managed Accounts. While not available for purchase, you may only transfer in from an external account and hold these investments for up to 180 days. Positions will be billable while held in eligible Programs. Ineligible Investments Investment products (i) that do not meet our due diligence standards; (ii) where due diligence has not been completed; or (iii) that are not otherwise eligible to be held more than 180 days in Managed Accounts. Your financial advisor may recommend that you sell, or may sell in an SPS Advisor Account, any Ineligible Investments within your Managed Account to purchase Eligible Investments. Such transactions generally result in tax consequences in non-qualified Accounts. While such recommendation or sale and subsequent purchase in an SPS Advisor Account must be suitable and appropriate for your Managed Account, your financial advisor will generally receive more revenue from a Managed Account that generates ongoing revenue streams than in an Ameriprise brokerage account. Therefore, your financial advisor has a financial incentive to reposition any Ineligible Investments within your Managed Account into positions that are available for purchase. Ameriprise Financial Services seeks to address the conflict of interest through its policies, procedures and supervision of the suitability of recommendations related to your Managed Account based on your Client Information and in accordance with all applicable regulatory requirements. You may hold these types of investments as described above; however, your Managed Account will be subject to our ongoing determination that the Account is appropriate for you, including our belief that an SPS Advantage Account is appropriate if you primarily seek and act on the asset allocation and investment advice of your financial advisor. Investments Not Eligible to Hold or Purchase Non-advisory assets are not allowed to be purchased or held beyond initial transitional and administrative processing upon transfer from an external account You may not transfer Eligible to Hold Share Classes, Eligible to Hold Investments, or Ineligible Investments from an Ameriprise brokerage account into your Managed Account. In certain instances, clients of 14 to either a SPS Advantage or SPS Advisor Account. These positions are not billable during processing. Managed Accounts Program Oversight Committee and Due Diligence Services. The Managed Accounts Program Oversight Committee (“Oversight Committee”) of Ameriprise Financial Services is responsible for the oversight of such Advisory Service Providers. The Oversight Committee provides oversight of the advisory services provided to the applicable Program(s) such as investment strategies, model portfolios and asset allocation models, as applicable. The Oversight Committee, acting on behalf of Ameriprise Financial Services, is the Investment Manager of Select ETF Portfolios, a variety of portfolios that invest in non- proprietary ETF investments in partnership with Portfolio Strategists or Asset Allocation Strategists. Non-advisory assets include investments such as non-traded exchange funds, 1031 exchange offerings, Class C, Class B or any other mutual fund share class with a contingent deferred sales charge, leveraged and inverse ETFs and mutual funds, and other illiquid securities. Any non-advisory assets that are (i) transferred into your SPS Advantage Account or SPS Advisor Account, or (ii) that are subsequently reclassified such that they are no longer allowed to be held in your Managed Account will be promptly transferred into an Ameriprise brokerage account in accordance with the Relationship Agreement. Each of the Portfolio Strategists and Asset Allocation Strategists for Select ETF Portfolios, as applicable, develops asset allocation models, conducts qualitative and/or quantitative research on mutual funds and ETFs, and constructs model portfolio or asset allocation recommendations, as applicable. The Oversight Committee reviews and approves these recommendations as part of its ongoing oversight. The Oversight Committee may remove a Portfolio Strategist or an Asset Allocation Strategist from the Select ETF Portfolios Service and/or adjust an asset allocation or model portfolio as appropriate. In addition, trustee-directed retirement plans are not allowed to hold affiliated mutual funds and investment products advised or sub-advised by CMIA or their affiliates in qualified SPS Advantage Accounts and eligible qualified Select Separate Accounts. Similarly, these affiliated mutual funds and investment products are not allowed to be held in qualified SPS Advisor Accounts and Tax-Sheltered Custodial Accounts (“TSCAs”) invested in SPS Advisor and will be promptly transferred into an Ameriprise brokerage account in accordance with the Relationship Agreement. The IRG conducts initial and ongoing research and due diligence on Advisory Service Providers, their applicable investment strategies and the investment advisory services available or utilized in the Programs and provides recommendations to the Oversight Committee on matters including the addition or termination of an Advisory Service Provider, benchmark allocations, and security trading. The Oversight Committee determines which Advisory Service Providers are available within Programs. For all transfers of non-advisory assets or affiliated mutual funds and investment products, as with full Account transfers to an Ameriprise brokerage account, if you do not have an Ameriprise brokerage account with the same account registration, beneficiaries and other account level attributes as your Managed Account, a new brokerage account will be opened for you with the same attributes. Solely the Brokerage Agreement will govern your Ameriprise brokerage account relationship including fees charged in connection with maintaining a brokerage account, transaction fees and applicable terms and conditions such as mandatory pre-dispute arbitration. The IRG also conducts due diligence and provides ETF recommendations to the Oversight Committee for all Select ETF Portfolios investments where an Asset Allocation Strategist provides solely asset allocation services. Advisory Service Providers More detail on how Ameriprise Financial Services selects and reviews Advisory Service Providers for each Program are described in the “Advisory Solution Programs and services” sub-sections for Signature Wealth, Active Portfolios®, Select Separate Account and Managed Accounts Offered with Envestnet Asset Management, Inc. Types of Advisory Service Providers. The types of Advisory Service Providers that may provide services to your Managed Account include: Ameriprise Financial Services uses the services of affiliated and third party investment advisory firms (collectively, “Advisory Service Providers”) to provide discretionary and non-discretionary investment advisory services that include investment management, asset allocation and/or rebalancing, or providing investment models, as applicable, for the following Manager Directed Programs: Signature Wealth, Active Portfolios®, Select Separate Account, Vista Separate Account, Investor Unified Account and Access Account. 15 • more information about its investment advisory business. Due Diligence of Signature Wealth Investment Manager. Investment Managers. Investment Managers are Discretionary Managers with discretionary authority to purchase or sell securities or make other investments for your Managed Account. Such transactions generally result in tax consequences in non-qualified accounts. Investment Managers include (i) the Oversight Committee acting on behalf of Ameriprise Financial Services, and (ii) affiliated and non- affiliated third-party investment advisers. The Oversight Committee is the Investment Manager of Select ETF Portfolios. • Signature Wealth Investment Manager. Ameriprise Financial Services selected a non- affiliated third-party registered investment adviser as the discretionary Investment Manager for the Signature Wealth and Active Portfolios® Programs (“Signature Wealth Investment Manager”). The Signature Wealth Investment Manager: The IRG conducts an annual review of the Signature Wealth Investment Manager. This review is based on applicable information gathered from various sources, including information from the Signature Wealth Investment Manager, disclosure documents, historical performance and assets under management. As a result of these reviews, Ameriprise Financial Services may identify actual or potential concerns regarding the Signature Wealth Investment Manager and may request them to take corrective action to address such concerns. This review may result in the removal of the Signature Wealth Investment Manager. If the Signature Wealth Investment Manager is removed, you and your financial advisor will receive notice and direction on what actions you will need to take. If no action is taken, your Managed Account will be closed and moved in-kind to an Ameriprise brokerage account. • Investment Providers. o Receives asset allocation and investment selection recommendations from the Signature Wealth Model Providers. o Has with discretionary authority to purchase or sell securities or make other investments for your Account without your prior approval, except for mutual funds and ETFs you work with your financial advisor to select for your client directed model. o For the portion of your Account that is not Investment Providers for the Signature Wealth and Active Portfolios® Programs construct the recommended holdings in each model investment portfolio according to their specific investment strategy and may include their proprietary mutual funds and/or ETFs in the model investment portfolios. Each Investment Providers’ disclosure documents (Part 2A of Form ADV) are available to you at ameriprise.com/investmentproviders. invested in model investment portfolios and consists of individual mutual funds/ETFs that are recommended by your financial advisor (the “client directed model”) has trading authority only and is responsible for the ongoing trading and rebalancing of your client directed model. o Provides administrative and/or trading instruction to AEIS as the clearing / custody broker-dealer. o Provides rebalancing services to maintain to your Account’s asset allocation. Our affiliate, CMIA, participates in the Signature Wealth and Active Portfolios® Programs as an Investment Provider. The Investment Providers make non- discretionary investment and asset allocation recommendations to the Signature Wealth Investment Manager. For Signature Wealth Accounts with a client directed model, you will select the investments according to your personal portfolio, and the discretionary Signature Wealth Investment Manager will invest that portion of your overall Managed Account according to your direction and will be responsible for the ongoing trading and rebalancing of your Signature Wealth Managed Account, subject to any Reasonable Restrictions or other instructions provided by you. o Selects replacement mutual funds and ETFs for your client directed model in instances where the investment is no longer eligible for use in the Signature Wealth Program, as applicable. o Acts on any Reasonable Restrictions that you may impose on the management of your Account(s). The Signature Wealth Investment Manager exercises investment discretion for the Signature Wealth and Active Portfolios® Managed Accounts. Investment Providers do not have any investment discretion or trading authority to purchase or sell securities in your Managed Account. Different Investment Providers may arrive at different investment and asset allocation recommendations regarding Review the Signature Wealth Investment Manager’s Form ADV, Part 2A Appendix 1, for 16 investments in a certain sector, market capitalization, or other category of investments, depending on the model portfolio’s investment objective. Oversight of the Investment Provider and the model investment portfolio’s investment strategy is provided by the Oversight Committee, as described above. offer a wide variety of SMAs and asset allocation strategies (each, an “Envestnet Strategy”) with a wide range of investment objectives and risk tolerances. Envestnet Strategies are available in the Vista Separate Account, Investor Unified Account and Access Account Programs. Review Envestnet’s Form ADV, Part 2A Appendix 1 for more information about its investment advisory business. o Envestnet Advisory Services Include: • Portfolio Strategists. Portfolio Strategists provide asset allocation and investment recommendations to the Oversight Committee as Investment Manager. Portfolio Strategists do not have discretionary authority or control to purchase or sell securities or make other investments for individual investors. – Providing access to a variety of SMA Investment Managers (“Envestnet Managers”). Certain Envestnet Managers have entered into a sub- management agreement with Envestnet to provide discretionary Investment Manager account management services. Envestnet is the discretionary Investment Manager where the Envestnet Manager has entered into a Model Provider sub-management agreement. • Asset Allocation Strategists. Asset Allocation Strategists solely provide asset allocation recommendations to the Oversight Committee as Investment Manager. The Asset Allocation Strategists do not have discretionary authority or control to recommend, purchase or sell securities or make other investments for individual investors. – Providing administrative and/or trading services as directed by Envestnet and/or the Envestnet Manager. – Facilitating the asset allocation • Select Separate Account Model Providers. Model Providers construct a model portfolio according to their specific investment strategy and, in that capacity, make investment selection decisions for the model portfolio strategy, which Ameriprise Financial Services implements, subject to any Reasonable Restrictions or other instructions provided by you. • The Model Provider does not have any recommendations and helping to identify Envestnet Managers mutual funds and/or ETFs for the Account(s), considering factors it deems relevant, including, but not limited to, your investment objective, risk tolerance and investment time horizon. – Rebalancing services to maintain your Managed Account’s asset allocation. – Acting on any Reasonable Restrictions that you may impose on the management of your Managed Account(s) including designation of particular securities or types of security that you do not want purchased for your Managed Account(s). Envestnet and/or the Envestnet Manager must accept any Reasonable Restrictions before they will be binding on the Account(s). Review Envestnet’s Form ADV, Part 2A Appendix 1 for more information about its investment advisory business. investment discretion or trading authority to purchase or sell securities in your Account. Ameriprise Financial Services exercises investment discretion for Managed Accounts utilizing Model Providers and implements securities transactions in your Account(s) in accordance with the model portfolio provided by the Model Provider. Different Model Providers may arrive at different investment selection decisions regarding investments in a certain sector, market capitalization, or other category of investments, depending on the model portfolio’s investment objective. Oversight of the Model Provider and the model portfolio’s investment strategy is provided by the Oversight Committee, as described above. Due Diligence of Envestnet Managers. • Envestnet Platform. Ameriprise Financial The IRG conducts an annual review of the Envestnet Strategies. This review is based on applicable information gathered from various sources, including information from Envestnet, disclosure documents, Services offers certain advisory services that are available through a web-based platform offered by Envestnet Asset Management, Inc. (“Envestnet”). Envestnet is a non-affiliated registered investment adviser and seeks to 17 historical performance and assets under management. In limited circumstances, the IRG conducts initial and/or ongoing reviews to supplement Envestnet’s reviews of an Envestnet Strategy. As a result of these reviews, Ameriprise Financial Services may identify actual or potential concerns regarding Envestnet and/or an Envestnet Strategy and may request that Envestnet and/or the Envestnet Manager take corrective action to address such concerns. These reviews may result in the removal of an Envestnet Strategy from the applicable Program. If an Envestnet Strategy is removed from one or more of the Programs, you and your financial advisor will receive notice to change to a new investment. If no change is made, your Managed Account will be closed and moved in-kind to an Ameriprise brokerage account. Review of Envestnet Strategies by Envestnet. reject: i) a prospective client and related Managed Account for Vista Separate Account and Investor Unified Account Programs, or ii) the transition of your related account to Ameriprise Financial Services for Access Account Program. Once your Managed Account is accepted by Envestnet and/or the Envestnet Manager, you will become an investment management client of Envestnet and/or the Envestnet Manager. Envestnet and/or Envestnet Manager will have full discretionary authority to act on behalf of your Managed Account purchases, sales and other transactions in SMA(s), mutual funds and/or ETFs, without seeking your prior approval, except for selecting which mutual funds and/or ETFs are held in your Investor Unified Account. Envestnet may delegate its discretionary authority for your entire Account or a portion of your Managed Account, known as an investment sleeve, to an Envestnet Manager. Neither Envestnet nor the Envestnet Manager will have the ability to withdraw, disburse or transfer funds or securities from your Managed Account without your prior authorization. Client Contact with Advisory Service Providers. Ameriprise Financial Services relies in part upon Envestnet for analysis, information and the selection and monitoring of the various Envestnet Strategies. All Envestnet Managers receive and are directed to return a completed due diligence questionnaire each year. Your financial advisor will be your primary source of support in addressing any questions or concerns relating to your Managed Account. Although Ameriprise Financial Services imposes no limitations on the ability of clients to consult with their Advisory Service Provider(s) directly, you are encouraged to first contact your financial advisor with any questions or concerns. Information Relating to Your Household The Envestnet Strategies are considered “Approved” or “Available,” depending on the level of due diligence performed by Envestnet. Envestnet reviews the Envestnet Strategies and performance of a wide range of Envestnet Managers and in its sole discretion determines if an Envestnet Strategy is considered “Approved” or “Available.” Envestnet personnel rely on investment professionals of the Envestnet Managers and a variety of data available from one or more independent databases when determining if an Envestnet Strategy is “Approved” or “Available”. We use information concerning your primary household group’s investment, insurance, annuity and certain bank products to provide a consolidated statement. A primary household group may consist of an individual client, his or her spouse or domestic partner, and their unmarried children under age 21 who reside at the same address. Envestnet makes available information received from industry databases, such as Morningstar, regarding the Envestnet Strategies, to your financial advisor. This information may help your financial advisor to identify the strengths and weaknesses of each of the Envestnet Strategies. For certain products and services, the householding of your Managed Accounts may help you qualify for advantageous pricing or fees. See the “Householding of Account Assets and Minimum Asset-based Fee” sub- section of the “Fees and Compensation” section for more detail about householding’s impact on the Asset- based Fee. Please contact us at 800.862.7919 if you prefer to receive a statement covering only accounts that you own and not to participate in householding. Your financial advisor will be responsible for determining whether he or she has sufficient information about the Envestnet Strategies in order to recommend Envestnet and one or more of the Envestnet Strategies to you. Acceptance and Authority of Envestnet. Your Client Information along with a copy of your Statement of Investment Selection are provided to Envestnet as Investment Manager for review. Householding also permits us to deliver a single copy of certain shareholder documents – such as prospectuses, supplements, annual reports, semiannual reports and proxies – to clients who own the security and who reside at the same address. To opt out of this service, call 866.273.7429 and reference the client ID located in your statement. Envestnet in its sole discretion may determine based upon the applicable information whether to accept or 18 Multiple mailings will resume within 30 days of opting out. Tax documents are not eligible for householding. The Ameriprise® Custom Advisory Relationship The Relationship Agreement and this Disclosure Brochure, as amended, will apply to each Managed Account in the available Advisory Solutions Programs you are eligible to establish with us. Please retain these documents for future reference as they contain important information if you decide to add services or open new Managed Accounts with Ameriprise Financial Services. Advisory Solution Programs and Services for Managed Accounts The chart below provides an overview of the following Programs: for SPS Advantage, SPS Advisor, Signature Wealth, Active Portfolios® investments and Select Separate Account, including offering terms. Not all investment options listed for and SPS Advisor in the “Investment Products” row below may be available for new or additional purchases. Please refer to the “Programs and Services” section for a description of each Program and ask your financial advisor for more information about the investment products available to you. Fee information is included in the “Fees and Compensation” section following the description of the Programs. The charts also identify the primary mutual fund share class offered in the Programs and each Program’s corresponding minimum investment requirements. Minimum withdrawal amounts and Account minimums that may apply to the Program you select and are noted in the charts. Ameriprise Financial Services offers all new Managed Accounts to clients through a single Custom Advisory Relationship (“Relationship”). As used throughout this document, the defined term Relationship refers solely to an investment advisory relationship opened through the Relationship Agreement. By entering into a Relationship with us, you may establish Managed Accounts for the Advisory Programs described in this Disclosure Brochure, in many cases, without signing additional documentation. When you establish a Relationship, your initial signature will serve as your agreement to the terms and conditions of all of the Programs offered in this Disclosure Brochure and you may generally establish Managed Accounts and make many types of changes to your Managed Account by contacting your financial advisor and providing verbal instructions. We may ask you for written authorization to add certain features to an Account such as establishing margin or options trading, if available. The Access Account Program is a hold and service Program and, unlike the other Programs, requires you to complete additional paperwork and authorize the establishment of an Access Account by signature. When establishing a Relationship, you will make various elections that will be applied to your Managed Accounts opened in the applicable Program in the future. You can change some of these elections at Managed Account opening or any time for current Managed Accounts and/or Managed Accounts to be opened in the future by working with your financial advisor, although, changes to some elections require your written authorization. All Managed Accounts have a required (i) initial investment minimum; and (ii) maintenance minimum that varies by Program. For Signature Wealth Accounts, the maintenance minimum varies based on the mix of model investment portfolio(s) you select for your Managed Account. If an Account falls below the ongoing maintenance minimum, we will provide notice to you to add funds to the Account to bring it back to the initial investment minimum. If your Managed Account does not reach the initial investment minimum after 45 days, we will transfer the Account to an Ameriprise brokerage account in accordance with the Relationship Agreement. When reviewing the charts, please consider, among other factors: 1) your ability to meet initial investment and maintenance minimums for each Program using assets held in custody at Ameriprise or assets held elsewhere which might be aggregated; 2) whether the Program you select provides your financial advisor, the Oversight Committee or an Advisory Service Provider discretionary authority; 3) the impact of underlying investment product level fees on the overall performance of your portfolio; and 4) whether the rebate of any 12b-1 fees associated with your Managed Account may be a taxable event for you. Ameriprise Financial Services will send a confirmation letter to you when a Relationship is established, when a Managed Account is opened, or when your Asset-based Fee is changed as described in the “Fees and Compensation” section. You may make other changes verbally and we will send a confirmation letter reflecting such changes to you. Each confirmation letter becomes part of your Relationship Agreement unless you notify us that it is incorrect so it is important that you review and verify the information contained in it, such as your Managed Account elections, to ensure accuracy and notify your financial advisor immediately if you believe any information should be updated. 19 Programs SPS Advantage SPS Advisor Active Portfolios® Select Separate Account Signature Wealth Non-discretionary Discretionary Discretionary Discretionary Discretionary Investment Advisory Account Asset Structure Allocation Financial advisor recommends Financial advisor determines Financial advisor Recommends Investment Provider recommends Financial advisor recommends. For Select Strategist UMA Portfolios (“UMA Portfolios”), the Asset Allocation is determined by the Investment Manager. Investment Selection Financial advisor recommends Financial advisor determines Financial advisor recommends portfolios Financial Advisor recommends model investment portfolios and mutual funds1 and ETFs Financial advisor recommends portfolio/model. For UMA Portfolios, the investment selection of portfolios/models is determined by the Investment Manager. Investment Products Mutual funds and/or ETFs Mutual Fund/ETF model investment portfolios, SMA model investment portfolios, mutual funds and ETFs held within a single account Equity, ETF, balanced and fixed income separately managed account strategies (“SMA”). Some SMA managers may also invest in ETFs and certain mutual funds. UMA Portfolios invest in SMAs, ETFs and mutual funds. Includes, but not limited to: mutual funds1; (which could include fund of funds); ETFs; stocks; bonds; publicly traded REITs; options on indices and equities Includes, but not limited to: mutual funds1; (which could include fund of funds); ETFs; stocks; bonds; publicly traded real estate investment trusts (“REITs”); options on indices and equities; certain alternative investments (e.g., hedge funds, managed futures funds, non-traded REITs, non- traded BDCs, non- traded CEFs, real estate private placements, private equity offerings) Advisory Shares Advisory Shares Advisory Shares Advisory Shares Primary Share Class Offered for Purchase SMA strategies generally do not offer mutual funds. Where mutual funds are offered, Advisory Shares are offered for purchase $25,000 (for all accounts within a Household) $100,000 (for all accounts within a Household) Investment and Maintenance Minimums Initial investment minimum is $2,000, maintenance minimum is $1,000. Initial investment minimum $25,000, maintenance minimum $15,000. For Active Growth Builder Portfolios, initial investment minimum $5,000, maintenance minimum $4,000. Ameriprise Financial Services Initial investment minimum $2,000, maintenance minimum $1,000. Initial investment minimum $100,000 – $500,000 (depending on the SMA investment strategy or UMA portfolio). Ongoing minimums vary depending on the SMA investment strategy or UMA portfolio. Select ETF Portfolios have an initial investment minimum of $50,000. Each Signature Wealth Account has its own initial investment minimum and maintenance minimum and is determined by the investments you select within your personalized investment account asset allocation shown in the Signature Wealth Proposal. Ameriprise Financial Services may suspend or waive these amounts. Ameriprise Financial Services may suspend or waive these amounts. Each mutual fund/ETF portfolio investment model has its own initial investment minimum ranging from $5,000 - $50,000. Clients must invest in one or more model investment portfolios. Clients may also invest up to 25% of their Account in a client-directed model that holds individual mutual funds and/or ETFs. 20 N/A N/A N/A N/A Margin Trading Must be approved by Ameriprise Financial Services Cost Basis2,3 Open end mutual funds: Open end mutual funds: HIFO5, unless you select another option. Equities: HIFO5, unless you select another option. Average Cost2, unless you select another option. Equities: FIFO2, unless you select another option. Open end mutual funds: Non Average Cost Basis3 unless you elect a different option. Equities: Loss/Gain Utilization3 unless you elect a different option. Open end mutual funds: Average Cost2, unless you select another option. ETFs: HIFO5, unless you select another option. Open end mutual funds: Average Cost4, unless you select another option. Equities: FIFO4, unless you select another option. 1 Please contact your financial advisor or refer to our Mutual Fund Screener Tool for a current list of mutual funds offered in any of these accounts. Access the tool by logging into your Ameriprise Secure Site account and navigating to the “Trade & Research” and then, “Screeners” followed by “Mutual Fund”. From there, apply the Product Type filter and choose either SPS Advantage or SPS Advisor to view the funds and share classes available for purchase. 2 Below are the cost basis options available for SPS Advantage, SPS Advisor, Active Portfolios and Select Separate Account. You may elect to sell specific shares outside of the cost basis option you have selected. If you elect to change from average cost to another method after disposing of any mutual fund shares (i.e., sale, journal, transfer, etc.), the method change will apply only to covered shares acquired after the date of the most recent disposition. If you transfer securities into a Managed Account the cost basis method applied to the Managed Account receiving the securities will be applied to such securities. If you hold bonds in your Managed Account, you have the option to make tax elections which may affect the income on your bonds and the character of your bond income. These elections can be made by filing form 402459. Revoking certain bond elections may require IRS consent. Cost Basis for Equities: • First In, First Out (FIFO): The first tax lots purchased are the first tax lots sold. The tax lots remaining each maintain their individual tax lot cost and holding period. • Highest In, First Out (HIFO): The tax lots with the highest cost basis are the first tax lots sold. The tax lots remaining each maintain their individual tax lot cost and holding period. • Last In, First Out (LIFO): The last tax lots purchased are the first tax lots sold. The tax lots remaining each maintain their individual tax lot cost and holding period. • Loss/Gain Utilization (SPS Advisor Accounts only): Evaluates losses and gains and strategically selects shares to deplete based on the loss/gain in conjunction with the holding period. The loss/gain utilization method depletes shares with losses before shares with gains, consistent with the objective of minimizing taxes. For share lots that yield a loss, short-term share lots will be redeemed ahead of long-term share lots. For gains, long-term share lots will be redeemed ahead of short-term share lots. For SPS Advantage: If lot-specific identification of securities sold is desired, that must be done at the time of sale. For SPS Advisor: Note, that your financial advisor has the discretion to override these methods and use another cost basis method or specific identification. If lot-specific identification of securities sold is desired, that must be done at the time of sale. Cost Basis for Open End Mutual Funds: • Average Cost Basis: Each mutual fund’s cost basis is the total amount invested averaged over the number of shares purchased, giving each share the same basis. As new tax lots are purchased, or other adjustments are made, the average cost of the shares is recalculated. For holding period purposes, the first tax lots purchased are the first tax lots sold. Average cost is calculated separately for covered and non-covered shares. • Use Lot Relief Method selected above (FIFO, HIFO, LIFO): The lot relief method for the mutual fund account will be the same lot relief method elected for equities on this account, even if there are no equities in the account. For SPS Advisor Accounts, see footnote 4 (below). For SPS Advantage: If lot-specific identification of securities sold is desired, that must be done at the time of sale, and with a default lot relief election other than average cost made prior to sale. For SPS Advisor: Note, that your financial advisor has the discretion to override these methods and use another cost basis method or specific identification. If lot-specific identification of securities sold is desired, that must be done at the time of sale, and with a default lot relief election other than average cost made prior to sale. Cost Basis for Equities in Dividend Reinvestment Plans (DRP), as available: • Use Lot Relief Method selected above (FIFO, HIFO, LIFO): The lot relief method for the account will be the same lot relief method elected for equities on this account, even if there are no equities in the account. • Average Cost Basis: The cost basis for the shares is the total amount invested averaged over the shares purchased, giving each share the same basis. As new tax lots are purchased, or other adjustments are made, the average cost of the shares is recalculated. For holding period purposes, the first tax lots purchased are the first tax lots sold. Average cost is calculated for covered shares only. 21 3 Below are the cost basis options available in the Signature Wealth Program. You may elect to sell specific shares outside of the cost basis option you have selected. If you elect to change from average cost to another method after disposing of any mutual fund shares (i.e., sale, journal, transfer, etc.), the method change will apply only to covered shares acquired after the date of the most recent disposition. If you transfer securities into a Managed Account the cost basis method applied to the Managed Account receiving the securities will be applied to such securities. If you hold bonds in your Managed Account, you have the option to make tax elections which may affect the income on your bonds and the character of your bond income. These elections can be made by filing form 402459. Revoking certain bond elections may require IRS consent. Cost Basis for Mutual Funds • Non Average Cost Basis: The lot relief method for the mutual fund account will be the same lot relief method elected for equities on this account, even if there are no equities in the account. If shares have been sold using average cost, specific identification may be prospectively accounted. Cost Basis for Equities • Loss/Gain Utilization: Evaluates losses and gains and strategically selects shares to deplete based on the loss/gain in conjunction with the holding period. The loss/gain utilization method depletes shares with losses before shares with gains, consistent with the objective of minimizing taxes. For share lots that yield a loss, short-term share lots will be redeemed ahead of long-term share lots. For gains, long-term share lots will be redeemed ahead of short-term share lots. For Signature Wealth Accounts, if you indicate a preference, trades generally use that cost basis method. If you don’t indicate a preference, the cost basis selected by Ameriprise Financial Services listed above will generally be used for the Program. Further, the Signature Wealth Investment Manager with investment discretion may elect to sell specific investment products for tax-harvesting purposes regardless of the cost basis option you have selected. 4 For SPS Advisor accounts, open end mutual funds generally use average cost, but may use the Loss/Gain Utilization Method (defined above). Equities will generally use the Loss/Gain Utilization Method when your advisor is using certain trading systems. The FIFO preference may be used for the trades that do not use the Loss/Gain Utilization Method. Note, that your financial advisor has the discretion to override these methods and use another cost basis method or specific identification. 5 For discretionary Programs (other than SPS Advisor), if you indicate a preference, trades generally use that Cost Basis method. If you don’t indicate a preference, the cost basis selected by Sponsor and listed above will generally be used for the Program. Further, for Select Separate Accounts, the Advisory Service Provider with investment discretion may elect to sell specific investment products for tax-harvesting purposes regardless of the cost basis option you have selected. Programs Offered With Envestnet Asset Management, Inc. The chart below provides an overview of the following Programs: Vista Separate Account, Investor Unified Account and Access Account, including offering terms. Please refer to the “Programs and Services” section for a description of each Program and ask your financial advisor for more information about the investment products available to you. Fee information is included in the “Fees and Compensation” section following the description of the Programs. The charts also identify the primary mutual fund share class offered in the Programs and each Program’s corresponding minimum investment requirements. Minimum withdrawal amounts and Account maintenance minimums may apply to the Program you select and are available from your financial advisor. When reviewing the charts, please consider, among other factors: 1) your ability to meet investment minimums for each Program using assets held in custody at Ameriprise or assets held elsewhere which might be aggregated; 2) whether the Program you select provides your financial advisor, the Oversight Committee or an Advisory Service Provider discretionary authority; 3) the impact of underlying investment product level fees, on the overall performance of your portfolio; and 4) whether the rebate of any 12b-1 fees associated with your Managed Account may be a taxable event for you. Vista Separate Account Investor Unified Account Discretionary Discretionary Access Account2 Discretionary Investment Advisory Account Structure Asset Allocation Financial advisor recommends Financial advisor recommends Portfolio Strategist and/or Investment Manager determines Investment Selection Financial advisor recommends portfolio/model Financial advisor recommends portfolio/model and mutual funds/ETFs Financial advisor recommends portfolio/model Investment Products SMA strategies in multiple Accounts SMA strategies, mutual funds and ETFs within in a single account Mutual funds and/or ETF portfolios in one or more Accounts Advisory Shares Advisory Shares Advisory Shares Primary Share Class Offered for Purchase 22 Program minimum – Program minimum – Generally $25,000 to $250,000 Investment and Maintenance Minimums Program minimum - $100,000 Each SMA strategy has its own initial minimum and maintenance minimum. Client must invest in at least one SMA. Each SMA strategy has its own initial minimum and maintenance minimum. $50,000 depending on portfolio. Each Access portfolio has its own initial minimum and maintenance minimum. Client must invest in more than one investment product (e.g., one or more SMA, mutual fund or ETF, or combination thereof). Margin N/A N/A N/A Cost Basis3 Open end mutual funds: Average Cost, unless you select another option. Equities: HIFO4, unless you select another option. Open end mutual funds: Average Cost, unless you select another option. Equities: HIFO4, unless you select another option. Open end mutual funds: Average Cost, unless you select another option. Equities: HIFO4, unless you select another option. 1 In certain circumstances, your financial advisor may have discretion to select the asset allocation and investments for inclusion in your Managed Account. 2 This program is accommodation only. 3 Below are the cost basis options available. If you hold bonds in your Managed Account, you have the option to make tax elections which may affect the income on your bonds and the character of your bond income. These elections can be made by filing form 402459. Revoking certain bond elections may require IRS consent. Cost Basis for Equities: • First In, First Out (FIFO): The first tax lots purchased are the first tax lots sold. The tax lots remaining each maintain their individual tax lot cost and holding period. • Highest In, First Out (HIFO): The tax lots with the highest cost basis are the first tax lots sold. The tax lots remaining each maintain their individual tax lot cost and holding period. • Last In, First Out (LIFO): The last tax lots purchased are the first tax lots sold. The tax lots remaining each maintain their individual tax lot cost and holding period. Cost Basis for Open End Mutual Funds: • Average Cost Basis: Each mutual funds cost basis is the total amount invested averaged over the number of shares purchased, giving each share the same basis. As new tax lots are purchased, or other adjustments are made, the average cost of the shares is recalculated. For holding period purposes, the first tax lots purchased are the first tax lots sold. Average cost is calculated separately for covered and non-covered shares. • Use Lot Relief Method selected above (FIFO, HIFO, LIFO): The lot relief method for the mutual fund account will be the same lot relief method elected for equities on this account, even if there are no equities in the account. Cost Basis for Equities Dividend Reinvestment Plans (DRP), as available: • Use Lot Relief Method selected above (FIFO, HIFO, LIFO): The lot relief method for the account will be the same lot relief method elected for equities on this account, even if there are no equities in the account. • Average Cost Basis: The cost basis for the shares is the total amount invested averaged over the shares purchased, giving each share the same basis. As new tax lots are purchased, or other adjustments are made, the average cost of the shares is recalculated. For holding period purposes, the first tax lots purchased are the first tax lots sold. Average cost is calculated for covered shares only. 4 For discretionary Programs (other than SPS Advisor), if you indicate a preference, trades generally use that Cost Basis method; if you don’t indicate a preference, the cost basis selected by Ameriprise Financial Services and listed above will generally be used for the Program. Further, the Advisory Service Provider with investment discretion may elect to sell specific investment products for tax- harvesting purposes regardless of the cost basis option you have selected. 23 SPS Advantage logging into your Ameriprise Secure Site account and navigating to the “Trade & Research” and then, “Screeners” followed by “Mutual Fund”. From there, apply the Product Type filter and choose either SPS Advantage or SPS Advisor to view the funds and share classes available for purchase. See the “Revenue Sources for Ameriprise Financial Services, LLC” section regarding compensation for the sale of mutual funds. SPS Advantage is a non-discretionary Program which enables your financial advisor to provide investment advice relating to securities held in a single account, with access to a wide spectrum of investment choices. Advisory Shares are the primary share class for mutual funds offered for purchase in SPS Advantage Managed Accounts. SPS Advantage may be appropriate for clients who seek and act on the investment advice of their financial advisor. Your financial advisor makes regular investment recommendations in consideration of an asset allocation. You review and approve each recommendation. SPS Advantage is appropriate if you primarily choose transactions your financial advisor recommends to you (solicited). You may also choose transactions on your own (unsolicited). However, an SPS Advantage Account is not appropriate as a self- directed account or for day trading, highly active traders, or other excessive trading activity (solicited or unsolicited), including trading mutual funds based on market timing or if you plan to hold only a few mutual fund or securities holdings in your Managed Account. Dividends and distributions received on your investments held in your SPS Advantage Account may be reinvested, where allowed, if selected by you. The reinvestment of equity, ETF, preferred security, CEF or UIT. dividends will generally result in the purchase of a fractional share as further described in the “Fractional Shares and Principal Transactions” sub- section of the “Brokerage Practices” section and in your Relationship Agreement. Where reinvestment is not allowed or selected, your dividends and distributions will be deposited in your (“Sweep Program”), which is a vehicle for uninvested cash. Investment minimums may also apply to mutual funds you purchase through SPS Advantage. Review each applicable mutual fund’s prospectus for further details. Alternative Investments in SPS Advantage Accounts Ameriprise Financial Services will determine whether an SPS Advantage Account is appropriate upon account opening and thereafter. Ameriprise Financial Services, with thirty (30) days prior notice, also reserves the right to limit or close any Account that is used for excessive securities trading, or if it is determined that the Account is no longer appropriate for you. See the “Terminating a Relationship Agreement” section for more detail and for information regarding your right to terminate your SPS Advantage Managed Account(s). Ameriprise Financial Services offers certain types of alternative investments in SPS Advantage Accounts, including but not limited to hedge funds, managed futures funds, non-traded REITs, non- traded BDCs, non-traded closed end funds, real estate private placements, and private equity offerings. In order to be considered for inclusion in an SPS Advantage Account, the particular alternative investment must offer an eligible fee structure that is designed for use with advisory accounts and periodic redemptions. As a courtesy, annuities and life insurance policies may be displayed on your Managed Account statement. Such annuities and life insurance policies are not held in your Managed Account and any values provided by third parties are not validated by us. You will not receive recommendations or investment advice related to such annuities and life insurance policies as part of the SPS Advantage Program and the dollar value of any such annuity or life insurance policy is excluded from any portion of the Asset-based Fee calculation. Alternative investments that meet Ameriprise Financial Services’ due diligence standards are available for purchase. On an ongoing basis the product sponsor of the alternative investment determines the timing and amounts of funds that are available for redemption requests by investors. As a result, your investment in an alternative investment is less liquid than an investment in more common types of securities such as an equity, bond, mutual fund or ETF. Your ability to redeem all or a portion of your position will be impacted by these factors. In the event redemptions for a particular alternative investment are unavailable to you or otherwise significantly restricted for an extended period of time, or the alternative investment no longer meets our due diligence criteria, Ameriprise Financial Services will reclassify the investment as a non-advisory asset and promptly transfer the position into an Ameriprise brokerage account in accordance with the Relationship Agreement. Included among the available mutual funds for a SPS Advantage Account, except for trustee-directed retirement plans, are affiliated mutual funds and investment products which are managed or sub- advised by CMIA or their affiliates. For more information on fund families and mutual funds offered in our Managed Account services including the applicable Advisory Share class or other share class utilized, please contact your financial advisor or refer to our Mutual Fund Screener Tool. Access the tool by 24 You should choose investments that are comprised of an appropriate portfolio mix, based on a variety of factors including your age, risk tolerance, objectives, time horizon and historical performance of different asset classes. Keep in mind, however, that asset allocation analysis does not provide a comprehensive financial analysis of your ability to reach your goals, nor does it guarantee against losses in your portfolio. The valuation of alternative investments reflects the values as determined by and based on the records of the product sponsors and administrators of a given investment. While we apply reasonably designed due diligence procedures on an initial and ongoing basis, Ameriprise Financial Services does not guarantee the accuracy of valuation information. Valuation at time of redemption is based on various factors and therefore the value shown on your consolidated statement is not necessarily the value you will receive from the product sponsor if you choose to sell your position in an investment. While financial advisors do not pay transaction charges for trades they enter online, franchisee financial advisors are generally assessed a transaction charge for orders entered by phone. For employee financial advisors, this transaction charge is assessed to the employee’s branch. Payment of phone-in transaction charges in SPS Advantage Accounts may be a disincentive for a financial advisor to recommend an SPS Advantage Account or to recommend such trades in the Account(s). Optional Automatic Rebalancing Feature SPS Advantage has an optional feature that allows you to enable automatic rebalancing (the “Feature”). You may enroll in the Feature by completing the Ameriprise SPS Advantage Automatic Rebalancing Agreement with your financial advisor. Whether or not you enroll in the Feature you can direct your financial advisor to rebalance at any time. For purposes of calculating the Asset-based Fee, alternative investments will be valued as of the billing date using the values provided to us from the product sponsors and administrators of the investment. Valuation for alternative investments is often delayed, sometimes significantly, and is not guaranteed to be provided to Ameriprise Financial Services in a timely manner. As a result, the valuation used for purposes of calculating the Asset-based Fee may not be current with the actual value of your investments at the time billing is processed and, depending on the circumstances, can result in a higher Asset-based Fee. You should carefully consider the impact of these valuation delays on your Asset-based Fee when evaluating whether to invest in an alternative investment and when determining how much of your portfolio is appropriate to invest in alternative investments. Methods of Analysis After enrolling in the Feature, you can work with your financial advisor to establish a pre-determined allocation and frequency for Ameriprise Financial Services to rebalance your assets to your pre- determined allocation in accordance with your instructions (“Security Target”). When you have an active Security Target, Ameriprise Financial Services will effect the scheduled securities transactions in accordance with your instructions until your Security Target is inactivated, modified, or your Managed Account is terminated. Not all securities in your Managed Account need to be included in the Security Target (“Non-Target Securities”). Non-Target Securities are not subject to automatic rebalancing. Your financial advisor will review your financial and investment needs, objectives and risk tolerance. He or she may use asset value, current yield, yield projections as well as other assumptions you provide, as well as historical yield analysis, to provide you with investment recommendations. Investment recommendations will generally be made in consideration of an asset allocation strategy. Asset allocation is a strategy for diversifying investment assets among various types of investments or asset classes with the potential to move you toward your financial goals while mitigating portfolio risk. Diversification helps you spread risk throughout your investment portfolio. Different asset classes have different risk and potential return profiles, and they perform differently in different market conditions. Diversification will not guarantee a profit or protect against a loss. Any estimated returns, estimated asset values, and historical performance should not be used to project the performance of specific assets you currently own or may purchase. As with all investment strategies, past performance is no guarantee of future results. In addition, forecasts of future performance of financial markets may prove to be incorrect. You will be responsible for designating the securities in your allocation, as well as setting the Security Target percentage for each position. As part of activating a Security Target, you will select a rebalancing frequency interval (a “Frequency Interval”). The Frequency Intervals are quarterly (91 days), semi- annually (182 days), and annually (370 days). While these frequency intervals are generally long enough that you will not incur a short-term redemption fee from a mutual fund, it is possible that you will incur such a fee. When choosing the mutual funds to put in your Security Target, you should consider this. When you select a rebalancing Frequency Interval, the next rebalancing date (the “Rebalancing Date”) will be on or about the day following the end of the Frequency 25 Interval you have chosen in your most recent Security Target or the actual day that we were able to effect the automatic rebalancing in your Managed Account, whichever is later. The only permissible reason for a delay is an operational delay as described below. If you want to add to, delete, or otherwise modify your Security Target, you will confirm the change with your financial advisor. All Security Target modifications or activations will not be implemented until a minimum of a calendar quarter has elapsed. You will receive a confirmation letter setting forth your newly activated, modified, or inactivated Security Target. Notify your financial advisor immediately if the instructions confirmed to you are incorrect. account is subject to a trade correction, technology failures, operational failures, high trading volumes, corporate reorganizations, unusual market conditions, or any other condition which impedes our ability to process your instructions accurately. If automatic rebalancing has been delayed, generally it will take place in the next market session, however, we will attempt to rebalance your Managed Account on successive days for up to five (5) business days. If we have tried to rebalance your Managed Account five successive times and each rebalance has failed, your Security Target will be inactivated. Additionally, we will automatically inactivate your Security Target if we receive notice of death, divorce, or in the case where we receive returned/undeliverable mail. In each case, you will receive notice of your Security Target becoming inactivated. We will report any trades executed in connection with the Feature to you in your monthly account statement for the month in which the transaction took place. Eligible Assets and Eligible Securities. Only certain types of assets and securities are eligible for the Feature. The security types eligible for the Feature include mutual funds, ETFs, traded CEFs, and individual equities. Assets held on margin are ineligible for the Feature. Only securities already owned in your Managed Account may be a part of your Security Target. A rebalancing will fail if: the account has a pending or unprocessed trade correction, the Security Target includes a security that is not held in the account, the account becomes restricted from trading, a position is held on margin, the Security Target includes a mutual fund position that is not eligible for trading, or the account becomes ineligible to purchase additional shares of a mutual fund included in the Security Target. You can deposit cash, transfer in securities, or make additional purchases at any time while enrolled in the Feature. Additional cash deposited into your Managed Account may be invested at any time as you instruct. Cash in your Managed Account that exceeds the Security Target percentage will be automatically invested in accordance with your Security Target the next time your Managed Account rebalances. Margin Balances Held in SPS Advantage Accounts. The Rebalancing Process. Automatic rebalancing will be accomplished by buying and selling eligible securities. Overweighted securities will be sold and underweighted securities will be purchased, provided the transactions required to rebalance the Account meet the minimum trade requirement of $100. When rebalancing, the Feature will calculate whether the eligible securities included in the Security Target are over or underweight their target percentage relative to each other when calculating the automatic rebalancing; it will not take the value of Non-Target Securities into account and Non-Target Securities will not be rebalanced as a part of the Feature. Also, when you choose a security to be included in your Security Target, any purchases or transfers into your Managed Account of that same security will be included in and subject to your Security Target and rebalanced on the next Rebalancing Date, if applicable. Both pledge loans and margin are available in non- qualified SPS Advantage Accounts; however, you may not utilize both margin lending features and a pledge line of credit in the same Account. This section covers the specific benefits, costs and risks of using margin in a non-qualified SPS Advantage Account. For details regarding the Ameriprise Preferred Line of Credit and conflicts of interest associated with both types of products, see the “Securities-Based Lending Solutions” section. Automatic rebalancing will generally occur on or about the day after the last day of the Frequency Interval from the date your last Security Target instruction was accepted or the last automatic Rebalancing Date, whichever was later. The only permissible reason for a delay is an operational delay as described below. Such transactions generally result in tax consequences in non-qualified SPS Advantage Accounts. Investing on margin involves the extension of credit to you and your financial exposure could exceed the value of your securities. Ameriprise Financial Services, in its sole discretion, may approve your Managed Account for margin trading. Margin lending has specific risks outlined in the Margin Risk Disclosure document; review that document before opening a margin account. We may only delay processing your instructions under circumstances related to operational issues associated with the Security Target, and the delay may only persist to the extent that these operational issues impede our ability to process your instructions, including but not limited to: a Rebalancing Date falling on a day other than a business day, the Rebalancing Date falling on a day your Asset-based Fee is being deducted, the 26 Considerations Include: • margin activity in your SPS Advantage Account, the incremental fees paid to Ameriprise Financial Services and its affiliates may be significantly higher than in the absence of margin or than might otherwise be paid pursuant to a standard margin arrangement with us or another broker-dealer. The following is a hypothetical illustration of the impact on the compensation received by Ameriprise Financial Services and its affiliates. It compares an SPS Advantage Account that does not engage in margin activity to an Account with a margin arrangement with respect to 30% of the SPS Advantage Account assets. A decline in the value of securities that are purchased on margin or are in a margin account may require you to provide additional funds to AEIS to maintain your position and/or to maintain sufficient assets in the Sweep Program to meet fee requirements. If you do not provide the required additional funds or securities within the prescribed time, we will determine which securities to liquidate to address any margin call and can liquidate all or a portion of your holdings. You will be liable for any resulting deficit in your Managed Account. • Without buying on Margin With buying on Margin Account Value $100,000 $100,000 You can lose more funds than you deposit in the margin account. Margin trading can work against you as well as for you, leading to, for example, larger losses as well as the potential for larger gains. n/a $130,000 • Margin may be approved only for non-qualified SPS Advantage Accounts. Revised Account value including assets purchased on margin • $2,000 $2,600 Annual Asset-based Fee received by Ameriprise Financial Services (based on 2.0% Asset-based Fee) Tax-qualified SPS Advantage accounts, such as accounts established under the Employee Retirement Income Security Act of 1974 (“ERISA”), IRAs and Tax-Sheltered Custodial Accounts (“TSCAs”) are not available for margin accounts. n/a $1,800* • Margin interest received by AEIS $2,000 $4,400 Total Asset-based Fee and margin interest received by Ameriprise Financial Services and affiliates** Only one account per ownership registration (e.g., individual, joint) is allowed to establish margin at Ameriprise. For example, if you have already established margin borrowing in an Ameriprise brokerage account in an individual ownership, an SPS Advantage Account in the same individual ownership will not be approved for margin unless margin trading is removed from the Ameriprise brokerage account. • * This Assumes average daily outstanding margin loan balance of $30,000 over one-year period and 6% interest rate. For current interest rates consult your financial advisor. ** This example does not include any product-level fees that may be received by Ameriprise Financial Services on the mutual fund portion of the SPS Advantage Account(s). If these fees were included, total fees received by Ameriprise Financial Services would be higher. If you acquire/hold securities positions on margin, any margin account balance in SPS Advantage will be included in the calculation of your Asset-based Fee for that period. Therefore, if you engage in margin activity your Asset-based Fee will be higher and Sweep Program maintenance requirements will be impacted to the extent of the margin exposure. SPS Advisor Fees and Compensation Associated with Margin Activity. If you purchase securities in your non-qualified SPS Advantage Account using margin you will be subject to interest charges for the extension of credit in the margin account in addition to your Asset-based Fee based on total assets under management. In addition, your Asset- based Fee will increase as the value of your Managed Account increases and the compensation earned by your financial advisor will similarly increase. In situations where you engage in SPS Advisor is a discretionary Service that enables your SPS Discretionary Advisor to direct the purchase or sale of eligible securities and/or investment products within a single account on your behalf. Advisory Shares are the primary share class for mutual funds offered for purchase in SPS Advisor Accounts. The term SPS Discretionary Advisor refers to each individual that has discretionary authority to purchase or sell securities in your SPS Advisor Account without seeking your prior approval for each trade. Your financial advisor may be a part of a team. In this scenario, there may be more 27 statement. Such annuities and life insurance policies are not held in your Managed Account and any values provided by third parties are not validated by us. You will not receive recommendations or investment advice related to such annuities and life insurance policies as part of the SPS Advisor Service and the dollar value of any such annuity or life insurance policy is excluded from any portion of the Asset-based Fee calculation. than one SPS Discretionary Advisor authorized to use discretion on your Managed Account. For example, in the instance your SPS Discretionary Advisor(s) becomes unavailable or incapacitated, your Managed Account may temporarily be managed, and securities purchased and sold, by a designated back-up SPS Discretionary Advisor for the individual or team. Your primary, or servicing financial advisor, will recommend the Managed Account or AFPS, negotiate the Advisory Fee with you, and oversee the analysis and advice prepared for you. Your servicing financial advisor may or may not be your SPS Discretionary Advisor. In the instance that your servicing financial advisor is not your SPS Discretionary Advisor, your SPS Discretionary Advisor will oversee the analysis and investment advice prepared for you. Dividends and distributions received on your investments held in your SPS Advisor Account may be reinvested, where allowed, if selected by you. The reinvestment of equity, ETF, preferred security, CEF or UIT dividends will generally result in the purchase of a fractional share as further described in the “Fractional Shares and Principal Transactions” sub-section of the “Brokerage Practices” section and in the Relationship Agreement. Where reinvestment is not allowed or selected, your dividends and distributions will be deposited in your Sweep Program. Your SPS Discretionary Advisor will purchase and sell securities in your Managed Account that are suitable for you and consistent with your investment objectives, time horizon, financial situation, risk tolerance and in consideration of each Account’s asset allocation. You must promptly notify your financial advisor if these factors change. SPS Advisor Accounts are not appropriate for day trading, highly active traders, or other excessive trading activity, including trading mutual funds based on market timing. Such short- term trading activity may result in a short-term redemption fee from a mutual fund. Included among the available mutual funds for a non- qualified SPS Advisor Account are mutual funds which are managed or sub-advised by our affiliate, CMIA. For more information on fund families and mutual funds offered in our Managed Account Services including the applicable Advisory Share class or other share class utilized, please contact your financial advisor or refer to our Mutual Fund Screener Tool. Access the tool by logging into your Ameriprise Secure Site account and navigating to the “Trade & Research” and then, “Screeners” followed by Mutual Fund. From there, apply the Product Type filter and choose either SPS Advantage or SPS Advisor to view the funds and share classes available for purchase. See the “Revenue Sources for Ameriprise Financial Services, LLC” section regarding compensation for the sale of mutual funds. Your SPS Discretionary Advisor will not have the ability to withdraw, disburse or transfer funds or securities from your SPS Advisor Account without your prior authorization. You may impose Reasonable Restrictions on your SPS Advisor Account(s) by working with your financial advisor to reflect your restriction request(s). Although your SPS Discretionary Advisor will exercise discretion in your Managed Account, the performance of your Managed Account(s) will not be monitored on a day-to-day basis. Education and Business Standards Ameriprise Financial Services will determine whether an SPS Advisor Account is suitable upon account opening and thereafter. Ameriprise Financial Services, with thirty (30) days prior notice, also reserves the right to limit or close any Account if it is determined that the Program is no longer suitable for you. See the “Terminating a Relationship Agreement” section for more detail and for information regarding your right to terminate your SPS Advisor Account(s). Ameriprise Financial Services also reserves the right, with thirty (30) days prior notice, to transfer your SPS Advisor Account into an SPS Advantage Account as further described in the Relationship Agreement, which are available from your financial advisor and online at www.ameriprise.com/disclosures. As a courtesy, annuities and life insurance policies may be displayed on your Managed Account Financial advisors can choose whether or not to pursue certification as an SPS Discretionary Advisor and participate in the SPS Advisor Program. In order for a financial advisor to become eligible to provide discretionary investment management services to you in the SPS Advisor Program, Ameriprise Financial Services requires that financial advisors become certified as an SPS Discretionary Advisor. A financial advisor can become certified by meeting certain eligibility requirements and completing required training. Eligibility requirements include a minimum number of years of relevant experience, a particular level of assets under management, and industry certifications such as an Accredited Portfolio Management AdvisorSM (“APMA®”) program certificate or a Chartered Financial Analyst®(“CFA®”) or Certified Investment Management Analyst®(“CIMA®”) certification. Ameriprise Financial Services reserves the right to deny and withdraw a 28 Signature Wealth financial advisor's ability to offer SPS Advisor Accounts even though the financial advisor otherwise meets our certification requirements. SPS Discretionary Advisors are also subject to ongoing reviews to maintain their eligibility to continue offering discretionary investment management services to you in the SPS Advisor Program. These reviews and the eligibility requirements we impose may be a disincentive for a financial advisor to participate in the SPS Advisor Program and offer SPS Advisor Accounts. Methods of Analysis Your financial advisor will review your financial and investment needs, objectives and risk tolerance. Your SPS Discretionary Advisor may use asset value, current yield, yield projections, historical yield analysis, as well as other assumptions you provide, to make investment decisions. Investment decisions will generally be made in consideration of an asset allocation strategy. Asset allocation is a strategy for diversifying investment assets among various types of investments or asset classes with the potential to move you toward your financial goals while managing your risk tolerance. Diversification helps you spread risk throughout your investment portfolio. Different asset classes have different risk and potential return profiles, and they perform differently in different market conditions. The Signature Wealth Program, a flexible Unified Managed Account, is a discretionary investment advisory program, which offers clients the ability to combine multiple investment types such as mutual fund and ETF model investment portfolios, SMA model investment portfolios, and individual mutual funds/ETFs in an asset allocation within a single Account. With the assistance of your financial advisor, you will determine your investment objective, risk tolerance, and time horizon that will form the basis of your target asset allocation. From your Client Information, your financial advisor will create a personalized Signature Wealth Proposal and recommend investments from a broad range of model investment portfolios that are constructed by Signature Wealth Investment Providers and eligible mutual funds and ETFs to fulfill your Signature Wealth Account target asset allocation. You can further customize and round out the asset allocation in your Managed Account with a client directed model, the portion of your Managed Account that is not invested in model investment portfolios and where you select from individual eligible mutual funds and ETFs to hold in your Managed Account in addition to the model investment portfolio(s). A minimum of one model investment portfolio must be selected to participate in this Program. A client directed model is not required to participate in this Program. Advisory Shares are the primary share class for mutuals funds offered for purchase in a Signature Wealth Account. TSCA accounts are not eligible to invest in Signature Wealth. Diversification will not guarantee a profit or protect against a loss. Neither estimated returns, estimated asset values, nor historical performance should be used to project the performance of specific assets you currently own or may purchase. As with all strategies, past performance is no guarantee of future performance. In addition, forecasts of future performance of financial markets may prove to be incorrect. In addition, your SPS Discretionary Advisor will choose investments that are comprised of an appropriate portfolio mix, based on a variety of factors such as your age, risk tolerance, objectives, time horizon and historical performance of different asset classes. Keep in mind, however, that asset allocation analysis does not provide a comprehensive financial analysis of your ability to reach your goals, nor does it guarantee against losses in your portfolio. While financial advisors do not pay transaction charges for trades they enter online, franchisee financial advisors are assessed a transaction charge if entering an order by phone. For employee financial advisors, this transaction charge is assessed to the employee’s branch. Payment of phone-in transaction charges in SPS Advisor accounts may be a disincentive for a financial advisor to recommend an SPS Advisor Account or to place such trades in the Account(s). For Accounts in the Signature Wealth Program, all discretionary investment management is provided by the Signature Wealth Investment Manager, a third-party Advisory Service Provider. The Signature Wealth Investment Manager has the discretionary authority to purchase or sell securities or make other investments for your Managed Account; however, you directly own the underlying securities in the portfolio. Your financial advisor provides recommendations regarding which model investment portfolios, mutual funds and ETFs to hold in your Signature Wealth Account. The Signature Wealth Investment Manager, not your financial advisor, will provide you with investment management services for your Signature Wealth Account according to your Managed Account’s target asset allocation and the model investment portfolios, mutual funds and ETFs you select. The Signature Wealth Investment Manager will manage the assets in your Managed Account(s) according to your Account’s target asset allocation, subject to any Reasonable Restrictions or other instructions provided by you. 29 the following steps: Ameriprise Financial Services will (i) first close the SMA strategy in the Select Separate Account Program to new investments prior to offering the SMA strategy in the Signature Wealth Program; (ii) generally allow pending new accounts for the SMA strategy to continue to be processed in the Select Separate Account Program; and (iii) subsequently migrate existing accounts investing in the SMA strategy from the Select Separate Account Program into the Signature Wealth Program. If you have chosen to add a client directed model to your portfolio, you will work with your financial advisor to select the investments that make up your client directed model. The Signature Wealth Investment Manager has trading discretion over any client directed model and will be responsible for all trading and rebalancing of your client directed model along with the model investment portfolios you selected to maintain your Managed Account’s target asset allocation. In instances where a particular mutual fund or ETF is no longer eligible for use in the Signature Wealth Program, the Signature Wealth Investment Manager has limited investment discretion to select a replacement mutual fund or ETF for your client directed model. During this transition phase, if you hold an impacted SMA strategy in an existing Select Separate Account the Platform Fee rate you pay is higher for your Select Separate Account than it would be if you held the same SMA strategy in the Signature Wealth Program. As your Select Separate SMA strategy goes through this transition, Ameriprise Financial Services will notify you. Your Signature Wealth Account will generally only rebalance when (i) you make deposits into or withdrawals from the Signature Wealth Account, (ii) annually at least every 370 days, or (iii) when requested. However, if you make a change to your model investment portfolios or asset allocation, your Managed Account will be rebalanced to align with the appropriate asset allocation in effect for your investment objective and risk tolerance. Such rebalancing transactions generally result in tax consequences in non-qualified accounts. Your annual rebalance date will reset each time your Managed Account rebalances. The Signature Wealth Investment Manager will rebalance and reallocate your Signature Wealth Account, across each model investment portfolio and if applicable any client directed model. You may request Reasonable Restrictions on your Managed Account(s) by working with your financial advisor to complete and sign appropriate documents to reflect your restriction request(s). The Signature Wealth Investment Manager must accept any Reasonable Restrictions before they will be binding on the Account(s). If a Reasonable Restriction is accepted any impacted position(s) will be removed from the applicable model investment portfolio or client directed model and the proceeds reallocated to the remaining positions in any impacted model investment portfolio or client directed model on a pro rata basis. This creates a conflict of interest as Ameriprise Financial Services receives a higher Platform Fee for Select Separate Accounts than we receive for Signature Wealth Accounts, including the transition period when the same SMA strategy is held in both Programs. Ameriprise Financial Services addresses this conflict through a combination of disclosures and by closing any duplicative SMA strategies through the transition process described above. Additionally, the transition process does not impact the Manager Fee that compensates the Advisory Service Provider and does not affect the portion of the Asset-based Fee received by your financial advisor. However, the transition process will result, for a limited period of time, in Sponsor receiving a higher Platform Fee from impacted SMA strategies held within Select Separate Accounts than it would from the same SMA strategy invested in Signature Wealth Accounts. Beginning in the second half of 2026, Ameriprise Financial Services plans to eliminate this conflict of interest by migrating any Select Separate Account with an impacted SMA strategy from the Select Separate Account Program to the Signature Wealth Program, in accordance with the Relationship Agreement. As noted above, when your Select Separate Account SMA strategy is a part of this transition, Ameriprise Financial Services will notify you so that you may work with your financial advisor to transition your Select Separate SMA Account to the Signature Wealth Program at a date of your choosing so that you can benefit sooner from the reduced Platform Fee rate the Signature Wealth Program provides. Dividends and distributions received on your investments held in your Signature Wealth Account may be reinvested, where allowed, if selected by you. Inclusion and Management of Advisory Service Providers The following summarizes Ameriprise Financial Services’ research, due diligence and contractual efforts in connection with the inclusion of Advisory Service Providers in the Signature Wealth Program. Certain SMA strategies that are currently available in the Select Separate Account Program are / or will become available in our Signature Wealth Program as our initial step to transition such SMA strategies from the Select Separate Account Program into the Signature Wealth Program. The full transition process will include 30 Review of Advisory Service Providers Ameriprise Financial Services’ Contractual Relationship with Advisory Service Providers Ameriprise Financial Services conducts initial and ongoing reviews of the Signature Wealth Investment Manager and the available Signature Wealth Investment Providers, as further described in the “Advisory Service Providers” section. The Signature Wealth Investment Manager and each of the Signature Wealth Investment Providers have entered into a master advisory agreement with Ameriprise Financial Services, which governs the relationship and responsibilities of the respective parties. You may pay a Manager Fee for any of the Signature Wealth Investment Providers, you will pay the Signature Wealth Investment Manager a fee for their services. See “Fees and Compensation” section below for more information. Ameriprise Financial Services seeks to identify and make available a range of model investment portfolios within the Signature Wealth Program to provide clients with a choice of investment styles and corresponding risk levels. The evaluation process consists of gathering information on the Signature Wealth Investment Provider candidates from published materials, questionnaires and interviews. Screening factors are both quantitative and qualitative and include (but are not limited to): (i) management style and total assets under management; (ii) assets managed in a particular investment style; (iii) number of years the firm has managed assets; and (iv) the number and qualifications of investment professionals employed. Each evaluation factor may have a different weighting in the decision- making process. Generally, no one factor determines the outcome of any selection. Certain Signature Wealth Investment Providers may employ one or more affiliates to perform certain aspects of their portfolio construction, administrative support, sales and marketing for one or more model investment portfolios. In these situations, the affiliate is subject to the same duties and obligations as the Signature Wealth Investment Provider, including adherence to the master advisory agreement with Ameriprise Financial Services. In delegating responsibilities to an affiliate, the Signature Wealth Model Provider would not be relieved of any of its duties or obligations and remains responsible for the acts and omissions of the affiliate as if such acts and omissions were its own. Your Selection of Signature Wealth Firms, including affiliates of Ameriprise Financial Services, which pass the evaluation process are subject to a structured due diligence review by IRG. Ameriprise Financial Services may identify actual or potential concerns regarding a particular Signature Wealth Investment Provider as a result of the review and may request that the Signature Wealth Investment Provider take corrective action to address such concerns. These reviews may also result in the removal of a Signature Wealth Investment Provider from the Program. Education and Business Standards The investment advisory personnel employed by Advisory Service Providers participating in the Signature Wealth Program must meet certain educational, business and personnel requirements. The minimum educational requirement for an individual providing investment advice is a college degree and completion of further financial service industry certifications such as the CFA, FINRA Series 7, 63, 65 and 66 licenses, or comparable education or work experience. Ameriprise Financial Services’ research personnel seek to identify, and encourage participation by, Advisory Service Providers whose personnel have additional professional qualifications, including graduate degrees or a CFA designation. In addition, suitable work experience in the financial services industry is considered as part of an individual’s overall qualifications. Your financial advisor will discuss your financial objectives and other factors such as your risk tolerance, investment objectives, and important information regarding the Signature Wealth Program, the Signature Wealth Investment Manager and the available Signature Wealth Investment Providers. Based on the Client Information you provided, you and your financial advisor will work together to create a Signature Wealth proposal which will provide you with a target asset allocation for your Managed Account along with recommendations for model investment portfolios and as applicable, a client directed model of individual mutual funds and / or ETFs to round out your target asset allocation. Your financial advisor will recommend and you may select one or more Signature Wealth Investment Providers from the list of available model investment portfolios. Included in the available model investment portfolio list is Columbia Management Capital Advisers, an operating division of CMIA, an affiliate of Ameriprise Financial Services. When you select your investments and agree to establish a Signature Wealth Account, you will be giving discretion of your Signature Wealth Account to the Signature Wealth Investment Manager. To assist you in making your decision, you will be provided with a copy of the Signature Wealth Investment Manager’s disclosure brochure document (Part 2A of Form ADV) and you will be provided with access to the Signature Wealth Model Provider’s disclosure document (Part 2A 31 withdraw, disburse or transfer funds or securities from your Managed Account without your prior authorization. Limitations on Security Type of Form ADV), which includes important information regarding the Advisory Service Providers. Your financial advisor will also provide you with Signature Wealth Model Provider Fact Sheets for the model investment portfolios you selected for your Signature Wealth Account. Please note that past performance is not an indication of future results. Composite performance information included on the Signature Wealth Fact Sheet has been provided by the Signature Wealth Investment Provider. In general, these composites are created quarterly on an asset and time-weighted basis using month-end market values and returns. Your financial advisor can provide you with the Signature Wealth Fact Sheets for specific composite performance information regarding each model investment portfolio available. Except as may be provided in connection with the Sweep Program, in general, the Signature Wealth Investment Manager may not directly invest your assets in cash equivalent securities or instruments such as money market securities, certificates of deposit, time deposits, banker’s acceptances or repurchase agreements; or options, futures or other derivative instruments; however these types of securities may be included in the underlying holdings of the mutual funds and ETFs recommended by the Signature Wealth Investment Providers and utilized by the Signature Wealth Investment Manager. These types of assets are also generally not accepted for deposit in connection with establishing a new Account. Prospectus Delivery to Signature Wealth Investment Manager Ameriprise Financial Services requires each Signature Wealth Investment Provider to meet Ameriprise Financial Services’ performance validation standards, however Ameriprise Financial Services does not review the appropriateness of the methodologies used by the Signature Wealth Investment Providers to calculate the underlying historical performance information presented in the Signature Wealth Fact Sheet, nor does Ameriprise Financial Services audit the mathematical accuracy of the Signature Wealth Model Provider’s performance information. Ameriprise Financial Services does restate the performance after deducting the highest annual Asset-based Fee when presenting the performance on a net basis. Prospectuses contain detailed information about the fees and expenses charged by, and the past performance of, the investments held in your Managed Account(s). With your authorization and appointment as your agent for delivery, the Signature Wealth Investment Manager will receive prospectuses on your behalf for the mutual funds and ETFs purchased in your Signature Wealth Account investments within the model investment portfolios. Information regarding your Managed Account’s holdings of, and transactions in, mutual funds and ETFs will be available on the secure site at amerprise.com and in your Ameriprise Financial statements. Review the Signature Wealth Investment Manager and as applicable, the Signature Wealth Model Provider’s disclosure document (Part 2A of Form ADV), this Disclosure Brochure Supplement, the Disclosure Brochure and the applicable Signature Wealth Investment Providers Fact Sheet(s) prior to selecting a Signature Wealth Account. Each Signature Wealth Model Provider’s disclosure document is available to you at ameriprise.com/investmentproviders. Acceptance of Your Signature Wealth Account You retain the right to receive any prospectuses that are delivered to the Signature Wealth Investment Manager on request and at any time by requesting a copy from your financial advisor or by contacting us at 800.862.7919. You may also access the prospectuses for the mutual funds and ETFs held in your Signature Wealth Account(s) via the fund family’s website. If you prefer to receive the information that is contained in prospectuses, please contact your financial advisor or us at the number above and we will provide them to you. In this case, Ameriprise Financial Services will deliver prospectuses for the investments held in your Signature Wealth Account(s) directly to you in accordance with your document delivery preference. If you elect a client directed model, the prospectuses related to the mutual funds and/or ETFs held will be directed to you. You may not direct these prospectuses to the Signature Wealth Investment Manager. Ameriprise Financial Services will determine, on behalf of the Signature Wealth Investment Manager, whether to accept or reject a prospective client and related Account based upon the Client Information. Once your Managed Account is accepted, you will become an investment management client of the Signature Wealth Investment Manager. The Signature Wealth Investment Manager will have discretionary authority as described above to act on your behalf for purchases, sales and other transactions in your Signature Wealth Account, including sales with respect to securities transferred in-kind to the account, without seeking your approval. Such transactions generally result in tax consequences in non-qualified accounts. Your Signature Wealth Investment Manager will not have the ability to 32 Methods of Analysis changes to the selected investments within your Managed Account, as well as other relevant information to help them monitor these discretionary Account(s). Transferred Accounts The following information applies generally to the Investment Managers and Investment Providers available in Managed Accounts Programs. Investment Managers and Investment Providers may utilize different techniques for buying and selling securities, which are often unique to the investment strategies they manage. Fundamental analysis is the most common method used and typically involves the development of a thorough understanding of fundamental features of a business through analysis and interpretation of company and industry data, such as revenue, expenses, assets, liabilities, management, industry position and other factors, in order to evaluate a security. You may wish to transfer a model investment portfolio that you hold at another investment advisory firm to Ameriprise Financial Services. If this model investment portfolio is offered in the Ameriprise Signature Wealth Program, you may transfer the account to your Signature Wealth Account. Upon receipt, the investment will be rebalanced into your Managed Account in accordance with your Signature Wealth Account’s target asset allocation within your Signature Wealth proposal, which may result in different investment positions and/or allocation of such positions than the model investment portfolio you held at the prior advisory firm. If your current model investment portfolio is not available in the Ameriprise Signature Wealth Service, your financial advisor will assist you with identifying other appropriate alternatives. Active Portfolios® Certain Investment Managers and Investment Providers may also use quantitative methods of analysis, which is computer-based and uses mathematical and statistical modeling to value securities, markets or investment opportunities. Technical analysis may also be used, involving the analysis of market data. Investment Managers and Investment Providers may employ one or more methods of analysis, with varying degrees of focus on certain attributes and techniques. Review and Update of Client Information Active Portfolios® is a discretionary Program that enables you to invest in actively managed portfolios comprised of mutual funds and/or ETFs. Advisory Shares are the primary share class for mutual funds offered for purchase in Active Portfolios® Accounts. Your financial advisor will review your Client Information and Signature Wealth Account’s performance and compatibility with respect to your Managed Account’s target asset allocation, risk tolerance and time horizon with you. All discretionary investment management is provided by the Signature Wealth Investment Manager, a non-affiliated third-party Advisory Service Provider that serves as the Investment Manager for all Active Portfolios® Accounts. Investment Providers deliver asset allocation and investment selection recommendations for their specific portfolio(s) to the Investment Manager. If there are changes to your Client Information, your financial advisor will inform Ameriprise Financial Services of any changes to your Client Information. Your financial advisor may also provide research and analysis regarding the target asset allocation and select model investment portfolios to you and recommend changes based on any changes to your Client Information. If there have been changes to your Client Information, your financial advisor may recommend updates your Signature Wealth Account’s target asset allocation and/or model investment portfolios. Your financial advisor will review the updated proposal with you and based on your review and acceptance, your financial advisor will then submit your updated proposal to Ameriprise Financial Services. Ameriprise Financial Services will inform and provide the Signature Wealth Investment Manager with your updated information and requested changes. The Investment Manager has discretionary authority to purchase or sell securities or make other investments for your Managed Account; however, you directly own the underlying securities in the portfolio. The Investment Manager invests your Managed Account assets in the portfolio you select with your financial advisor and is responsible for the ongoing investment management and trading of your Active Portfolios® Account, subject to any Reasonable Restrictions or other instructions you provide. Your financial advisor provides recommendations regarding which portfolio to hold in your Active Portfolios® Account. The Investment Manager—not your financial advisor or the Investment Provider—provides discretionary investment management services for your Active Portfolios® Account in accordance with your Managed Account’s target asset allocation and the portfolio you select. Ameriprise provides the Signature Wealth Investment Manager with ongoing updates of Client Information and Account information, such as updates to your Managed Account’s target asset allocation and Ameriprise Financial Services offers a variety of Active Portfolios® investments that are designed to help meet 33 your investment growth and/or income needs. TSCA Accounts are only eligible to invest in Active Diversified Portfolios® investments. You retain the right to receive any prospectuses that are delivered to the Investment Manager on request and at any time by requesting a copy from your financial advisor or by contacting us at 800.862.7919. You may also access the prospectuses for the mutual funds and ETFs held in your Active Portfolios® Account(s) via the fund family’s website. CMIA, an affiliate of Ameriprise Financial Services, is the Investment Provider of the following Active Portfolios® investments Active Accumulation Portfolios® (only available for non-qualified Accounts) and Active Risk Portfolios®. Non-qualified Active Accumulation Portfolios®, and Active Risk Portfolios® are designed to primarily invest in, and therefore favor, Columbia mutual funds managed by CMIA. The Columbia Management Asset Allocation Team determines the asset allocation at the portfolio level and selects the investments to be included in the portfolios. If you prefer to receive the information that is contained in prospectuses, please contact your financial advisor or us at the number above and we will provide them to you. In this case, Ameriprise Financial Services will deliver prospectuses for the investments held in your Active Portfolios® Account(s) directly to you in accordance with your document delivery preference. Ameriprise Financial Services and our affiliates receive greater revenue when you select a portfolio managed by CMIA than if you select another Active Portfolios® investment. In the event our master investment advisory agreement with your Investment Manager does not provide for the receipt of certain or all prospectuses on behalf of clients, you will receive such prospectuses directly. Inclusion and Management of Active Portfolios® Investment Managers The following summarizes Ameriprise Financial Services’ research, due diligence and contractual efforts in connection with the inclusion of Advisory Service Providers in the Active Portfolios® Program. Investment Manager for Active Portfolios® investments may select mutual funds and/or ETFs. In general, the selected mutual funds are among the fund families that fully participate in the Ameriprise Financial Services mutual fund program. Program participants pay cost reimbursement payments to AEIS, as described in the “Cost Reimbursement Services and Third-Party Payments” section. Review of Advisory Service Providers You may request Reasonable Restrictions on your Active Portfolios® account(s) by completing and signing the appropriate document reflecting your request. Ameriprise Financial Services and the applicable Investment Manager(s) must accept any Reasonable Restrictions before they will be binding on the Account(s). Ameriprise Financial Services conducts initial and ongoing reviews of the Investment Providers and their applicable investment strategies and investment advisory services available or utilized in Active Portfolios® investments as further described in the “Advisory Service Providers” section. From time to time, the IRG personnel will conduct searches to identify new Advisory Service Providers for Active Portfolios®. These recommendations are presented to the Oversight Committee for inclusion in Active Portfolios®. The Investment Manager will determine whether to reinvest dividends, interest and distributions received on the investments held in your Active Portfolios® Account. Where reinvestment of dividends is not allowed, dividends, interest and distributions will be deposited into your Sweep Program. Prospectus Delivery to Investment Managers In addition, IRG conducts periodic reviews of the Advisory Service Providers. These reviews are based on applicable information gathered from various sources including disclosure documents, questionnaires, portfolio performance, assets under management, personnel changes, portfolio turnover and other factors as Ameriprise Financial Services deems appropriate. Ameriprise Financial Services periodically provides information from these reviews to financial advisors servicing Active Portfolios® investments. From time to time, these reviews may also result in Ameriprise Financial Services removing an Advisory Service Provider. Prospectuses contain detailed information about the fees and expenses charged by, and the past performance of, the investments held in your Managed Account(s). With your authorization and appointment as your agent for delivery, the Investment Manager for Active Portfolios® investments will receive prospectuses on your behalf for the mutual funds and ETFs purchased in your Active Portfolios® Account(s). Information regarding your Managed Account’s holdings of, and transactions in, mutual funds and ETFs will be available on the secure site at amerprise.com and in your Ameriprise Financial statements. 34 Education and Business Standards management client of the Investment Manager. Your Investment Manager will have full discretionary authority to act on your behalf for purchases, sales and other transactions in your Active Portfolios® Account, including sales with respect to securities transferred in-kind to the account, without seeking your approval. Such transactions generally result in tax consequences in non-qualified accounts. Your Investment Manager will not have the ability to withdraw, disburse or transfer funds or securities from your Managed Account without your prior authorization. For Active Portfolios® managed by CMIA or an unaffiliated Investment Providers, review the applicable Advisory Brochure (Part 2A of the Form ADV) for additional information about the Investment Manager’s advisory services and methods of analysis. The investment advisory personnel employed by the Investment Manager must meet certain educational, business and personnel requirements. The minimum educational requirement for an individual providing investment advice is a college degree and completion of further financial service industry certification such as CFA®, Financial Industry Regulatory Authority (“FINRA”) Series 7, 63, 65 and 66 licenses, or comparable education or work experience. Ameriprise Financial Services’ due diligence personnel seek to identify, and encourage participation by, Investment Managers whose personnel have additional professional qualifications, including graduate degrees or a CFA designation. In addition, suitable work experience in the financial services industry is considered as part of an individual’s overall qualifications. Investment Manager Review of Active Portfolios® Ameriprise Financial Services’ contractual relationship with Advisory Service Provider Ongoing updates of Active Portfolios® account information, including holdings and transaction information, as well as other relevant information are made available to the Investment Manager to help monitor the Active Portfolios® investments. Each Advisory Service Provider has entered into a master investment advisory agreement with Ameriprise Financial Services, which governs the relationship and responsibilities of the respective parties. Select Separate Account Your Active Portfolios® Selection Select Separate Account is a discretionary Program in which you may own a portfolio of individual securities, SMAs, ETFs, and/or mutual funds managed by a professional Advisory Service Provider in accordance with a single investment strategy or a combination of complementary strategies. Select Separate SMA strategies generally do not offer mutual funds. Where mutual funds are offered, Advisory Shares will be offered for purchase. TSCA Accounts are not eligible to invest in Select Separate Accounts. Your financial advisor will assist you in selecting one or more Active Portfolios® investments. Your financial advisor will discuss your financial objectives and other factors such as your risk tolerance, investment objectives, and important information regarding the Investment Manager. Your financial advisor will also provide you with the applicable Active Portfolios® investment fact sheet (“Active Portfolios® investment Fact Sheet”). The Active Portfolios® investment Fact Sheet includes biographical information about the Investment Manager and investment philosophy and style information, portfolio characteristics and composite performance. Past performance is not an indication of future results. The Oversight Committee, acting on behalf of Ameriprise Financial Services, is the Investment Manager of the Select ETF Portfolios that invest in a variety of non- proprietary ETF investments in partnership with Portfolio Strategists or Asset Allocation Strategists. Composite performance information included in the Active Portfolios® investment Fact Sheet is calculated by Ameriprise Financial Services. This composite performance information is shown both gross and net of the highest annual Asset-based Fees. These composites are created quarterly on an asset and time-weighted basis using month-end net asset values and returns. Ameriprise Financial Services also offers a series of portfolios consisting of SMAs, mutual funds and ETFs in a single account called Select Strategist UMA. These portfolios are managed by a non-affiliated Investment Manager with discretionary authority to purchase or sell securities or make other investments for your Managed Account. Acceptance of your Active Portfolios® Account Ameriprise Financial Services will determine, on behalf of the Investment Manager, whether to accept or reject a prospective client and related Account based upon the Client Information. Once your Managed Account is accepted, you will become an investment Each of the Portfolio Strategists and Asset Allocation Strategists for Select ETF Portfolios, as applicable, develops asset allocation models, conducts qualitative and/or quantitative research on mutual funds and ETFs, and constructs model portfolio recommendations, as applicable, to the Oversight Committee. The Oversight 35 through this transition, Ameriprise Financial Services will notify you. Committee reviews and approves these recommendations. The Oversight Committee may remove an Advisory Service Provider from the Select ETF Portfolios Service and/or adjust an asset allocation or model portfolio as appropriate. With the aid of your financial advisor, you select the appropriate Advisory Service Provider(s) in accordance with the Client Information you provide to your financial advisor. The Advisory Service Provider, not your financial advisor, will provide you with investment management services according to the investment strategy you select and the related investment objectives. Advisory Service Providers in the service will either serve as a discretionary Investment Manager over the assets in your Managed Account(s) or as a Model Provider. Model Provider will construct a model portfolio according to a specific investment strategy. The Model Provider will be independently responsible for the investment decisions it makes for the model portfolio strategy. The Oversight Committee will have discretionary trading authority over the assets in your Managed Account(s) to implement the Model Provider’s trading instructions for the model portfolio. You may request Reasonable Restrictions on your Managed Account(s) by working with your financial advisor to complete and sign appropriate documents to reflect your restriction request(s). Ameriprise Financial Services and the applicable Investment Manager(s) must accept any Reasonable Restrictions before they will be binding on the Account(s). This creates a conflict of interest as Ameriprise Financial Services receives a higher Platform Fee for Select Separate Accounts than we receive for Signature Wealth Accounts, including the transition period when the same SMA strategy is held in both Programs. Ameriprise Financial Services addresses this conflict through a combination of disclosures and by closing any duplicative SMA strategies through the transition process described above. Additionally, the transition process does not impact the Manager Fee that compensates the Advisory Service Provider and does not affect the portion of the Asset-based Fee received by your financial advisor. However, the transition process will result, for a limited period of time, in Sponsor receiving a higher Platform Fee from impacted SMA strategies held within Select Separate Accounts than it would from the same SMA strategy invested in Signature Wealth Accounts. Beginning in the second half of 2026, Ameriprise Financial Services plans to eliminate this conflict of interest by migrating any Select Separate Account with an impacted SMA strategy from the Select Separate Account Program to the Signature Wealth Program, in accordance with the Relationship Agreement. As noted above, if your Select Separate Account SMA strategy is a part of this transition, Ameriprise Financial Services will notify you so that you may work with your financial advisor to transition your Select Separate SMA Account to the Signature Wealth Program at a date of your choosing so that you can benefit sooner from the reduced Platform Fee rate the Signature Wealth Program provides. Inclusion and Management of Advisory Service Providers The following summarizes Ameriprise Financial Services’ research, due diligence and contractual efforts in connection with the inclusion of Advisory Service Providers in the Select Separate Program. Screening and Evaluation of Advisory Service Providers Concurrent with the addition of SMA model investment portfolios to the Signature Wealth Program in late 2025, certain SMA strategies that are currently available in the Select Separate Account Program will become available in our Signature Wealth Program as our initial step to transition such SMA strategies from the Select Separate Account Program into the Signature Wealth Program. The full transition process will include the following steps: Ameriprise Financial Services will (i) first close the SMA strategy in the Select Separate Account Program to new investments prior to offering the SMA strategy in the Signature Wealth Program; (ii) generally allow pending new accounts for the SMA strategy to continue to be processed in the Select Separate Account Program; and (iii) subsequently migrate existing accounts investing in the SMA strategy from the Select Separate Account Program into the Signature Wealth Program. During this transition, if you currently hold an impacted SMA strategy in an existing Select Separate Account, the Platform Fee rate you pay is higher for your Select Separate Account than it would be if you held the same SMA strategy in the Signature Wealth Program. If your Select Separate SMA strategy will go Ameriprise Financial Services seeks to identify a range of professional Advisory Service Providers to participate in the Select Separate Account Service in order to provide clients with a choice of investment styles and corresponding risk levels. The evaluation process consists of gathering information on the Advisory Service Provider candidates from published materials, questionnaires and interviews. Screening factors are both quantitative and qualitative and include (but are not limited to): (i) management style and total assets under management; (ii) assets managed in a particular investment style; (iii) number of years the firm has managed assets; and (iv) the number and qualifications of investment professionals 36 Provider receives the Manager Fee component of the Asset-based Fees paid by clients. employed. Each evaluation factor may have a different weighting in the decision-making process. Generally, no one factor determines the outcome of any selection. Firms, including affiliates of Ameriprise Financial Services, which pass the evaluation process are subject to a structured due diligence review by IRG. Review of Advisory Service Providers Certain Advisory Service Providers may employ one or more affiliates as sub-advisers for one or more investment strategies. In these situations, the sub- adviser is subject to the same duties and obligations as the Advisory Service Provider, including adherence to the master advisory agreement with Ameriprise Financial Services, and any reasonable restrictions imposed by clients. In delegating responsibilities to a sub-adviser, an Advisory Service Provider would not be relieved of any of its duties or obligations and remains responsible for the acts and omissions of the sub- adviser as if such acts and omissions were its own. From time to time, an Advisory Service Provider’s investment strategy that is currently available through Envestnet in the Vista Separate Account Program may become available in our Select Separate Account Program. In this instance, Ameriprise Financial Services will (i) close any duplicative investment strategies in the Vista Separate Account Program to new clients prior to offering such investment strategies in the Select Separate Account Program; (ii) generally allow pending Vista Separate Account Program Accounts for existing clients, and in certain instances new clients, to continue to be processed for transition purposes; and (iii) subsequently migrate such Vista Separate Account strategies into the same investment strategy in the Select Separate Account Program. Ameriprise Financial Services conducts initial and ongoing reviews of the Investment Managers, Investment Providers, Portfolio Strategists and Asset Allocation Strategists and their applicable investment strategies and investment advisory services available or utilized in the Select Separate Program as further described in the “Advisory Service Providers” section. This review is based on applicable information gathered from various sources, including disclosure documents, annual questionnaires and other data and reports received from Advisory Service Providers. The information provided to Ameriprise Financial Services includes composite performance, assets under management, personnel changes, portfolio turnover, trading practices and placement of client trade orders. Ameriprise Financial Services may identify actual or potential concerns regarding a particular Advisory Service Provider as a result of the review and may request that the Advisory Service Provider take corrective action to address such concerns. These reviews may also result in the removal of an Advisory Service Provider from the Service. Your Selection of an Advisory Service Provider Education and Business Standards The investment advisory personnel employed by Advisory Service Providers participating in the Select Separate Account Service must meet certain educational, business and personnel requirements. You may select one or more Advisory Service Providers from the list of participating professional asset managers. Included in the participating Advisory Service Providers is Columbia Management Capital Advisers, an operating division of CMIA, an affiliate of Ameriprise Financial Services. Ameriprise Financial Services may also act as an Investment Manager within the Select Separate Account Service. If you select CMIA as an Investment Manager, Ameriprise Financial Services may receive greater revenues than if you select an unaffiliated Advisory Service Provider. Contact your financial advisor for a current list of Advisory Service Providers participating in the Select Separate Account Service. The minimum educational requirement for an individual providing investment advice is a college degree and completion of further financial service industry certifications such as the CFA, FINRA Series 7, 63, 65 and 66 licenses, or comparable education or work experience. Ameriprise Financial Services’ research personnel seek to identify, and encourage participation by, Advisory Service Providers whose personnel have additional professional qualifications, including graduate degrees or a CFA designation. In addition, suitable work experience in the financial services industry is considered as part of an individual’s overall qualifications. Ameriprise Financial Services’ Contractual Relationship with Advisory Service Providers Each Advisory Service Provider has entered into a master investment advisory agreement with Ameriprise Financial Services through which the Advisory Service To assist you in making your decision regarding the selection of an Advisory Service Provider, you will be provided with a copy of the Advisory Service Provider’s disclosure document (Part 2A of Form ADV), which includes important information regarding the Advisory Service Provider. Your financial advisor will also provide you with the Strategy Fact Sheet for the Advisory Service Provider indicating whether it serves as Investment Manager or Model Provider, and which also includes biographical information, investment philosophy and style, portfolio characteristics, composite performance 37 an Investment Manager that does not invest in ETFs or mutual funds. Methods of Analysis and may include information, if applicable, about the Portfolio Strategist or Asset Allocation Strategist. Please note that past performance is not an indication of future results. Depending on the strategy, composite performance information included on the Strategy Fact Sheet may be calculated by the Ameriprise Financial Services or the Advisory Service Provider. In nearly all cases, these composites are created quarterly on an asset and time-weighted basis using month-end market values and returns. Your financial advisor can provide you with the Strategy Fact Sheet for specific composite performance information regarding each investment strategy available. The following information applies generally to Investment Managers participating in the Select Separate Account Service. For additional information on Investment Managers, please refer to Part 2A of the applicable Investment Manager’s Form ADV. Investment Managers utilize different techniques for buying and selling securities, which are often unique to the strategies they manage. Fundamental analysis is the most common method used and typically involves the development of a thorough understanding of fundamental features of a business through analysis and interpretation of company and industry data, such as revenue, expenses, assets, liabilities, management, industry position and other factors, in order to evaluate a security. Certain Investment Managers and third-party providers of model portfolios may also use quantitative methods of analysis, which is computer-based and uses mathematical and statistical modeling to value securities, markets or investment opportunities. Technical analysis may also be used, involving the analysis of market data. Ameriprise Financial Services requires each Advisory Service Provider to meet Ameriprise Financial Services’ performance validation standards, however Ameriprise Financial Services does not review the appropriateness of the methodologies used by Advisory Service Providers to calculate the underlying historical performance information presented in the Strategy Fact Sheet, nor does Ameriprise Financial Services audit the mathematical accuracy of the Advisory Service Provider’s performance information. Ameriprise Financial Services does restate the performance after deducting the highest annual Asset-based Fee when presenting the performance on a net basis. Investment Managers may employ one or more methods of analysis, with varying degrees of focus on certain attributes and techniques. Review and Update of Client Information Review the Advisory Service Provider’s disclosure document (Part 2A of Form ADV), this Disclosure Brochure and the Strategy Fact Sheet prior to selecting an Advisory Service Provider. Limitations on Security Type Your financial advisor reviews the Investment Manager’s performance and compatibility with respect to your Select Separate Account and may also provide research and analysis regarding the Investment Manager to you. Your financial advisor will then inform Ameriprise Financial Services if any information contained in the Client Information has changed or if you wish to make any other changes with respect to the Investment Manager(s) servicing. Except as may be provided in connection with the Sweep Program, in general, participating Investment Managers may not directly invest your assets in cash equivalent securities or instruments such as money market securities, certificates of deposit, time deposits, banker’s acceptances or repurchase agreements; or options, futures or other derivative instruments; however these types of securities may be included in the underlying holdings of the mutual funds and ETFs utilized by the Investment Manager. These types of assets are also generally not accepted for deposit in connection with establishing a new Account. Where Investment Manager has discretionary authority over the assets in your Managed Account, Ameriprise Financial Services provides Investment Managers ongoing updates of Account information, including holdings and transaction information, as well as other relevant information to help them monitor these discretionary Account(s). Transferred Accounts You may wish to transfer a separately managed account (“SMA”) that you hold at another investment advisory firm to Ameriprise Financial Services. This SMA strategy may not be available in the Ameriprise Select Separate Account Service. Contact your financial advisor to discuss other appropriate alternatives. Some participating Investment Managers may use ETFs and mutual funds as a part of their investment strategy that incur a separate and additional Investment Cost for its management fee which is assessed by the fund or ETF directly and is in addition to the Asset-based Fee charged by Ameriprise Financial Services. Due to Investment Costs, the use of ETFs and mutual funds by an Investment Manager may result in clients paying more than clients utilizing 38 Managed Accounts Offered with Envestnet Asset Management, Inc. Vista Separate Account The Vista Separate Account is a discretionary investment advisory Program offered on the Envestnet platform that gives you access to a selection of SMAs in a single or multi-account investment portfolio. Contact your financial advisor for a current list of available SMAs offered in a Vista Separate Account. Your financial advisor will help you customize a portfolio that includes multiple investment styles, such as domestic and international offerings. Separate Account Program to new clients prior to offering such investment strategies in the Select Separate Account Program; (ii) generally allow pending Vista Separate Account Program Accounts for existing clients, and in certain instances new clients, to continue to be processed for transition purposes; and (iii) subsequently migrate such Vista Separate Account strategies for all clients into the same investment strategy in the Select Separate Account Program. If you have a Vista multi-account portfolio, your Vista Statement of Investment Selection will be updated to remove the migrated strategy and reallocate its designated allocation among the remaining strategies on a pro rata basis. Investor Unified Account You will directly own individual securities when investing in an SMA. Envestnet and/or the Envestnet Manager will rebalance and reallocate the individual securities within each SMA. If you invest in multiple Vista Separate Accounts within your Vista Statement of Investment Selection, (a “Vista multi-account portfolio”) you will work with your financial advisor to designate a percentage allocation for each SMA included in your total Vista multi-account portfolio. Your Vista multi-account portfolio will be rebalanced to these designated allocations when you make deposits or withdrawals. You may also request a rebalance of your Vista multi-account portfolio at any time. Such transactions generally result in tax consequences in non-qualified accounts. The Investor Unified Account is a discretionary investment advisory Program that offers clients the ability to purchase SMAs, mutual funds and ETFs in an asset allocation within a single account managed by Envestnet. Advisory Shares are the primary share class for mutual funds offered for purchase in Investor Unified Accounts. Your financial advisor will help you to select from a broad range of SMAs, eligible mutual funds and ETFs in order to customize a portfolio for you. You must select at least one SMA in order to participate in this Program. In certain limited instances an SMA that is also available for new purchases and new contributions in the Access Account Program may also be available for selection in your Investor Unified Account. Envestnet and Ameriprise Financial Services have defined various risk-based asset allocation models available in the Investor Unified Account service. With the assistance of your financial advisor, you will determine your investment objective, risk tolerance, the appropriate asset allocation and then select the specific underlying investment vehicles for the asset allocation to meet your needs. You will receive an asset allocation and a personalized proposal based on your Client Information. Envestnet provides overlay management services for Investor Unified Accounts and you directly own the underlying securities in the portfolio. Your Managed Account will generally only rebalance when you make deposits into or withdrawals from the Account, on the Account’s anniversary date, or when requested. However, if you make a change to your investment vehicle selections or asset allocation model, your Managed Account will be rebalanced to align with the appropriate asset allocation model in effect for your investment objective and risk tolerance. From time to time, an Advisory Service Provider’s investment strategy that is currently available through Envestnet in the Vista Separate Account Program may become available in our Select Separate Account Program. For Select Separate Accounts each Advisory Service Provider enters into a master investment advisory agreement with Ameriprise Financial Services, and we pay the Advisory Service Provider the Manager Fee for its investment management services. For Vista Separate Accounts that are available through Envestnet, each Advisory Service Provider enters into a sub-management agreement with Envestnet, and Envestnet pays the Advisory Service Provider directly for their investment management services. As a result, the same Advisory Service Provider may earn more or less in investment management fees from Envestnet than from Ameriprise Financial Services for the same investment strategy available in the Select Separate Account Program. Ameriprise Financial Services manages this conflict by migrating all applicable existing client assets from the Vista Separate Account Program into the Select Separate Account Program and mitigates this potential conflict of interest by disallowing any duplicative investment strategies in the Vista Separate Account Program and the Select Separate Account Program. In this instance, Ameriprise Financial Services will (i) close any duplicative investment strategies in the Vista Such rebalancing transactions generally result in tax consequences in non-qualified accounts. Your annual rebalance date will reset each time your Managed Account rebalances. Envestnet will rebalance and 39 record keeping, custody, and all clearing functions for accounts introduced by Ameriprise Financial Services. reallocate your Managed Account and each SMA that you select within the Account. Under Envestnet’s Appendix 1 of Form ADV Part 2A, the Investor Unified Account is referred to as the Unified Managed Account. Access Account Generally, Ameriprise Financial Services, your financial advisor and AEIS act as an agent when executing transactions in your Managed Account. When permissible by applicable law, and after complying with regulatory requirements, we will execute some transactions on your behalf, and in your Managed Account(s) while acting as principal for our own account (“Principal Transactions”). Fractional Shares and Principal Transactions The Access Account program is a discretionary Program that accommodates a variety of actively managed portfolios containing mutual funds and/or ETFs transferred to Ameriprise from another firm. These portfolios are managed by Envestnet and Envestnet Managers and offered on the Envestnet platform. If you currently hold an Access Account portfolio, you may add new contributions to your existing account(s). Access Account is generally a hold and service Program. In certain limited instances you may make both new purchases and new contributions into Access Account portfolios that are not otherwise available for sale. Some or all of your portfolio may temporarily move to a cash position in certain circumstances such as if there is no selling agreement in place at the time of transition to Ameriprise Financial Services. Such transactions generally result in tax consequences in non-qualified accounts. Supplementary Managed Accounts Information Brokerage Practices A fractional share is defined as less that one full share of an equity, ETF, preferred security, CEF or UIT. Fractional shares are not eligible for purchase in your Managed Account(s) however when you direct Ameriprise Financial Services to reinvest dividends of securities that transact in fractional shares into your Managed Account(s), where allowed, you are also directing us to purchase additional shares on your behalf in an amount equal to the amount of the dividend proceeds. This will generally result in us purchasing a fractional share of the applicable securities on your behalf. Fractional shares may be held in your Managed Account(s), if appropriate, but due to their nature may not be purchased or sold on an agency basis through AEIS. The liquidation of fractional shares requires us to purchase a full share and divide the share while acting as principal for our inventory account in order to pay you the proceeds of the value of the fractional share you own. By entering into the Relationship Agreement, you authorize Ameriprise Financial Services to effect fractional share Principal Transactions. AEIS and Ameriprise Financial mitigate any potential conflicts of interest in effecting fractional share Principal Transactions by acting in the best interest of our clients and neither Ameriprise Financial nor AEIS will receive any selling concession or other compensation or benefits. You will not be charged a markup or markdown in connection with fractional share Principal Transactions. Aggregated Trade Orders Ameriprise Financial Services will act in the best interest of its clients, including, but not limited to, seeking best execution on all client transactions in Managed Accounts Programs. Both AEIS and Ameriprise Financial Services have implemented various policies and procedures to address any potential conflict of interest, including but not limited to procedures regarding the suitability, supervision and best execution of securities recommended to, or purchased to or from, Ameriprise Financial Services client accounts. Brokerage services are made available through Ameriprise Financial Services. Ameriprise Financial Services and AEIS have an agreement in which Ameriprise Financial Services introduces customer accounts to AEIS on a fully disclosed basis. AEIS serves as Ameriprise Financial Services’ clearing agent in providing clearing, custody and settlement services for transactions that are executed for customers of Ameriprise Financial Services. Under certain circumstances, when Ameriprise Financial Services or your financial advisor deems a transaction to be in the best interests of you and other clients, and to the extent permitted by applicable law and regulation, Ameriprise Financial Services will instruct AEIS to aggregate multiple client orders to obtain what Ameriprise Financial Services believes will be the most favorable price and/or lower execution costs at the time of execution, as further described below. SPS Advantage Program—Fixed Income Securities Ameriprise Financial Services approves and opens accounts and accepts securities order instructions with respect to the accounts. In exchange for a fee paid by Ameriprise Financial Services, AEIS provides For fixed income securities in SPS Advantage Accounts, when you provide your financial advisor with your 40 trade order, which includes transaction costs when AEIS executes transactions in your Managed Account. consent to take time and price discretion for a given trading session, your trade order will be combined with orders for multiple clients of that financial advisor in order to buy and sell the same securities in an aggregated trade order for best execution purposes. Ameriprise Financial Services will instruct AEIS to aggregate the trade orders for the applicable securities and to buy or sell the securities in one or more aggregated trade orders. Your financial advisor will then allocate the executed trades to each individual client Account in a manner that is fair and equitable through a trade rotation or random selection methodology, including for any partially filled trade orders. When fixed income securities are aggregated for execution in SPS Advantage Accounts, you receive the average price for the aggregated trade order, meaning you may receive a higher or lower price for the applicable fixed income securities than may otherwise have been obtained. Client trade orders submitted for Accounts enrolled in the optional automatic rebalancing feature do not include fixed income securities and are not aggregated for execution. In connection the Manager Directed Programs, you will grant discretionary trading authority to place trades for securities bought or sold for your Managed Account, or brokerage discretion, to an Investment Manager (including the Signature Wealth Investment Manager or an Envestnet Manager, for applicable Accounts) or to Ameriprise Financial Services under the terms of your Relationship Agreement. In such cases, the Investment Manager or Ameriprise Financial Services is subject to an obligation to seek best execution, which is a duty to place trades with the broker-dealer or stock exchange (collectively referred to herein as the “Executing Party”) that the manager reasonably believes is capable of providing the best qualitative execution of client trade orders under the circumstances considering all relevant factors, such as execution capabilities, efficiency and responsiveness of the Executing Party, transaction costs for the trade, familiarity with the type of security to be traded, the value of any research or other services provided by the Executing Party and other relevant factors. SPS Advisor Program—Aggregate Orders The Asset-based Fee associated with each Account covers transaction costs when trades are executed by the Ameriprise Financial Services on an agency basis through AEIS; therefore, it is common for participating Investment Managers to direct transactions for your Managed Account to Ameriprise Financial Services for execution in this manner. For SPS Advisor Accounts, financial advisors generally aggregate orders of the same security for multiple clients of that financial advisor in one aggregated trade order to seek best execution. When securities are aggregated for execution, each client will receive the average share price for the aggregated trade order. As a result, the average share price you receive may be higher or lower than the price you would have received had the transaction been executed independently from the aggregated transaction. For Signature Wealth, Active Portfolios® investments, Select Strategist UMAs and Investment Providers in the Select Separate Program and Envestnet Managers that have entered into a Model Provider sub- management agreement with Envestnet, Ameriprise Financial Services will execute brokerage transactions for your Managed Account on an agency basis through our clearing agent, AEIS. Your financial advisor will then allocate the executed trades to each individual client Account in a manner that is fair and equitable through a trade rotation or random selection methodology, including for any partially filled trade orders. Adjustments may also be made to avoid a nominal allocation to client accounts. However, for Select Separate Account, Vista Separate Account and Investor Unified Account the Investment Manager or Envestnet Manager, as applicable, that you select has discretionary trading authority, or brokerage discretion, and may allocate a purchase or sale transaction for the Account to an Executing Party other than AEIS, provided the allocation is consistent with the manager’s obligation to seek best execution on the particular transaction. Financial advisors may choose not to aggregate transactions in certain circumstances, for example, client directed trading activity such as contributions, withdrawals, asset allocation changes, or investment strategy changes. Adjustments to trade aggregation and allocations may also be made by your financial advisor to take into consideration account specific investment restrictions, undesirable position size, account portfolio weightings, client tax status, client cash positions and client preferences. Manager Directed Programs When an Investment Manager directs transactions for execution with or through Executing Parties other than AEIS, these trades are referred to as “step-out trades” and the practice is referred to as “trading away.” Any additional trading costs (“Third Party Execution Fees”) incurred will be passed along to you, are included in the purchase or sale price of the transacted security and are in addition to the Asset-based Fee. Any Third- Discretionary trading in Manager Directed Programs generally requires aggregation of client trade orders for the purchase or sale of securities within a Program and clients receive the average share price for the 41 Party Execution Fees incurred may impact and reduce the investment performance of your Managed Account. However, an Investment Manager’s election to place step-out trades may allow the Investment Manager to execute client trade orders at a better purchase or sale price for the transacted security than would otherwise be obtained through AEIS and any such price improvement may contribute to the investment performance of your Managed Account. The Investment Manager’s trade rotation practices may result in transactions placed on behalf of your Managed Account receiving a more or less favorable net price for the transaction as compared to the Investment Manager’s other client accounts. Before selecting an Investment Manager for your Managed Account, you should carefully review all material related to the Investment Manager and the SMA strategy you select, including information in the Investment Manager’s disclosure document (Part 2A of Form ADV) regarding the Investment Manager’s best execution, trade aggregation and trade allocation practices, if any, as well as whether the Investment Manager may select Executing Parties that provide the Investment Manager credit toward the acquisition of research or other transaction related products and services. When an Investment Manager places a step-out trade, the transaction is generally traded from broker to broker and may be executed without any Third-Party Execution Fees. However, for many step-out trades, the Executing Party will assess a commission or transaction cost. These costs may be in excess of what other Executing Parties may have charged, including AEIS. Investment Managers that specialize in certain SMA strategies, such as those investing in fixed income, preferred, convertible or small-cap securities, will be more likely to place step-out trades due to factors the Investment Manager considers relevant in meeting its best execution obligations. Ameriprise Financial Services does not restrict an Investment Manager’s ability to trade away in SMA strategies for your Managed Account, as the Investment Manager has brokerage discretion over its client trade orders and must meet its best execution obligations with respect to transactions placed on behalf of your Managed Account. This may cause certain Investment Managers to direct most, if not all, of their trades to an Executing Party other than AEIS. Ameriprise Financial Services is not a party to step-out trades, does not participate in Executing Party selection for step-out trades and is not in a position to negotiate the price or transaction related cost(s) with the Executing Party selected by the Investment Manager in these situations. Ameriprise Financial Services has procedures in place to monitor the services, including trading practices and placement of client trade orders, provided by Investment Managers. Ameriprise Financial Services requires that Investment Managers place client trade orders in accordance with the Investment Manager’s best execution and fair trading policies and procedures as well as any trade aggregation or trade allocation policies and procedures utilized by the Investment Manager with respect to your Managed Account. In determining whether to place client trade orders with AEIS or another Executing Party an Investment Manager may consider not only the factors listed above but also the fact that transaction costs related to trades effected by Ameriprise Financial Services through AEIS are included in the Asset-based Fee. The Investment Manager may manage institutional or other client accounts that are not a part of Ameriprise Financial Services’ program. In the event the Investment Manager purchases or sells a security for all of its client accounts using a particular strategy offered by the Investment Manager, the Investment Manager may determine that it will receive more favorable execution, including better pricing and enhanced investment opportunities, if it aggregates all such client transactions into a block trade that is executed through one Executing Party. Investment Managers for fixed income SMA strategies will generally step-out all of their client trades. For other types of SMA strategies, some Investment Managers step-out most, if not all, of their client trades. Additionally, due to operational and other considerations specific to the Envestnet platform, Envestnet Managers may be more likely to place step- out trades for Accounts than Investment Managers for Select Separate Accounts. SMA strategies of Investment Managers that elect to place step-out trades may, in certain circumstances, be more costly to clients than SMA strategies of Investment Managers that elect to trade exclusively or primarily through AEIS. As discussed above, the Investment Manager’s decision to place step-out trades may reduce or may contribute to the investment performance of your Managed Account. Please ask your financial advisor for more information about the trading practices of each Investment Manager, including the average Third Party Execution Fees for step-out trades placed by the Investment Manager, and consider the impact of those costs before selecting an Investment Strategy for your Select Separate Account or your Managed Account offered with Envestnet. Alternatively, the Investment Manager may utilize a trade rotation process where one group of its client accounts may have a transaction executed before or after another group of the Investment Manager’s client accounts. 42 • Credit Risk. Credit risk is the risk that the issuer, Ameriprise Financial Services does not receive research products or services in exchange for commissions generated by transactions in client Accounts, also known as “soft dollars” or client commission practices. guarantor or borrower becomes unable or unwilling, or is perceived to be unable or unwilling, to honor its financial obligations or otherwise defaults. • Reinvestment Risk. This is the risk of having to reinvest future proceeds from investments, whether scheduled or unscheduled, at potentially lower prevailing rates. • Liquidity Risk. Liquidity risk is the risk associated with any event, circumstance, or characteristic of an investment or market that negatively impacts the ability to sell, or realize the proceeds from the sale of, an investment at a desirable time or price. Ameriprise Financial Services receives and distributes research authored by its affiliate AEIS; however, this research is not provided in exchange for any type of compensation to AEIS. Nor do we or our affiliates receive client referrals from broker- dealers or third parties that are considered in selecting or recommending broker- dealers. See the “Broker- dealer” subsection in the “Other Financial Industry Activities and Affiliations” section of this Disclosure Brochure for more information about the brokerage business of Ameriprise Financial Services and its affiliates. • Investment and Market Risk You should understand that: • All investments involve risk of loss and you should be prepared to bear such a loss (the amount of which may vary significantly), • Foreign Investments and Currency Risk. Investments in or exposure to foreign investments involve certain risks not associated with US investments. Foreign investments are subject to the risks including, but not limited to, political, economic, market, regulatory and others within a particular country or region, as well as currency fluctuations and less stringent financial and accounting standards. Risks are enhanced for emerging market. Investment performance in any products referenced in this Disclosure Brochure can never be predicted or guaranteed, • • Tax Risk. This is the risk that the tax treatment of certain investments and of the income and gain therefrom is uncertain and can vary over time. The market value of a Managed Account will fluctuate due to market conditions and other factors such as liquidity and volatility, • • There is no guarantee that a mutual fund or Managed Account will meet its objective, Legal and Regulatory Risk. This is the risk that new or revised laws or regulations may adversely affect investments and programs. • Past performance does not predict future performance with respect to any Managed Account described in this Disclosure Brochure, • All trading in your Managed Account will be at your risk. • Operational Risk. Operational risks can include risks of loss arising from operational failures including but not limited to failures in internal processes, people, or systems, or from external events, including those resulting from the mistakes of third parties. • Business Disruption Risk. This is the risk of The Risks of Investing in the Programs Include, but are not Limited to the Following: • Market Risk. Market risk refers to the possibility that the market values of securities or other investments will fall, sometimes rapidly or unpredictably, or fail to rise, because of a variety of actual or perceived factors affecting issuer, industry or sector in which it operates or the market as a whole. • business disruption of varying severity and scope occurring. The types of disruption may include, but not be limited to, firm-only disruption, disruption that affects a single building, a disruption that affects the entire city or business district, and disruption that affects the entire region. Please read more in Ameriprise Financials’ Business Continuity Plan Disclosure and Ameriprise Financial Client Relationship Guide. Interest Rate Risk. The interest rate risk is the risk that investment value is sensitive to changes in interest rates. In general, a rise in interest rates may result in a price decline of fixed-income instruments. This risk may be heightened for longer maturity and duration instruments. • Cybersecurity Risk. With the use of technologies such as internet to conduct business, businesses are susceptible to cybersecurity breaches, please read more at https://www.ameriprise.com/ privacy-security-fraud. • • Technology Risk. Businesses must rely in part on digital and network technologies to conduct Inflation Risk. Inflation risk is the uncertainty over the future value of an investment due to inflation. Investments may not keep pace with inflation, which may result in losses. 43 business, provide services and maintain business operations. These technology systems may fail to operate properly or become disabled as a result of events or circumstances wholly or partly beyond control. Technology failures, whether deliberate or not, could have a material adverse effect and could result in, among other things, financial loss, reputational damage, regulatory penalties or the inability to conduct business. intended for all investors. Clients who choose to follow high-risk strategies should know that there is the possibility of significant losses up to and including the possibility of the loss of all assets placed in the strategies. Clients investing in high-risk strategies should be prepared to bear this loss. It is strongly recommended that you diversify your investments and do not place all of your investments in high-risk investment strategies. • Business Risk. This risk is associated with a particular industry or a particular company within an industry. • Management Risk. The risk refers to the risk of the situation in which the company and shareholders would have been better off without the choices made by management. • Concentration Risk. This risk refers to Any firm, whether Ameriprise Financial Services and its affiliates or a non-affiliated Advisory Service Provider, that has discretionary authority over client assets may be limited in its investment activities due to ownership restrictions imposed by an issuer (i.e., a legal entity that sells common stock shares to the general public) or a regulatory agency. These ownership restrictions are based upon the level of beneficial ownership in a security. For purposes of determining whether a particular ownership limit has been reached, a firm may be required to aggregate holdings across an entire group of affiliated companies, meaning that all shares held on a discretionary basis for the account of the firm and its affiliates or for the benefit of their respective clients are taken into account for purposes of determining the maximum amount that may be held under the ownership restrictions. undiversified or concentrated investments. When assets are invested in a small number of issuers, specific asset type or overly exposed to particular sectors, industries or geographic regions that may create more vulnerability to unfavorable developments in these issuers, asset type, sectors, industries or geographic regions and greater risk of loss than those that are invested more broadly. • Margin Risk. Margin borrowing has specific risks outlined in the Margin Risk Disclosure document, review that document for more information. • Pledging Assets Risk. Pledging assets to secure loan involves additional risks, please read more in the Pledging Assets Section of Disclosure Brochure. • Ameriprise Financial Services and its affiliates, including CMIA, are subject to the limitations referenced above. As a result, you may be limited or prevented from acquiring securities of an issuer that Ameriprise Financial Services, CMIA or your financial advisor may otherwise prefer to purchase in your Managed Account if Ameriprise Financial Services or your financial advisor has discretionary authority. These limitations apply to certain Active Portfolios® investments, Select ETF Portfolios and SPS Advisor Accounts. Leverage Risk. Leverage occurs when assets available for investment are increased by using borrowings, short sales, derivatives, or similar instruments or techniques. The use of leverage allows for investment exposure in excess of net assets, thereby magnifying volatility of returns and risk of loss. The risks described above should not be considered to be an exhaustive list of all the risks which clients should consider. For further information about various risks, please refer to the applicable prospectus or other investment product offering documents, as well as the Advisory Service Provider’s disclosure document (Part 2A of Form ADV) and the Strategy Fact Sheet, the Ameriprise Financial Client Relationship Guide, and any applicable risk acknowledgement forms. It is possible that these ownership limitations could cause performance dispersion among Accounts of clients who have chosen the same investment strategy. For example, if purchases in an issuer are restricted due to ownership limits, Ameriprise Financial Services or a financial advisor would not be able to purchase that security for client accounts even though an Advisory Service Provider may hold that security in its investment strategy or model portfolio, as applicable, and recommend it for purchase. Similarly, certain Accounts may hold fewer shares of a certain security than other Accounts following the same investment strategy depending on when purchases of that security were restricted. Some strategies may be high-risk strategies and usually have the potential for substantial returns; however, there are correspondingly significant risks involved in the strategies. Such strategies are not In addition, purchases of certain securities may be restricted from purchase by client Accounts of Ameriprise Financial Services and its affiliates for risk management reasons. 44 Sources of information Although the information and data provided by third party organizations is believed to be accurate, Ameriprise Financial Services and its financial advisors do not independently verify third party information. In general, Discretionary Managers conduct securities analysis using the services of research analysts. Among the various sources of information utilized by these research analysts and other investment management personnel may include: • information prepared by companies; Neither Ameriprise Financial Services nor its financial advisors guarantee the accuracy, completeness or timeliness of any such information nor do they imply any warranty of any kind regarding the information provided. • meetings with outside analysts; • informational interviews at corporations; Third Party Research Provider Materials Not Approved for Use with Clients • corporate rating services; • financial and industry trade publications; • • research materials prepared by a wide variety of financial services sources; and economic reports and government services. From time to time, financial advisors may access research, models, investment tools or other material from third party research providers that are not approved for use with clients rather are for the purposes of the financial advisor’s general education, staying current on industry trends or developing potential investment ideas. Financial advisors may provide clients with general market commentary or non- security information once the individual pieces have been approved for use by Ameriprise Financial Services. Death of a Managed Account Holder In the Signature Wealth Program, the Signature Wealth Investment Providers will utilize Sources of Information made available to them from Ameriprise Financial Services to assist them in the support of the Signature Wealth Program. The source of the information provided is Ameriprise Financial Services and is specific to the administration and operational support of the Signature Wealth Program. In addition, Ameriprise Financial Services will make available certain Signature Wealth Investment Provider information to all Signature Wealth Investment Providers. Except for the extent such information is ultimately provided by Ameriprise Financial Services, the information and data provided by the third-party organizations is believed to be accurate, Ameriprise Financial Services and its financial advisors do not independently verify third party information. In addition, for mutual funds, mutual fund analysts may also use the following sources of information: • conferences with mutual fund advisors; • mutual fund rating and performance services; • • For Signature Wealth Accounts, when Ameriprise Financial Services receives notice that the owner of an individual Account has died, Ameriprise Financial Services will freeze the Signature Wealth Account(s), prorate the Asset-based Fee based on the period of time during the billing period the Account was open and rebate any unused portion of the Asset- based Fee, and will then close the Signature Wealth Account and transfer the Account, and transfer the positions in-kind to a restricted SPS Advantage Account and await instructions from the executor or designated administrator of the deceased’s estate. If the beneficiary wants to establish a new Signature Wealth Account, Ameriprise Financial Services must receive the necessary Account opening documents, including a newly executed Relationship Agreement and related documentation including a new Signature Wealth Proposal. • • asset allocation tools; training and marketing materials; prospectuses and annual reports for the investment; product materials (some of which are created by Ameriprise Financial Services or affiliates); and • market commentary (some of which may be provided by Ameriprise Financial Services’ affiliates). For all other Programs, when the Ameriprise Financial Services receives notice that the account holder of an individual Account has died, Ameriprise Financial Services will freeze the Account(s), prorate the Asset- based Fee based on the period of time during the billing period the Account was open and rebate any unused portion of the Asset- based Fee, and will await instructions from the executor or designated administrator of the deceased’s estate. Ameriprise Financial Services is not responsible for taking any action with respect to such Accounts prior to its receipt of appropriate instructions, which means that Ameriprise Financial Services will not take action in response to market fluctuations or other factors that may adversely impact the market value of any Account. Your financial advisor may utilize research produced by Ameriprise Financial Services or its affiliates, such as material prepared by the IRG, or from third party research providers that have been approved by Ameriprise Financial Services when providing investment advice within a Managed Account. Our affiliates may have views and opinions, or may make research available, that differs from that of the IRG or your financial advisor. 45 Upon receipt of appropriate instructions, an Account will be created to hold each beneficiary’s portion. If the beneficiary wants to maintain an active Account, Ameriprise Financial Services must receive the necessary Account opening documents, including a newly executed Relationship Agreement and related documentation. the purchase is in a qualified Managed Account. Gain/loss information may be available on your Managed Account statements and/or by accessing your Managed Account through ameriprise.com. Wash sales may not always be reported as such in your Managed Account statement, as reporting is required only if the exchange is for the exact same security. You should work with your tax advisor to determine the appropriate tax treatment. In the event that Ameriprise Financial Services receives notice that an account holder of an Account held in some form of joint ownership has died, additional conditions will apply to continue the enrollment and any related management of the Account. Tax Consequences For certain non-covered securities, you are encouraged to provide your Ameriprise financial advisor with the correct cost basis information for any assets that are transferred into your Managed Account. Please contact your financial advisor to determine whether you hold any non-covered securities. You should discuss with your financial advisor whether you want to initiate any tax- related transactions, such as tax loss harvesting. Payment of an Asset-based Fee may produce accounting, bookkeeping and/or income tax results that are different from those resulting from the payment of securities transaction-based commissions or other charges on a transaction-by transaction basis. The tax treatment of the fee may differ if some, or all of the investment is in tax- exempt municipal bonds or bond funds. We will provide you with certain legally required tax documents in connection with your Managed Account. You may also receive other tax related information from time to time. You should understand that neither Ameriprise Financial Services, your financial advisor nor any Discretionary Manager provides tax advice. Clients seeking tax advice are urged to seek the advice of a professional tax advisor. You will be responsible for any tax liabilities associated with your Managed Account. We may be legally required to withhold US tax from certain payments, for example, if you fail to provide a certified taxpayer identification number. Certain investment income, such as dividends on foreign equities, may incur foreign withholding taxes that may or may not be recoverable. Special Considerations for Retirement Accounts There may be tax consequences associated with transactions, including rebalancing, in your non- qualified Managed Account, such as capital gains or losses. These transactions are generally reflected on your Managed Account statements and include activities such as you selling or redeeming securities for the purpose of establishing a Managed Account or your Discretionary Manager exercising investment discretion within your discretionary Managed Account to sell all or a portion of the securities. There may be other taxable income, for example, dividends or interest. Mutual funds and ETFs may make capital gain distributions of net long- term gains in the fund. Purchasing fund shares shortly before a dividend, also known as “buying a dividend,” may raise tax costs as you will effectively receive part of your dividend price back as the distribution, resulting in inefficient tax consequences. Unless you are a tax-exempt investor or holding fund shares through a tax-advantaged account (such as a 401(k) plan or IRA), you should consider avoiding buying fund shares shortly before the Fund makes a distribution. For IRAs and other tax- qualified retirement accounts, transactions that occur within the account generally do not generate taxable income although the purchase, sale or holding of certain investments such as master limited partnerships can. See “Your Guide to IRAs” (available on Ameriprise.com or from your financial advisor) for possible tax consequence of IRA distributions. Your financial advisor may discuss, present or offer ideas for you to consider related to the allocation of retirement assets among one or more Managed Accounts. Such communications are offered as education, marketing and examples of the potential uses of these Managed Accounts for purposes of discussion and for your independent consideration, and should not be viewed, construed or relied upon, as investment or fiduciary recommendations or advice under ERISA or Section 4975 of the Internal Revenue Code of 1986, as amended (the “Internal Revenue Code”). Additionally, if in connection with discussing, presenting or offering particular Managed Accounts to you, we provide you with a sample or proposed asset allocation, including one that identifies specific You should also be aware that you may need to make estimated tax payments periodically during the year due to income generated in the non-qualified account, including: interest, dividends, and net capital gains from securities sales. There is also the potential for losses to be disallowed under the “wash sale” rules. A wash sale typically occurs when you sell or trade a stock or security at a loss, and within 30 days before or after the sale, you: (i) buy substantially identical stock or securities, (ii) acquire substantially identical stock or securities in a fully taxable exchange, or (iii) acquire a contract or option to buy substantially identical stock or securities. The wash sale rules also apply to sales in a non-qualified Managed Account and 46 investments. Any fees you pay reduce the overall value of and net performance of your Managed Account. Fee Information for Each Advisory Solution Program The Asset-based Fee is comprised of the total of (1) a negotiable Advisory Fee of up to a maximum annual rate of 2.0%; (2) a Platform Fee rate that varies by Program; and (3) any applicable Manager Fee. The Advisory Fee and the Platform Fee applies to each Managed Account in a Program and the Manager Fee applies to the Select Separate Account Program, Vista Separate Account Program, Investor Unified Account Program, the Access Account Program, and SMA investment portfolios within the Signature Wealth Program. securities or other investments, such asset allocation is merely an example of, or proposal for, the fiduciary advice and recommendations that may potentially be made available through the Managed Account once you decide to enroll in the Managed Account and should not be relied upon as investment or fiduciary advice or a recommendation under ERISA or the Internal Revenue Code. We are not acting as a fiduciary under ERISA or the Internal Revenue Code when you decide to engage us for a new service, including with respect to your decision, or the decision of a plan participant, to roll over assets to an Ameriprise IRA. Similarly, we are not acting as a fiduciary under ERISA or the Internal Revenue Code when you decide to move assets from one type of account held at Ameriprise Financial Services to another type of account (e.g., moving assets from an Ameriprise brokerage account to a Managed Account). Ameriprise Financial Services and its financial advisors may be subject to limitations with respect to the revenue they receive in connection with Accounts of retirement or other tax-favored savings plans. In addition to your Asset-based Fee, for SPS Advisor Accounts, Ameriprise Financial Services assesses a quarterly asset-based Investments and Infrastructure Support Fee of 0.03% of the total advisory assets in your Managed Account. Our affiliate AEIS credits to clients all sub- transfer agency fees and networking fees AEIS receives for SPS Advisor Accounts from mutual fund firms. This Investments and Infrastructure Support Credit may be more or less than the Investments and Infrastructure Support Fee. Annual Fee Rate Fee Component Applicable Program(s) 2.0% Retirement account clients are not permitted to open or maintain a margin account with AEIS or any other broker or dealer for the purposes of effecting Managed Account transactions on margin. Retirement account clients are also precluded from pledging assets held in a Managed Account. For additional information regarding special considerations that may apply to retirement accounts, please refer to the Relationship Agreement. Maximum Advisory Fee All Managed Accounts Programs Platform Fee 0.17% Select Separate Account, Vista Separate Account, Investor Unified Account, and Access Account Programs Covered family members of Ameriprise financial advisors are able to purchase investment products in their Ameriprise brokerage retirement accounts at a lower commission rate and receive a rebate of the applicable 12b-1 fees, as well as a waiver of any transaction charges paid by your financial advisor. Ameriprise financial advisors who provide advisory services to covered family members will not receive any portion of the Advisory Fees paid on these Managed Account retirement accounts, unless the Asset-based Fee is paid from a nonqualified account via an alternative fee billing arrangement. Please contact your financial advisor if you have questions as to whether you’re a covered family member of an Ameriprise financial advisor. Fees and Compensation SPS Advisor, Signature Wealth and Active Portfolios Programs Ranges from 0.02% - 0.05% based on advisory household assets under management (“AUM”).* * Asset tier ranges and rates are set forth in Section 9 of the Relationship Agreement. 0.02% SPS Advantage Program The total cost to you of a Managed Account will include (1) the Asset-based Fee, which includes any investment management fees charged by Advisory Service Providers for SMA strategies; (2) for SPS Advisor Accounts, the Investments and Infrastructure Support Fee; (3) Investment Costs; and (4) Additional Fees and Expenses which are any additional transaction related fees that may be incurred in connection with your Managed Account based on the nature of your 47 Manager Fee Generally ranges from 0.10% to 0.80% Managed Account such as asset allocation, portfolio construction, creation of model portfolios, investment recommendations and selection including applicable investment product due diligence, execution of transactions through our affiliated clearing agent, AEIS, custody of securities, and tax and account reporting including trade confirmations and client statements and services provided by your financial advisor for your Managed Account. The Advisory Fee you pay is shared between Ameriprise Financial Services and your financial advisor and discussed in further detail in the Financial Advisor – Advisory Fee” sub- section under the “Financial Advisors Compensation & Benefits “ section. o Ameriprise Financial Planning Service Fee. Select Separate Account, Vista Separate Account, Investor Unified Account, Access Account Program, and SMA investment portfolios within the Signature Wealth Program. SPS Advisor Program If you choose to pay for your Ameriprise Financial Planning Service (“AFPS”) through the consolidated advisory fee service a portion of your Asset-based Fee is allocated to cover the financial planning services you receive (“AFPS Fee”). The AFPS Fee rate is negotiated with your financial advisor, however the sum of the Advisory Fee and the AFPS Fee cannot exceed 2%. The level of the Advisory Fee you negotiate with your financial advisor will depend upon a number of factors including: • • • total assets in your Managed Account the service level of your Managed Account type of strategy employed Investments and Infrastructure Support Fee and Investments and Infrastructure Support Credit 0.03% AEIS credits to clients all sub-transfer agency fees and networking fees it receives for SPS Advisor fund firms. fees and networking fees it receives for SPS Advisor Accounts from mutual fund firms. Because the Advisory Fee component of the Asset- based Fee is negotiable, client Asset-based Fees may vary. Accordingly, you may pay a higher or lower Asset based Fee than a similarly situated client due to factors such as account value, types of investment products, investment strategy, trading activity and the range of services received. For example, you may pay more or less than another client invested in the same particular investment strategy with a higher or lower account value than your Managed Account. This means you may pay more than a similarly- situated client with a lower account balance who is receiving the same services. Based on the Program you select, the components of your Asset-based Fee will vary. The fee components will be displayed to you when open a new Managed Account or make changes to an existing Managed Account that result in a change to one or more components of your Asset-based Fee. You may also request current fee rates from your financial advisor. Each possible component that may apply to you is further described below. • Advisory Fee. The Advisory Fee rate is an ongoing asset-based fee negotiated between you and your financial advisor. It is part of the overall Asset- based Fee calculated for you on a monthly basis. The Advisory Fee is based in part on the total value of the assets in your Managed Account(s) at Ameriprise Financial Services (“Advisory Tiers”). There are minimum Advisory fee rates that vary based on this total value. The Advisory Fee covers services provided by your financial advisor for your • Platform Fee. The Platform Fee rate is part of the overall Asset-based Fee calculated for you on a monthly basis. For Programs that charge a Platform Fee rate within a range, the effective Platform Fee is based on the advisory household AUM. o For discretionary programs, e.g., SPS Advisor, Signature Wealth, Active Portfolios, Select Separate Account, Vista Separate Account, Investor Unified Account, and Access Account Programs, the Platform Fee covers additional costs associated with these Programs for services provided by Ameriprise Financial 48 In calculating the Blended Fee Rate, assets without a Manager Fee (such as mutual funds, ETFs, uninvested cash, and securities) are assigned a 0% rate, while SMA assets use the applicable Manager Fee based on their respective allocations. Services such as advisory service provider due diligence and oversight, investment selection including initial and ongoing investment strategy due diligence (Manager Directed Programs only), investment product due diligence, overlay management, additional trading costs, enhanced proposal and trading tools (as applicable by Program), reporting (e.g. manager and portfolio reports), advisory training and expert support, platform management (e.g. ongoing product development and administration) and additional operational and support related functions. o For non-discretionary programs, e.g., SPS Advantage, the Platform Fee covers additional costs associated with non-discretionary program services provided by Ameriprise Financial Services such as advisory training and expert support, platform management (e.g. ongoing product development and administration) and additional operational and support-related functions. • Manager Fee. The Manager Fee represents For Select Strategist UMA Managed Accounts, the initial Blended Fee Rate will be calculated based on the percentage of the Managed Account targeted to each SMA on the date your Managed Account is accepted. Thereafter, the Blended Fee Rate will be calculated on the net asset value of the actual allocation within each SMA on the last business day of each month. Investor Unified Account Managed Accounts calculate the Blended Fee Rate using the net asset value of the allocation within each SMA. For Signature Wealth Managed Accounts the initial and first monthly Blended Fee Rate will be calculated based on the percentage of the Managed Account targeted to each model investment portfolio at the time your Account is accepted. This is to allow the Investment Manager adequate time to fully invest into the model investment portfolios. Thereafter, the Blended Fee Rate will be calculated based on the actual asset value of each model investment portfolio, on the last business day of each month. investment management fees charged by Advisory Service Providers for a specific SMA investment strategy. The Manager Fee rate is variable by Advisory Service Provider and specific investment strategy and is charged to you as a component of your Asset-based Fee. Manager Fee rates are subject to change. Because each SMA may be subject to different fees, your Blended Fee Rate will change depending on a variety of factors, including the value of the assets in each sub- account, market movements, your contributions and withdrawals, any changes to your allocation or the selection of a new SMA strategy. As a result, the Blended Fee Rate may be more or less than the Blended Fee Rate originally shown in the confirmation of your new Account. Investments and Infrastructure Fee for SPS Advisor Accounts. The Manager Fee also applies to SMA investment portfolios within Signature Wealth. Other Signature Wealth Investment Providers generally earn compensation through management fees, or Investment Costs, associated with proprietary mutual funds and ETFs used in the investment models recommended. The Asset-based Fees for Programs that offer SMA strategies range higher than Programs that do not offer SMA strategies in order to cover the fees paid to Advisory Service Provider(s) for services provided to your Managed Account. As of the date of this Disclosure Brochure, the fee rates for SMA strategies generally range from 0.10% to 0.80% per annum of the market value of the assets invested in each SMA strategy. More information regarding the investment management fees charged by a particular Advisory Service Provider for its SMA strategies is contained in its disclosure document (Part 2A of Form ADV). For SPS Advisor Accounts, Ameriprise Financial Services assesses an annual asset-based Investments and Infrastructure Support Fee of 0.03% of the total advisory assets in your Managed Account. The Investments and Infrastructure Support Fee is assessed quarterly and calculated based on the closing market value of your Managed Account as of the last business day of the calendar quarter. If you do not have an SPS Advisor Account balance as of the last business day of the calendar quarter, you will not be assessed the Investments and Infrastructure Support Fee. You will be charged an Investments and Infrastructure Support Fee for the entire calendar quarter if you have an SPS Advisor Account balance on the last business day of the calendar quarter (i.e., no proration). The Investments and Infrastructure Support Fee is in addition to your Asset-based Fee and helps support the cost of maintaining and servicing the SPS Advisor Program. For Select Strategist UMA, Investor Unified Account, and Signature Wealth Managed Accounts each underlying SMA investment strategy may be subject to a different Manager Fee rate. The Manager Fee rate for these Managed Accounts is assessed as a blended rate (the “Blended Fee Rate”), calculated using the full billable value of the Managed Account. 49 considered miscellaneous income for tax reporting purposes. For Accounts with alternative fee billing arrangements, the entire Investments and Infrastructure Support Credit will be considered miscellaneous income if the originating Account is a non-qualified Account. Account holders receiving aggregate miscellaneous income of $600 or more annually will receive an IRS Form 1099-MISC, Miscellaneous Income, from AEIS. Account holders receiving miscellaneous income amounts under $600 annually generally will not receive an IRS Form 1099- MISC from AEIS, but will be responsible for reporting the income to the IRS. Holders of IRAs and qualified retirement plan Accounts will not experience a taxable event as a result of a rebate and will instead be taxed only on amounts when they are distributed from the Account. Householding of Account Assets and Minimum Asset- based Fee. For SPS Advisor Accounts, Ameriprise Financial Services causes its affiliate, AEIS, to credit to clients all sub- transfer agency fees and networking fees AEIS receives from mutual funds firms. This Investments and Infrastructure Support Credit is calculated on a proportionate basis based on the revenues earned over the course of the applicable calendar quarter, divided by SPS Advisor Account assets as of the closing market value of each client’s SPS Advisor Account(s) as of the last business day of the calendar quarter. Clients who do not have an Account balance as of the last business day of the calendar quarter will not be eligible to receive the Investments and Infrastructure Support Credit. Clients who open an Account during the calendar quarter will receive a full credit (i.e., no proration) if they have an SPS Advisor Managed Account balance on the last business day of the calendar quarter. The Investments and Infrastructure Support Credit will be allocated without regard to the value of mutual fund positions held in any particular client’s SPS Advisor Account. Although Ameriprise Financial Services intends to credit these sub-transfer agency fees and networking fees back to clients, AEIS reserves the right, in its discretion, to cease to collect these sub-transfer agency fees and networking fees at any time and, accordingly, cease crediting client Accounts. The Asset-based Fee provides householding benefits across all Programs and Managed Accounts (“Advisory Fee Householding”). By default, a primary household will consist of a client, their spouse or domestic partner, unmarried children under the age of 21, and accounts owned by these people, which are displayed under one Group ID on your client statement. If you have more than one Group ID, you may be able to link the Group ID associated with your primary household group to the Group ID associated with an additional household group with which you have an eligible affiliation, such as the grantor of an irrevocable trust or owner of a corporation. Household minimums are assessed across all Managed Accounts within a household and the minimum Asset-based Fee for a household is $100. Households charged the minimum annual Asset-based Fee amount may exceed the maximum Asset-based Fee percentage otherwise applicable to your Managed Account(s). Households with less than a $3,333 balance will be charged an effective Asset-based Fee in excess of 3%. If your effective Asset- based Fee exceeds 3%, Managed Accounts may not be the most cost-effective investment vehicle for you; similar products and services may be available at a lower overall fee through another investment program. A pro- rata portion of this minimum fee is assessed each billing period. The Investments and Infrastructure Support Fee and Investments and Infrastructure Support Credit apply at the same rate for each SPS Advisor Managed Account regardless of how many mutual fund positions, if any, are held in the Managed Account. Ameriprise Financial Services intends to fund, in whole or in part, the Investments and Infrastructure Support Credit from sub- transfer agency fees and networking fees its affiliate collects from mutual fund companies for the mutual fund accounting, recordkeeping, tax reporting and other shareholder services related to the mutual funds held in all SPS Advisor Accounts. As a result, the Investments and Infrastructure Support Credit will generally offset the cost of the Investments and Infrastructure Support Fee. However, changing circumstances, such as a shift at the Program level away from investments in mutual funds into individual securities, ETFs or other investment products, could cause the credit to be less than the Investments and Infrastructure Support Fee and may impact the costs associated with your SPS Advisor Account. The Investments and Infrastructure Support Credit may also be more than the Investments and Infrastructure Support Fee. Each quarterly fee and credit is displayed on your statement for the following month. For example, December’s fee and credit will appear on your January statement. In circumstances where the Investments and Infrastructure Support Credit exceeds the Investments and Infrastructure Support Fees paid from your nonqualified account, the excess will be Where eligible, Advisory Fee Householding allows you to combine Managed Account assets across multiple household groups, which may help you qualify for a lower minimum Advisory Fee rate, or, if applicable, to qualify for the household minimum Asset-based Fee across all Managed Accounts in the linked households. Generally, pension and group retirement plans are not eligible to be linked for Advisory Fee Householding. Due to the timing of Account processing, when a new Account is created, funded and billed on the last 50 business day of the billing period, such new Account may not be included in your household assets for that billing period. In addition to your client statement, you can also find your Group ID online if you’re registered on the secure site at ameriprise.com. Contact your financial advisor to review whether your Group IDs are eligible to be linked for Advisory Fee Householding benefits. You may also call 800.862.7919 to review your Group IDs and householding eligibility. any such changes, with the exceptions of (i) changes to your Platform Fee rate for SPS Advisor, Signature Wealth and Active Portfolios Accounts which varies over time based on your household advisory AUM; and (ii) changes to your Blended Fee Rate for the Manager Fee charged to Select Strategist UMA Managed Accounts and Investor Unified Managed Accounts. You authorize Ameriprise Financial Services to apply future changes to the fee components by continuing to accept the Service. Billing Methodology Your Asset-based Fee is deducted directly from your Managed Account and paid from cash available in your Sweep Program unless your Asset-based Fee is paid via an alternate fee billing arrangement. The Advisory Fee that you negotiate with your financial advisor for a specific Account will increase if your total advisory assets fall below the minimum for your Advisory Tier and remain as such through any applicable grace period (a “Passive Advisory Fee Change”). If you have a Passive Advisory Fee Change, we will provide you with prior notice that your Advisory Fee rate will be increased unless you take some action. If you do not take any action, we will confirm the new Advisory Fee rate once it is effective. Passive Advisory Fee Changes do not require your signature. The maximum change is 0.25% and your Advisory Fee will not exceed 2%. If you are in a consolidated advisory fee service, and the Passive Advisory Fee Change causes the sum of the new Advisory Fee rate and the AFPS Fee rate to exceed 2%, your AFPS Fee rate will be reduced until the sum of the Advisory Fee rate and AFPS Fee rate totals 2%. The initial Asset-based Fee is based on the market value of the Account on the opening date, except for the Platform Fee portion of SPS Advisor, Signature Wealth and Active Portfolios Accounts which is based on advisory household AUM, adjusted proportionately to reflect the number of days remaining in the initial monthly billing period. Thereafter, billing will be calculated based on the market value of the assets in the Account or advisory household AUM, as applicable, as of the last business day of the preceding monthly billing period and deducted on the 14th of each month, or if the 14th is a weekend or holiday, the fee deducts the following business day. In the event a Managed Account is terminated, Ameriprise Financial Services will prorate the Asset- based Fee based on the period of time during the billing period the Account was open and rebate any unused portion of the Asset-based Fee. When you establish your Relationship, you negotiate the highest Advisory Fee that you agree could apply to an Account opened under the Relationship without obtaining an additional signature (the “Negotiated Advisory Fee”). If you are engaged in a consolidated advisory fee service, the Negotiated Advisory Fee includes your AFPS Fee. You may choose a Negotiated Advisory Fee rate for each specific Program offered by Ameriprise Financial Services or you may negotiate one rate that will apply at the Relationship level and consistently across all Programs offered. Your Negotiated Advisory Fee rate(s) may be lower than or up to 2% but may not exceed 2% for any individual Account at any time. Your signature is required for any increase to your Negotiated Advisory Fee rate(s). For SPS Advisor, Signature Wealth and Active Portfolios Accounts, the initial Platform Fee rate applied to your Managed Account at new Account set up will be determined by the anticipated advisory household AUM selected on your Managed Account opening paperwork. The ongoing Platform Fee rate will then be adjusted on a monthly basis based on your actual advisory household AUM. As a result, your total Asset-based Fee for each SPS Advisor, Signature Wealth and Active Portfolios Account will increase and decrease over time within the range specified in the chart above, based on the market value of your advisory AUM. Deposits into and withdrawals from your Managed Accounts will cause your advisory AUM to increase and decrease. Any such increase or decrease that changes your applicable advisory household asset tier will be effective immediately and charged as of the next applicable billing period. Changes to Fee Components The Negotiated Advisory Fee you’ve agreed to may not be the same as the (i) Advisory Fee, or (ii) sum of the Advisory Fee and AFPS Fee, if applicable, that you agree to be applied to and charged on a specific Managed Account (within the remainder of this section, the “Assessed Advisory Fee”). When establishing a Managed Account, you may agree to an Assessed Advisory Fee up to the applicable Negotiated Advisory Fee without a signature. Your signature will be required if you agree to an Assessed Advisory Fee that is higher than the applicable Negotiated Advisory Fee. Fee components are subject to change in the circumstances set forth below. Any change to an underlying fee component will change your total Asset- based Fee. We will provide you written confirmation of For an existing Managed Account, you may renegotiate the Assessed Advisory Fee with your financial advisor at 51 any time. Your financial advisor will complete the appropriate documents reflecting the new Assessed Advisory Fee. Your signature will be required if the Assessed Advisory Fee, including an APFS Fee if applicable, is higher than the applicable Negotiated Advisory Fee. Your financial advisor or Ameriprise Financial Services may, without obtaining your signature: (i) for Managed Accounts that are part of a negotiate the Advisory Fee rate with your financial advisor, move to another Program, add the consolidated advisory fee service to that Managed Account, or when processing certain ownership changes. Clients with a Grandfathered Advisory Fee will not be subject to a Passive Advisory Fee Change. Ask your financial advisor whether you have a Grandfathered Advisory Fee rate and consider this rate before re-negotiating your Advisory Fee rate or moving to another strategy. Relationship: reduce or increase your Assessed Advisory Fee up to the Negotiated Advisory Fee; or, Allocation of Asset-based Fees The Asset-based Fee paid in connection with each Managed Account you establish will be allocated to Ameriprise Financial Services, your financial advisor and if applicable, the Advisory Service Providers as follows. • (ii) for all Accounts where the Assessed Advisory Fee includes an AFPS Fee: reduce, increase, reallocate or remove the AFPS Fee associated with your Managed Account providing that the new sum of your Assessed Advisory Fee does not exceed the higher of your Managed Account’s current Assessed Advisory Fee or the applicable Negotiated Advisory Fee, if the Account is part of a Relationship. The Advisory Fee compensates Ameriprise Financial Services. A portion of the Advisory Fee and, if applicable, the AFPS Fee, is shared with your financial advisor. • The Platform Fee compensates Ameriprise Financial Services. The Platform Fee is not shared with your financial advisor. For Signature Wealth Accounts, a portion of the Platform Fee is shared with the Signature Wealth Investment Manager. The Assessed Advisory Fee change will become effective at the start of the next billing period, following the period in which the request is received and accepted by Sponsor. For each instance of a Negotiated Advisory Fee or Assessed Advisory Fee change, we will send you a confirmation, regardless of whether your signature was required. • The Manager Fee compensates the Advisory Service Provider and is not shared with Ameriprise Financial Services or your financial advisor. As of the date of this Disclosure Brochure, Manager Fee rates generally range from 0.10% to 0.80% per annum of the market value of the assets invested in each SMA strategy. More information regarding the investment management fees charged by a particular Advisory Service Provider for its SMA strategies is contained in its disclosure document (Part 2A of Form ADV). Manager Fee rates are subject to change. The Manager Fee may change if (i) your Managed Account changes Advisory Service Providers, (ii) you make changes to your investment strategy, (iii) one of your current Advisory Service Providers change their fee, or (iv) your investment strategy moves to another Program as a part of a Program reorganization. Any increase or decrease in the Manager Fee is passed along to you. For UMA accounts, the Blended Fee Rate will generally change as the allocation between the underlying SMAs changes. • Changes to the Manager Fee, including the Blended Fee Rate, do not require your signature. The SPS Advisor Investments and Infrastructure Support Fee compensates Ameriprise Financial Services and is not shared with your financial advisor. Ameriprise Financial Services. Ameriprise Financial Services retains the portion of the Advisory Fee not allocated to your financial advisor. Our portion of the Advisory Fee may be higher or lower than the portion of the Advisory Fee allocated to your financial advisor. Advisory Service Providers. Important considerations for the Manager Fee paid to Advisory Service Provider(s) you select include: Platform Fee rates are subject to change. Platform Fee rate changes do not require your signature. Platform Fee rates for SPS Advisor, Signature Wealth and Active Portfolios Accounts are subject to change within the current applicable ranges based on your advisory household AUM, as described above, and can vary over the course of your Relationship. The Platform Fee rate or the overall range(s) applicable to your Managed Account(s) may increase or decrease with notice to you. • Manager Fee rates are negotiated separately with each Advisory Service Provider. • Grandfathered Advisory Fee Rates. If you have received notice that you have a Grandfathered Advisory Fee rate, which is an Advisory Fee rate that is lower than the minimum fee rate allowed for the applicable Advisory Tier (the “Grandfathered Advisory Fee rate”), you will retain that fee rate until you re- Participating Advisory Service Providers may reimburse AEIS and AEIS may subsequently reimburse financial advisors for the costs arising from, or make payments to AEIS for participation in, client meetings or educational and training 52 meetings held with financial advisors and other personnel. pay additional fees and expenses associated with your specific Sweep Program. This section discusses each of these costs. Investment Costs of Mutual Funds. There are underlying mutual fund expenses charged to all mutual fund shareholders. Some mutual fund companies and their service providers pay AEIS a portion of the fees it receives for underlying mutual fund expenses in the form of Third-Party Payments. Any mutual fund fees or expenses you pay reduce the overall value of and net performance of your Managed Account. Important considerations: In addition to the fees described above, Ameriprise Financial Services and its affiliates retain the revenues each receives related to the investment products held in your Managed Account such as (i) Third Party Payments; and (ii) any management fees, distribution fees or compensation earned related to administrative or transfer agency fees related to affiliated mutual funds held in your Managed Account that are included in the Investment Costs paid indirectly by you and are received by our affiliates, such as CMIA. • Additional Costs Associated with a Managed Account The underlying fees related to investment products you purchase within your Managed Account are referred to as Investment Costs and are more fully described below. These costs are in addition to the Asset-based Fee that you pay directly from your Managed Account and may include Third Party Payments that are compensation to AEIS, as discussed above. They are paid by you indirectly as part of the cost of the investment and they reduce the value of your investment in the product. They are not a direct fee deducted from your Managed Account. These fees and expenses include management fees, distribution and other expenses. A mutual fund may also charge shareholder service (“12b- 1”) fees. These fees and expenses could increase the total cost of your investment in the mutual fund by 1.00% to 2.00% or more. For example, if the Asset-based Fee for your Managed Account is 1.00%, and the mutual funds in which you invest have average fees of 1.50%, the total fees will be 2.50%. As noted above, all Managed Accounts offer Advisory Shares that typically do not assess 12b-1 fees as the primary share class. To the extent that Ameriprise Financial Services receives 12b-1 fees from mutual fund companies for applicable mutual fund classes utilized in any Managed Accounts, it rebates these fees to clients. Rebates are generally deposited into the applicable client Accounts within a week after we receive the 12b-1 shareholder servicing fees. • Charges imposed by the underlying mutual funds held in your Managed Account may include short- term redemption fees and small position fees. Investment Costs apply whether the investment product is sponsored or managed by a third party or an affiliate of Ameriprise Financial Services, such as Columbia Management Investment Advisers, LLC (CMIA”), a wholly owned subsidiary of Ameriprise Financial, Inc., Ameriprise Financial Services’ parent company. When you invest in investment products managed by CMIA, CMIA or its affiliates will receive compensation for managing those investments and for other services they provide based on the amount you invest, just as they would if you invested in CMIA investment products through another service provider. • Ameriprise Financial Services and/or one or more of its affiliates may serve as the fund’s distributor, transfer agent, shareholder servicing agent, custodian and/or investment adviser. In these situations, Ameriprise Financial Services and/or its affiliates will receive payments for such services that may vary depending on the assets invested in such mutual fund. • Other mutual funds, such as fund-of-funds, also have additional management, advisory and other internal fees and expenses which are assessed by the fund directly and are in addition to the Asset- based Fee. Investment Costs received by CMIA are not compensation to Ameriprise Financial Services, however, Ameriprise Financial Services, CMIA and their affiliates receive more revenue, in aggregate, from the purchase of affiliated mutual funds or investment products offered by CMIA or their affiliates than from the purchase of investment products offered by firms that are not affiliated with Ameriprise Financial, Inc. It is your responsibility to understand all fees and charges prior to making investment decisions. Review each applicable mutual fund prospectus for details on all fund fees. In addition to your Asset-based Fee and Investment Costs, you may pay Third Party Execution Fees associated with “step-out trades” placed by an Investment Manager in an investment strategy you select in Select Separate Account or a Managed Account offered with Envestnet, as described in the “Brokerage Practices” section; and you may pay any additional fees and expenses to the extent incurred in connection with your Managed Account. You may also Third Party Payments. A portion of Investment Costs are paid to AEIS by third parties who manage, Ameriprise Financial Services or distribute investment products held in your Managed Account. This compensation helps fund the cost of providing service, 53 maintaining accounts and offering an investment platform for our clients. These payments are generally funded directly, or indirectly, from Investment Costs, as more fully discussed above. Cost reimbursement services and Third-Party Payments related to your Managed Account are further described in the “Cost Reimbursement Services and Third-Party Payments” section, including marketing and sales support payments are received from certain mutual fund firms that participate in the Full Participation Program Ameriprise Financial Services offers. AEIS will receive the following types of payments from product companies with respect to the investment model portfolios and other investment products we recommend, and you select for the investment of your Managed Account assets. For qualified SPS Advisor Accounts, inherited IRAs in qualified SPS Advantage Accounts where a trust has inherited the IRA and Ameriprise Bank acts as trustee of the trust and eligible trustee-directed retirement plans in Select Separate Accounts AEIS either does not collect Third Party Payments or credits them back to client Accounts. Third Party Payments do not include any management fees, distribution fees or compensation earned related to administrative, or transfer agency fees related to affiliated mutual funds held in your Managed Account and managed by one of our affiliates, such as CMIA. These fees are included in the Investment Costs paid indirectly by you and are received by our affiliates but are not compensation to Ameriprise Financial Services or AEIS, however they are an economic benefit to Ameriprise Financial Services and its affiliates as further discussed in the “Economic benefits of affiliates’ products and services” section. • Mutual funds – AEIS will receive cost- reimbursement payments (e.g., reimbursement for marketing support) from non-affiliated mutual fund firms for investments you make as a result of our recommendations. • Certain other investment products – AEIS will receive cost-reimbursement payments from third party investment firms whose products Ameriprise Financial Services recommends. Additional Fees and Sources of Compensation. Under certain circumstances, you may be assessed transaction related fees or charges depending on the nature of the investment products held in your Managed Account. You may also be charged fees for transactions initiated by you such as costs associated with pledge loans and interest charges when investing on margin. Any such fees and charges incurred in connection with your Managed Account are in addition to the Asset- based Fee charged to your Managed Account(s). Any additional fees you pay reduce the overall value of and net performance of your Managed Account. Examples of the types of additional fees and charges that you would pay, to the extent they are incurred in connection with your Managed Account, include: • Brokerage commissions resulting from • Other servicing and account maintenance fees – AEIS will also receive sub-transfer agency fees or networking fees with respect to investments you make in mutual funds except for inherited IRAs in qualified SPS Advantage Accounts where a trust has inherited the IRA and Ameriprise Bank acts as trustee of the trust and eligible trustee-directed retirement plans in Select Separate Accounts, as noted above. As further described above, for SPS Advisor Accounts, Ameriprise Financial Services will rebate to clients all sub- transfer agency fees or networking fees and other servicing and account maintenance fees its affiliate, AEIS, receives from mutual funds firms. transactions effected through or with a broker- dealer other than AEIS; • AEIS also receives revenues that exceed the costs • Transaction fees relating to any foreign securities other than American Depositary Receipts; • of the cost reimbursement services provided. These revenues include marketing support and distribution support payments, and such payments increase the gross revenues and net earnings of AEIS. • AEIS is responsible for delivering to clients or their The entire public offering price, including underwriting commissions or discounts, on securities purchased from an underwriter or dealer involved in a distribution of securities; • Fees related to the sale of Initial Public Offerings; and • Other costs or charges imposed by third parties, including American Depositary Receipts issuance fees and annual depository fees, voluntary reorganization fees, odd-lot differentials, transfer fees exchange fees, and other fees or taxes required by law. agent all shareholder materials (e.g. annual reports and proxies) received from the issuers of securities. It does this through a vendor. The vendor charges each issuer based on rates determined by the New York Stock Exchange. AEIS earns rebates from its vendor based on the difference between the rate charged to the issuer and the cost to the vendor to deliver the shareholder materials. The rebates are generally higher for customers who consent to utilizing electronic delivery. Review the Relationship Agreement and Ameriprise brokerage materials for a summary of the service fees 54 ameriprise.com/disclosures or call our service line at 800.862.7919. Sweep Programs Offered in Managed Accounts: • Ameriprise Insured Money Market Account (“AIMMA”) is the Sweep Program offered for SPS Advantage Accounts, except for trustee-directed 401(a) Accounts; and for non-qualified Accounts in the following Advisory Programs: SPS Advisor Accounts, Signature Wealth Accounts, Active Portfolios® Accounts, Select Separate Accounts, Vista Separate Accounts, Investor Unified Accounts, and Access Accounts. that may be charged in connection with your Managed Account(s). You should also refer to the disclosure document(s) for a description of the fees and expenses associated with any product or service that is made available in connection with the Managed Account. It is your responsibility to understand all fees, expenses and other charges prior to investing or participating in any product or service. All Investment Costs and additional fees are subject to change. Contact your financial advisor if you have any questions about the types of additional fees and expenses that may be associated with your Managed Account. • Sweep Program and Expenses Your Managed Account(s) will from time to time receive and disburse cash. Cash received can be in the form of deposits you make to your Managed Account, the proceeds from investments you sell, and the receipt of dividend and interest payments from investments you own. Ameriprise Bank Insured Sweep Account (“ABISA”) is the Sweep Program offered for SPS Advantage trustee-directed 401(a) Accounts and qualified Accounts in the following Advisory Programs: SPS Advisor Accounts, Signature Wealth, Active Portfolios® Accounts, Select Separate Accounts, Vista Separate Accounts, Investor Unified Accounts, and Access Accounts. • Either Dreyfus Government Cash Management – Institutional Shares or the Dreyfus Government Cash Management – Wealth Shares are the Sweep Program offered for TSCA/403(b) Managed Accounts and personal trust services Managed Accounts opened by Ameriprise Bank as trustee and certain other non-qualified Managed Accounts that are ineligible for an insured deposit Sweep Program. An investment in a money market fund is not a bank deposit and is not insured or guaranteed by the FDIC or any other government agency. Cash is disbursed from your Managed Account to pay for new investment products you buy, to cover check writing, debit card, ACH or bill pay activity, and to pay the Asset-based Fee and other fees you may incur. Any portion of your Managed Account balance that is held in cash will be included in the Asset-based Fee calculation. On a daily basis, Ameriprise Financial Services will move all uninvested cash into the Sweep Program applied to your Managed Account(s). The Sweep Programs may pay interest or dividends. By authorizing Ameriprise Financial Services to open a Managed Account, you expressly authorize Ameriprise Financial Services to move such cash balances. Rates and yields vary across the different Sweep Programs and maybe be higher or lower depending on the particular money market fund or interest-bearing bank deposit product, and on the cash balance you maintain in your Managed Account. Regardless of the Sweep Program made available to you, you can also buy and sell positional money market mutual funds, brokered certificates of deposit, treasury bills, and other similar cash-equivalent products to manage cash in your non-discretionary Managed Accounts and Ameriprise brokerage accounts, and such investment products may be available for you to buy and sell in certain discretionary Managed Accounts. These options for the investment of cash balances are generally expected to offer higher returns than the Sweep Program we make available for your Managed Account. Some types of investment products may not be available to you under the terms of your specific Account. If you decline the Sweep Program offered for your Managed Account(s), or if you subsequently revoke your acceptance, you may at any time direct Ameriprise Financial Services to (i) hold your Sweep Program balance as a free credit balance in your Managed Account(s); (ii) return the proceeds to your Managed Account(s) for investment in a cash equivalent investment product; or (iii) have us remit the cash to you. Cash held as a free credit balance is eligible for coverage by SIPC, up to $250,000 per capacity as determined by SIPC. Cash held as a free credit balance is not eligible for FDIC coverage. For Managed Accounts, we may earn interest or other revenue on the balance but are not obligated to pay interest on cash held as a credit balance in your Managed Account(s). More detail regarding Sweep Programs offered by Ameriprise Financial Services is available in the Other Important Brokerage Disclosures document and the Money Settlement Options section of the Ameriprise Brokerage Client Agreement. For a copy of the Other Important Brokerage Disclosures or the Ameriprise Brokerage Client Agreement, visit our website at 55 AIMMA Program Banks pay on the deposits held through AIMMA. This difference is known as “spread.” Like the unaffiliated Program Banks participating in AIMMA, Ameriprise Bank earns spread revenue when it participates in AIMMA as a Program Bank. AEIS receives and retains compensation from Program Banks for its services related to AIMMA for Advisory Solutions, based on the cash deposits held at each Program Bank. This compensation is either negotiated between each Program Bank and AEIS, or between the Program Bank and our vendor, IntraFi, and is either a fixed rate or is based on a benchmark interest rate, such as the Federal Funds Rate, plus or minus a spread. You can find up-to-date information on the revenue AEIS receives from unaffiliated Program Banks participating in AIMMA at ameriprise.com/products/ investments/brokerage-sweep-options. AIMMA is an interest-bearing multi-bank deposit product made available by Ameriprise Financial and held in an omnibus account(s) at one or more FDIC member banks (collectively, the “Program Banks”). Our affiliate, Ameriprise Bank, FSB (“Ameriprise Bank”) is a Program Bank and participates in AIMMA. The Program Banks may serve individually as custodians for all or a portion of the cash balance held within your Managed Account that are swept to AIMMA, as described in the Other Important Brokerage Disclosures document. Multibank deposit products are FDIC insured up to $250,000 per depositor ($500,000 for joint ownerships) per Program Bank, including deposits held at Ameriprise Bank. AEIS will use reasonable efforts to place deposits across multiple Program Banks to enable clients to receive up to $2.5 million per depositor ($5 million for joint ownerships) across all Program Banks combined. Ameriprise Bank does not compensate AEIS for its sweep services provided or for the cash deposits held at Ameriprise Bank, but reimburses AEIS for its direct out of pocket expenses related to AIMMA. Your financial advisor does not receive any of (i) the compensation paid by the Program Banks; or (ii) the reimbursements paid by Ameriprise Bank to AEIS. ABISA For any amount above the applicable limit that is deposited in a single Program Bank, including any other FDIC insured product you may own through that Program Bank, the amount above the limit will not be eligible for FDIC deposit insurance. Ameriprise Bank may restrict AIMMA deposits based on certain account ownership types. Deposit products are not covered by the SIPC. If your Managed Account uses AIMMA as its Sweep Program, you agree to accept the proprietary algorithm applied by IntraFi LLC (“IntraFi”), which determines the Program Banks into which your deposits are placed. You also understand and agree that IntraFi will periodically change the order of the Program Banks to optimize the amount of FDIC insurance available in the AIMMA Sweep Program. Under ordinary business conditions, changes to the Program Bank List will be published at least five business days prior to the effective date, and current interest rates for each interest rate tier will be published three to five business days prior to their effective date. The Program Banks are identified on the Program Bank List and interest rate information is available at Ameriprise.com/cashrates. ABISA is an interest-bearing single bank deposit product made available by Ameriprise Financial Services. Deposits into ABISA are held in an omnibus account(s) at Ameriprise Bank, Member FDIC, an affiliate of Ameriprise Financial. Ameriprise Bank serves as custodian for the cash balances held within Managed Accounts that are swept to ABISA, as described in the Other Important Brokerage Disclosures. Single bank deposit products are FDIC insured up to $250,000 per depositor ($500,000 for joint accounts), per FDIC rules. For any amount above the applicable limit, the amount above the limit will not be eligible for FDIC deposit insurance. Deposit products are not covered by SIPC. If your Managed Account uses ABISA as its Sweep Program, Ameriprise Bank earns spread revenue, the difference between what it pays in interest and what it earns on its investments. Ameriprise Bank does not compensate AEIS for its sweep services provided or for the cash deposits held at Ameriprise Bank, but reimburses AEIS for its direct out of pocket expenses related to ABISA. Your financial advisor does not receive any of (i) the compensation earned by Ameriprise Bank; or (ii) the reimbursements paid by Ameriprise Bank to AEIS. Money Market Fund Any cash in your Managed Account(s) that is swept to AIMMA is aggregated with cash held by other Ameriprise clients that utilize AIMMA and is held in an omnibus account at one or more Program Banks. Omnibus accounts, by virtue of their ability to raise significant balances for the Program Banks, are generally able to earn higher interest rates than those you would be able to earn if you deposited cash individually at a bank. The Program Banks participating in AIMMA earn income by lending or investing the deposits they receive and charging a higher interest rate to borrowers, or earning a higher yield, than the If your Managed Account’s Sweep Program uses a money market mutual fund, our affiliate AEIS may receive marketing support payments of up to 0.37% of the amount held in that money market mutual fund Sweep Program. Please refer to the applicable 56 prospectus or the “Cost Reimbursement Services and Third-Party Payments” sub-section for further specific details regarding mutual fund marketing and sales support payments received by AEIS. An investment in a money market fund is not a bank deposit and is not insured or guaranteed by the FDIC or any other government agency. Affiliate Compensation reserves the right to, or may instruct the custodian to, sell securities held in your Managed Account Sweep Program to cover these fees. Ameriprise Financial Services reserves the right to determine which mutual funds or other securities will be sold. Because of mutual fund redemption minimums and other applicable minimums, Ameriprise Financial Services may be required to sell more shares than is necessary to cover this amount. The proceeds of such sales will be held in your applicable Sweep Program pending deduction of the applicable fee(s). As noted above, our affiliate AEIS is compensated based on the balance held in your Sweep Program. Brokerage Accounts Sweep Programs made available in Managed Accounts are offered by Ameriprise Financial Services in its capacity as a broker-dealer, and services are provided by our affiliate AEIS as part of the overall brokerage services provided to your Managed Account(s) pursuant to the “Money Settlement Options” section of the Ameriprise Brokerage Client Agreement. Your financial advisor does not recommend the Sweep Program offered to you for any particular Account(s) and revenues received by our affiliates related to the Sweep Programs are not shared with financial advisors. Generally, the combined revenue earned by our affiliates AEIS and Ameriprise Bank is expected to be (i) the highest when your Managed Account sweeps cash into ABISA or AIMMA where Ameriprise Bank is utilized as a Program Bank; (ii) the second highest when your Managed Account sweeps cash into AIMMA where unaffiliated Program Banks are utilized; and (iii) the lowest when your Managed Account sweeps cash into an eligible money market mutual fund. Retail brokerage services are also available through Ameriprise Financial Services. If you choose to open an Ameriprise brokerage account separate from your Managed Account to purchase and sell securities, you will incur a sales commission or pay a mark-up or mark- down in connection with each transaction in that account. These transaction charges are paid to compensate Ameriprise Financial Services and your financial advisor for the assistance they provide in helping to execute those transactions. You may also incur a variety of other fees in connection with maintaining an Ameriprise brokerage account, including fees and margin loan interest. Review the account opening documents provided in connection with establishing a brokerage account for additional information. Our affiliates AEIS and Ameriprise Bank use this revenue to defray the cost of operating our Sweep Programs and the expense of providing other services to our clients, as well as for general operating expenses and to provide net earnings to AEIS and Ameriprise Bank. In the absence of this revenue Ameriprise Financial Services would likely charge higher fees or other charges to clients for the services AEIS and Ameriprise Bank provide to clients. Ameriprise Financial Services does not receive research or other products or services other than execution from any unaffiliated broker-dealer or other third party for client securities transactions. Ameriprise Financial Services receives and distributes research authored by its affiliate AEIS however this research is not provided for client securities transactions or for any other compensation. Nor do we or our affiliates receive client referrals from broker-dealers or third parties that are considered in selecting or recommending broker-dealers. Other Investment Advisory Services Ameriprise Financial Services addresses this conflict of interest through a combination of disclosures and policies and procedures regarding Sweep Program availability and the free-credit balance, as well as supervision and surveillance of cash balances held in Managed Accounts. Sweep Program Balance Requirements Your financial advisor may offer ongoing financial planning or other services that are not included in a Managed Account for additional fees. A Managed Account is not a financial planning service and clients investing solely in a Managed Account will not receive all material elements of the financial planning process. Managed Account clients are required to maintain sufficient cash balances in the Sweep Program or as a free credit balance in your Managed Account(s) to meet the applicable Asset-based Fee and, if applicable, SPS Advisor Investments and Infrastructure Support Fee deductions. If there is not sufficient cash in your Managed Account(s) Sweep Program to cover these and other applicable fees, Ameriprise Financial Services In addition to the Advisory Solutions Programs described in this Disclosure Brochure Ameriprise Financial Services offers the following advisory services for retail investors: • Ameriprise Financial Planning Service • Ameriprise Premier Retirement Income Service 57 but also provides the ability to borrow money to purchase securities. Both pledge loans and margin are available on non-qualified SPS Advantage Accounts and non-qualified Ameriprise brokerage accounts; however, you may not utilize both margin lending features and a pledge line of credit on the same Account. You also have the option to engage in the consolidated advisory fee service. The consolidated advisory fee service is a combined investment advisory service for which you will receive AFPS and at least one Managed Account Service. The fee is based on the assets in the Managed Account(s) with a portion of the fee calculated for AFPS, as described in the “Fees and Compensation” section. Any Managed Account fees are separate from and in addition to any advisory fees you pay for these additional services. Margin is available in non-qualified SPS Advantage Accounts and non-qualified Ameriprise brokerage accounts and involves the extension of credit to you and your financial exposure could exceed the value of your securities. Ameriprise Financial Services, in its sole discretion, may approve your Managed Account for margin trading. Margin lending has specific risks outlined in the Margin Risk Disclosure document which you should review before opening a margin account. A description of the advisory services listed above and the fees, compensation and other policies associated with each may be viewed online by visiting www.ameriprise.com/disclosures and expanding the sub- heading “General Disclosures” for Ameriprise Financial Planning Service and Ameriprise Premier Retirement Income Service and “Managed Account Client Disclosure Brochures” for consolidated advisory fee service. You should consider the aggregate costs and expenses of investment advisory services and products as a whole. Your financial advisor may not offer all investment advisory services or accounts. Ameriprise Financial Services also offers Ameriprise® Retirement Plan Consulting Services to employers and trustees and is designed to assist in their role as a plan fiduciary. Other Products, Services and Features Ameriprise Financial Services may allow you to pledge certain non-qualified Managed Account(s) and non- qualified Ameriprise brokerage account assets as collateral for an Ameriprise Preferred Line of Credit offered jointly and separately by Ameriprise Bank and Goldman Sachs Bank USA (collectively, “Lender”), or a pledge line of credit program from a third-party financial institution. To the extent that you pledge non- qualified assets held at Ameriprise Financial Services as collateral for a pledge loan to a third-party financial institution, you will be required to execute, and arrange for the completion and execution of, certain required documentation. Among other things, this will result in the financial institution being required to complete Ameriprise Financial Services’ form of collateralization agreement. The interest rate you may secure from a third-party financial institution may be higher or lower than the interest rate offered for an Ameriprise Preferred Line of Credit. Certain pre-existing non-qualified SPS Advantage Accounts have access to check writing, bill pay and debit card features of the Ameriprise ONE® Financial Account. Other products, services and features may be included or made available in connection with a Managed Account. When you apply for a pledge loan for your Brokerage Account(s) or Managed Account(s) you agree that such assets will be pledged to the lender as security for that line of credit. Once your Managed Account(s) are pledged, the securities and cash will serve as collateral for the line of credit. If the market value of the securities in your pledged Account(s) drops below certain levels, you may be required by the lender to pay down the loan, sell securities in the Account(s), and/or pledge additional securities. These products, services and features may have their own terms, conditions, disclosure documents, fees and expenses. Review applicable materials, and consider fees related to a particular product, service or feature prior to deciding to participate or invest in, or as you consider remaining in, that product, service or feature. Talk to your financial advisor about the applicability of any product, service or feature of a Managed Account. Securities-based Lending Solutions It is important that you understand the actions the Lender has the right to take against any account(s) that you pledge as security for an Ameriprise Preferred Line of Credit, as well as risks and restrictions associated with pledging your Managed Accounts. If the Lender feels that the security for its line of credit to you is at risk, it may take actions regarding your pledged assets Account(s) that may be disruptive to your investment objectives for your Managed Account(s) or to the existing target asset allocation such as restricting trading or reinvestment in the Account while instructions from the Lender are Each of the Ameriprise Preferred Line of Credit, Ameriprise Preferred Loan and margin loans are securities-based lending solutions made available to clients of Ameriprise Financial Services. While a pledge line of credit or loan, such as the Ameriprise Preferred Line of Credit or Ameriprise Preferred Loan, is credit extended by a financial institution such lines of credit or loans are principally used for liquidity purposes only. Margin lending is credit extended directly by AEIS and may be used for liquidity purposes 58 processed; and the Lender may impose conditions that prevent you from maintaining your existing Managed Account(s). You may need to work with your financial advisor to take other steps to maintain your Ameriprise Preferred Line of Credit. Ameriprise Financial Services reserves the right to decline your request to pledge your assets. Compensation Received by Ameriprise Financial Services and Its Affiliates When Ameriprise Bank as co-lenders receive revenue related to your Ameriprise Preferred Line of Credit and Ameriprise Preferred Loan, each of Ameriprise Bank and Goldman Sachs Bank USA receives a pro-rata portion of the revenue generated. As a result, on a comparable amount of credit extended, Ameriprise Financial Services and its affiliates generally earn higher revenues for the use of margin, and it is therefore more profitable when clients utilize margin than when using an Ameriprise Preferred Line of Credit or and Ameriprise Preferred Loan. Ameriprise Financial manages this conflict of interest by keeping the cost to you for either a negotiated rate margin loan or an Ameriprise Preferred Line of Credit and Ameriprise Preferred Loan in line with each other as described below. A margin loan is the only securities-based lending solution offered by Ameriprise Financial Services that allows you to borrow money to purchase securities. Either of the Ameriprise Preferred Line of Credit or a margin loan allows you to borrow money for liquidity purposes. Non-qualified Brokerage Accounts and non- qualified SPS Advantage Managed Accounts offer both of these securities-based lending solutions. Conflicts of Interest Related to Financial Advisors’ Recommendations Margin When used to purchase securities, any margin account balance in your non-qualified SPS Advantage Account will be included in the calculation of your Asset-based Fee for that period and is shared with your financial advisor. Our affiliate AEIS earns interest on your margin balance whether you use the money to purchase securities or for liquidity purposes. Ameriprise Preferred Line of Credit Your financial advisor does not receive compensation on your margin account balance when you borrow money for liquidity purposes but does receive ongoing compensation based on the outstanding balance of the credit line extended to you for an Ameriprise Preferred Line of Credit or Ameriprise Preferred Loan. This compensation creates a financial incentive for your financial advisor to recommend the use of the Ameriprise Preferred Line of Credit or Ameriprise Preferred Loan over margin. Ameriprise Financial manages this conflict of interest through a combination of disclosures, compensating financial advisors for the Ameriprise Preferred Line of Credit and Ameriprise Preferred Loan within a reasonable range that is non-negotiable and capped, keeping client costs for either negotiated rate margin loans, an Ameriprise Preferred Line of Credit or an Ameriprise Preferred Loan comparable and in line with each other by monitoring interest rates, and policies, procedures, training and additional resources designed to delineate the features of each product to assist financial advisors in providing recommendations that are in a client’s best interest and consider reasonably available alternatives. Account Requirements and Types of Clients Establishing and Maintaining Accounts Ameriprise Bank earns revenue based on the outstanding balance amount of the Ameriprise Preferred Line of Credit and the interest rate on the loan. Ameriprise Financial Services receives compensation from Ameriprise Bank, FSB of 0.25% of the outstanding balance on the credit line on an annualized basis. This amount is shared with your financial advisor based on how your advisor is affiliated with us and on the payout rate for which your financial advisor qualifies. This compensation is separate from the compensation your financial advisor receives for servicing your Managed Account. These affiliations and compensation structures are described in the “Financial Advisors Compensation & Benefits” section below. Ameriprise Financial and your financial advisors will continue to receive the Asset- based Fee on any pledged assets held in your Managed Account(s). Ameriprise Bank does not compensate AEIS, but reimburses AEIS for its direct out of pocket expenses related to its Ameriprise Preferred Line of Credit support. To establish an Account in one or more of the services, you will be asked to: Conflicts of Interest Related to Securities-Based Lending Solutions • Review this Disclosure Brochure; and other applicable Advisory Service Provider Form ADV Part 2A; • Provide accurate and complete information to your Conflicts of Interest Related to our Affiliated Products and Services When AEIS charges you interest on your margin balance it retains the full amount of such revenue. financial advisor to complete the Client Information and the applicable Managed Accounts application; 59 • Read and sign the application which includes the Relationship Agreement; • Read and sign the Brokerage Agreement to establish and maintain a brokerage account as part of a Managed Account; and • Select a Sweep Program as described in the Brokerage Agreement. Coverdell Savings Accounts and 529 plan accounts are not available in a Managed Account. In the event a Managed Account is terminated, Ameriprise Financial Services will prorate the Asset- based Fee and rebate any unused portion. You have the right to request that your assets be distributed in the form of cash or securities. This transaction may have tax implications. Because you will be responsible for any associated tax liabilities, you should discuss the potential implications with your tax advisor. Additional fees may apply to distributions in the form of securities as outlined in the “Sweep Program and Expenses” section. In these situations, the anticipated timing of distributions would be the same as outlined for each Managed Account Service description in the “Services, Fees and Compensation” section. Termination of Advisory Service Providers Ameriprise Financial Services may, in its sole discretion and at any time, terminate an Advisory Service Provider’s (including an Envestnet Manager’s) participation in a Managed Account, or discontinue the Advisory Service Provider’s services with respect to a particular investment strategy in accordance with the Relationship Agreement and with thirty (30) days prior written notice to you. As a result, Ameriprise Financial Services may transfer the Account assets to an Ameriprise brokerage account, and the Brokerage Agreement will govern any assets transferred including fees charged in connection with maintaining an Ameriprise brokerage account and transaction fees. Managed Accounts are available for individual investors, corporate entities, certain nonprofit organizations and tax-qualified accounts. The types of tax-qualified accounts that may be available include traditional IRAs, Roth IRAs, Simplified Employee Pension (“SEP”) IRAs, Savings Incentive Match Plan for Employees (“SIMPLE”) and defined contribution plans as defined in Section 401(a) of the Internal Revenue Code (e.g., Profit Sharing, Money Purchase). Ameriprise Financial Services, in its own discretion, may offer certain account types to certain clients. Tax-Sheltered Custodial Account (“TSCA”) may be available for TSCA participants to invest in SPS Advantage, SPS Advisor, Active Diversified Portfolios® investments and Access Separate Accounts, but may not invest in other Managed Accounts. Trustee-directed retirement plans may not invest in the Active Portfolios®, SPS Advisor, certain Select Separate Account investment strategies, Vista Separate Account, Investor Unified Account or Access Account Programs. Nonprofit organizations operating as a donor advised fund are eligible to invest in certain investment strategies in most Manager Directed Programs. Programs and Managed Accounts are made available based on the ownership type associated with your Relationship, and not all Programs may be available to you. Nonresidents of the United States for U.S. tax purposes are not eligible to open Managed Accounts in all Programs. Terminating a Relationship Agreement If you terminate your Advisory Service Provider, or if Ameriprise Financial Services or Advisory Service Provider terminates or discontinues the service provided to you, you may reinvest with another Advisory Service Provider. Reinvesting with another Advisory Service Provider may result in portfolio turnover and tax implications (for non-qualified accounts) based on the holdings of the successor Advisory Service Provider’s portfolio. Because you will be responsible for any associated tax liabilities, you should discuss the potential implications for non-qualified accounts with your tax professional. Client Information Provided to Advisory Service Providers A description of the Client Information shared with an Advisory Service Provider for your Managed Account is included in the following sub-sections in this Disclosure Brochure: • “Acceptance of your Signature Wealth Account” subsection in the Signature Wealth section. • • The Relationship Agreement may be terminated by you or Ameriprise Financial Services by providing appropriate notice. If Ameriprise Financial Services decides to terminate your Managed Account(s), the Ameriprise Financial Services will provide you no less than 30 days prior notice. This notice will advise you of options, if any, that may be available to you. If Ameriprise Financial Services decides to terminate your Managed Account(s), Ameriprise Financial Services may transfer the Account assets to an Ameriprise brokerage account, and the Brokerage Agreement will govern your relationship with Ameriprise Financial Services. If Ameriprise Financial Services terminates your SPS Advisor Account, Ameriprise Financial Services may transfer the Account assets to an Ameriprise brokerage account as outlined above or to an SPS Advantage Account as set forth in the Relationship Agreement. “Investment Manager Review of Active Portfolios®” subsection in the Active Portfolios® section. "Review and Update of Client Information” subsection in the Select Separate Account section 60 • “Acceptance and Authority of Envestnet” in the Advisory Service Providers section. Additional Information Disciplinary Information Below is notice of certain regulatory and legal settlements entered into by Ameriprise Financial Services during the last ten years: Regulatory Proceedings allegations that from December 2010 through October 2013, the firm negligently relied on misrepresentations made by F- Squared Investments, Inc. regarding certain of its ETF portfolios and, as a result, the firm made false statements about the portfolios in certain advertisements. The SEC also alleged that the firm had failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the alleged violations. The firm agreed to pay a disgorgement amount of $6.3 million plus prejudgment interest of $700,000 and a civil penalty amount of $1.75 million. Ameriprise Financial Services entered into each of the regulatory settlements listed below without admitting or denying the allegations. Securities and Exchange Commission (“SEC”) and FINRA Actions In September 2016, Ameriprise Financial Services reached a settlement with FINRA regarding allegations that between October 2011 and September 2013 the firm failed to detect and prevent the conversion, via wire transfers, of more than $370,000 from five of its customers by one of its registered representatives. The customers were family members of the registered representative. FINRA also alleged this went undetected because the firm failed to establish, maintain, and enforce a supervisory system that was reasonably designed to review and monitor the transmittal of funds from accounts of customers to third parties, including those controlled by registered representatives of the firm. The firm paid restitution and a fine of $850,000. Other Financial Industry Activities and Affiliations In August 2024, Ameriprise Financial Services reached a settlement with the SEC in connection with its industry- wide review of firms’ recordkeeping practices regarding business-related electronic communications sent or received by firm personnel using non-approved channels or methods (“off-channel communications”). The settlement resolved allegations that, from at least June 2019, the firm did not maintain or preserve a substantial majority of off- channel communications that were records required to be maintained under federal securities laws and therefore failed to “reasonably supervise” its personnel. The firm agreed to pay a civil penalty amount of $50 million. Prior to the settlement, the firm retained a compliance consultant to address certain undertakings outlined in the settlement and took steps to enhance its policies and procedures and increase training concerning the use of approved communications methods. Ameriprise Financial Services is a subsidiary of Ameriprise Financial, Inc. and conducts its activities directly and through its affiliates. These activities may be material to its investment advisory business or its investment advisory clients. These affiliates include companies under common control with Ameriprise Financial Services by virtue of their status as direct or indirect subsidiaries of Ameriprise Financial, Inc. The information below provides you an overview of the Ameriprise Financial, Inc. companies. These companies work together to offer you financial products and services designed to help you reach your financial goals. Broker-Dealer Ameriprise Financial Services, LLC is a registered investment adviser and broker-dealer with the SEC and is authorized to engage in the securities business in all 50 states as well as the District of Columbia, Puerto Rico, and the U.S. Virgin Islands. Ameriprise Financial Services is also a member of FINRA and the Securities Investor Protection Corporation (“SIPC”). In August 2018, Ameriprise Financial Services reached a settlement with the SEC regarding allegations that from 2011 through 2014 the firm failed to adopt and implement policies and procedures reasonably designed to safeguard retail investor assets against misappropriation and failed to reasonably supervise five representatives with a view to preventing and detecting violations of certain federal securities laws by these representatives. The firm agreed to pay a civil penalty amount of $4.5 million. The firm further reimbursed all impacted clients for the losses they incurred due to the misconduct. The firm also took steps to enhance policies, procedures and controls related to the safeguarding of client assets against theft or misappropriation by its associated persons and voluntarily retained a compliance consultant to assess and confirm the reasonableness of these policies, procedures and controls. Ameriprise Financial Services is registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor (“CTA”) and has obtained membership with the National Futures Association (“NFA”) in connection with such CFTC registration. In December 2017, Ameriprise Financial Services reached a settlement with the SEC regarding 61 with respect to the accounts. AEIS serves as Ameriprise Financial Services’ clearing agent providing clearing and settlement services for transactions that are executed for customers of Ameriprise Financial Services. In exchange for a fee paid by Ameriprise Financial Services, AEIS provides clearing, custody, record keeping and all clearing functions for certain advice-based accounts. In addition, AEIS may act as an agent in effecting securities transactions for certain Ameriprise Bank trust accounts. In its capacity as a broker-dealer, Ameriprise Financial Services distributes or receives compensation from selling various products including but not limited to equities and fixed income products. Offerings include corporate bonds and municipal securities, mutual fund shares, ETFs, 529 plans, face-amount certificates, closed-end funds, preferred securities, UITs, non- traded REITs, non-traded BDCs, non-traded closed- end funds, hedge fund offerings, structured products, real estate private placements, exchange funds, private equity offerings, 1031 exchange offerings, fixed and variable annuities, and fixed and variable insurance. Ameriprise Financial Services also sells managed futures funds that engage in trading commodity interests, including futures. AMPF Holding Corporation, an indirect wholly owned subsidiary of Ameriprise Financial, Inc., is a holding company for Ameriprise Financial Services and AEIS. In addition, Ameriprise Financial Services is the distributor of the publicly offered face-amount certificates issued by Ameriprise Certificate Company. Ameriprise Financial Services also may serve as an underwriter or member of a selling group for securities offerings, including those issued by affiliates. Columbia Management Investment Distributors, Inc. (“Columbia Management Investment Distributors”), an indirect wholly-owned subsidiary of Ameriprise Financial, Inc., is a registered broker-dealer serving as principal underwriter and distributor of registered mutual funds and other funds advised by affiliated companies, CMIA and Columbia Wanger Asset Management, LLC (“Columbia Wanger Asset Management”) (collectively, “Columbia Management” or “Columbia”). These funds are collectively referred to as the “Columbia Funds.” Investment Company Ameriprise Financial Services has arrangements with Ameriprise Certificate Company to distribute and sell its face-amount certificates and selling arrangements with Columbia Management Investment Distributors to distribute the Columbia Funds. Investment Advisory Firm Columbia Management Investment Advisers, LLC (“CMIA”), is registered as an investment adviser with the SEC. CMIA provides investment management services to: • Columbia Funds, as well as the Columbia ETFs, closed-end funds and private funds • Ameriprise Certificate Company • RiverSource, as well as the Columbia Funds Retail brokerage services are made available through Ameriprise Financial Services, which has an agreement with American Enterprise Investment Services Inc. (“AEIS”), a registered broker-dealer and an affiliate of Ameriprise Financial Services. Ameriprise Financial Services requires clients to agree in their Relationship Agreement that their account(s) are introduced by Ameriprise Financial Services to AEIS on a fully- disclosed basis, and that securities purchase and sale transactions in their account(s) shall be directed through AEIS, except when an Investment Manager places “step-out trades” as described in the “Brokerage Practices” sub-section. You should consider that not all investment advisory firms require clients to direct execution of transactions through a specific broker- dealer. Brokerage accounts are carried by, and brokerage transactions are cleared and settled through, AEIS, subject to AEIS policies to assure that the resultant price to the client is as favorable as possible under the prevailing market conditions. See the Working in Your Best Interest – Regulation Best Interest Disclosure for more information about potential conflicts of interest relating to brokerage transactions. underlying certain variable contracts issued by RiverSource • Various wrap program sponsors including Ameriprise Financial Services • Other affiliated and unaffiliated clients. For purposes of Form ADV Part 2, certain Ameriprise Financial Services management persons are registered representatives of Ameriprise Financial Services in its capacity as a broker-dealer, registered representatives of American Enterprise Investment Services Inc., and are associated persons of Ameriprise Financial Services in its capacity as a commodity trading advisor. Ameriprise Financial Services approves and opens accounts and accepts securities order instructions Ameriprise Financial, Inc. has other subsidiaries that are registered as investment advisers with the SEC, including, Threadneedle International Limited and Lionstone Partners, LLC. These subsidiaries are registered as investment advisers and may provide advice to domestic and foreign institutional clients, the Columbia Funds, Columbia ETFs, Columbia closed-end 62 Trust Company funds, private funds and other fiduciary clients. These entities provide services independent from Ameriprise Financial Services. Columbia Management and its affiliates Threadneedle Asset Management Ltd. (U.K. based), Threadneedle Investments Singapore (Pte.) Limited (Singapore based), and Columbia Threadneedle Investments (ME) Limited (Dubai based) operate under a combined global asset management brand, Columbia Threadneedle Investments. Ameriprise Trust Company (“ATC”), a Minnesota- chartered trust company, provides custodial, investment management and collective trust fund services for employer-sponsored retirement plans, including pension, profit sharing, 401(k) and other qualified and nonqualified employee retirement plans. ATC also serves as custodian for IRAs, 403(b)s and some retirement plans qualified under section 401(a) of the Internal Revenue Code of 1986 as well as the Ameriprise Certificate Company. ATC is not a deposit bank or a member of FDIC. Insurance Company CMIA has entered into sub-advisory agreements, delegation agreements, intercompany agreements and “participating affiliate” arrangements with certain of our Non-U.S. Advisory Affiliates, including Threadneedle International Ltd. (“TINTL”), Threadneedle Asset Management Ltd. (“TAML”), Threadneedle Management Luxembourg S.A. (“TMLSA”), Threadneedle Investments Singapore (Pte.) Limited (“TIS”), Threadneedle Investments Services Limited (“TISL”), Columbia Threadneedle Management Limited (“CTML”), Columbia Threadneedle Fund Management Limited (“CTFML”), Columbia Threadneedle Investment Business Limited (“CTIBL”), Columbia Threadneedle Netherlands B.V. (“CTNL”), Pyrford International Ltd (“Pyrford.”) and Thames River Capital LLP (“Thames”), each of which, like us, is a direct or indirect wholly-owned investment advisory subsidiary of Ameriprise Financial. Each of TINTL, TAML, TMLSA, TIS, TISL, CTML, CTFML, CTIBL, CTNL, Pyrford and Thames is registered with the appropriate respective regulators in their home jurisdictions. In addition, Pyrford is also currently registered with the SEC as an investment adviser. Banking Institution Affiliated insurance products sold by Ameriprise Financial Services and its financial advisors are issued by RiverSource Life Insurance Company (“RiverSource Life”), a stock life insurance company that is qualified to do business as an insurance company in the District of Columbia, American Samoa and all states except New York; and in New York only, issued by RiverSource Life Insurance Co. of New York (“RiverSource Life of NY”), a stock life insurance company that is qualified to do business as an insurance company in New York. The products of RiverSource Life and RiverSource Life of NY (together, “RiverSource”) include fixed and variable annuities, structured annuities (RiverSource Life only) and fixed and variable life insurance, disability income insurance and life insurance with long-term care benefits. Insurance products are also offered by other third parties through an arrangement with Ameriprise Financial Services and through Diversified Brokerage Services, Inc., LTCI Partners and Disability Resource Group, which act as co-general agents. RiverSource Distributors, Inc. (“RiverSource Distributors”), a wholly owned subsidiary of Ameriprise Financial, Inc., is a registered broker-dealer, serving as principal underwriter and distributor of RiverSource variable life insurance and annuities on behalf of RiverSource. Ameriprise Financial Services has selling arrangements with RiverSource and RiverSource Distributors to distribute these products. Ameriprise Bank, FSB, a wholly owned subsidiary of Ameriprise Financial, Inc. and an affiliate of Ameriprise Financial Services, is a federal savings bank. In addition to its participation in the AIMMA and ABISA Sweep Programs, Ameriprise Bank currently makes available a core set of banking products, including mortgage financing, co-branded credit cards with an associated rewards program, savings, certificates of deposits (“CDs”) and checking accounts and pledged asset loans. Ameriprise Bank provides personal trust services to clients, including trustee and investment management services for asset trust, and investment management and custodial agency services for individual, individual trustee, association and non- profit organization accounts. Ameriprise Financial Institutions Group (“AFIG”) is a business channel within Ameriprise Financial Services that specializes in delivering investment products and services to clients of financial institutions, such as banks and credit unions. Ameriprise Financial Services enters into networking arrangement with each financial institution whereby AFIG financial advisors provide one or more of our investment advisory services, brokerage services and insurance products to clients of the financial institution and other persons or entities that may be introduced or referred to us by the financial institution. Ameriprise Financial Services establishes custodial accounts and accepts securities order instructions for trust accounts at Ameriprise Bank. In addition, Ameriprise Financial Services may provide investment advice and research support to Ameriprise Bank and its clients for these trust accounts. The financial institution provides AFIG financial advisors joint marketing access to a distinct client 63 fees and commissions with the financial institution, including Asset-based Fees charged for investment advisory services. Non- registered employees of the financial institution may also receive compensation for referring you to Ameriprise Financial Services. How We Get Paid This section should be read in connection with the “Services, Fees and Compensation” and/or the “Client Referrals and Other Compensation” sections in this Disclosure Brochure. segment and may provide office space in the building where it conducts its business. As a part of the contractual arrangement with the financial institution, Ameriprise Financial Services shares with the financial institution a portion of up to 94% of fees and commissions, including Asset-based Fees charged for investment advisory services, generated by AFIG financial advisors that are attributable to our operations under the joint marketing agreement with the financial institution. A portion of these fees may be paid to financial advisors who are employees of the financial institution, as described below. Ameriprise Financial Services and its affiliates receive revenue from several different sources on the products and services you purchase. These sources include the fees and charges you pay, other arrangements we have in place with product companies, and investment and interest income. The revenue generated or received supports, in part, the development of new products, maintenance of our infrastructure, and retention of employees and financial advisors. Further in this Disclosure Brochure you will find information on how our financial advisors are paid. Cost Reimbursement Services and Third-Party Payments Payments from Product Companies All AFIG financial advisors are licensed and registered through Ameriprise Financial Services. Ameriprise Financial Services has exclusive control over the activities conducted on our behalf under the agreement with the financial institution and is responsible for the supervision of certain activities of AFIG financial advisors. AFIG financial advisors are affiliated with Ameriprise Financial Services in one of three ways: independent contractors and their personnel, Ameriprise employee financial advisors and financial institution employee financial advisors. Financial advisors employed by the financial institution are compensated by the financial institution from the portion of fees and commissions it receives from Ameriprise Financial Services. In such cases the financial institution serves as paying agent on our behalf in accordance with applicable law. The level of compensation received by financial advisors employed by the financial institution is based on their employment agreement with the financial institution. Ameriprise Financial Services does not pay any compensation to any non-registered employee or agent of the financial institution for referrals. Any referral fee paid by the financial institution to an employee or agent is a one- time, per-customer fee of a nominal, fixed dollar amount and is unrelated to the products and services you purchase. AEIS will receive the following types of payments with respect to the investment products we recommend, and you select for the investment of your applicable Managed Account assets. This compensation is used in part to fund the cost of providing the services, maintaining Managed Accounts and offering an investment platform for our clients as well as providing revenue and net earnings to AEIS. For qualified SPS Advisor Accounts, inherited IRAs in qualified SPS Advantage Accounts where a trust has inherited the IRA and Ameriprise Bank acts as trustee of the trust and eligible trustee-directed retirement plans in Select Separate Accounts, AEIS either does not collect Third Party Payments or credits them back to client Accounts as described in the “Fees and Compensation” section. AFIG financial advisors who provide services at a financial institution that does not have a Trust Department can offer trust services through other providers, including our affiliate, Ameriprise Bank. Ameriprise Financial Services and the AFIG financial advisor may serve as a finder relating to trust services and may receive a referral fee for business referred to unaffiliated trust providers. AEIS performs certain services for the benefit of Ameriprise Financial Services, its financial advisors and clients, including but not limited to record keeping, administration and shareholder servicing support, applicable platform level eligibility and investment product due diligence, investment research, training and education, client telephonic and other servicing, and other support related functions such as trading systems, technology updates, asset allocation and performance reporting tools, websites and mobile applications (collectively “cost reimbursement services”). Any cost reimbursement payments received by AEIS that are paid by product sponsors out of assets of the investment, such as a Ameriprise Financial Services is not a bank or credit union. Any services or products you purchase through an AFIG financial advisor are not guaranteed or insured by Ameriprise Financial Services or the financial institution. The financial institution is not a party to your Relationship Agreement with us. Ameriprise Financial Services and each financial institution have entered into a networking agreement under which we have agreed to share 64 mutual fund or unit investment trust, reduce the investor return on their investment. compensation that Ameriprise Financial Services and its affiliates receive including payments for cost reimbursement services described in this section and other cost reimbursement and marketing support payments received by us and our other affiliates, as described in the “How we get paid” and the “Revenue Sources for other Ameriprise Financial, Inc. companies” sections of this Disclosure Brochure as applicable. AEIS also receives revenues that exceed the costs of the cost reimbursement services provided. These revenues include cost reimbursement and marketing support payments (as described below under the heading “Education, Training, Seminar Reimbursement and noncash compensation”) and such payments increase the gross revenues and net earnings of AEIS. Mutual Fund and 529 Plan Marketing and Sales Support Payments. Mutual fund and 529 plan marketing and sales support payments are received from certain mutual fund firms. These payments form a structure referred to here as the Ameriprise Financial Mutual Fund Program (“Mutual Fund Program”) with approximately 140 mutual fund families offered by Ameriprise Financial Services. The goal at Ameriprise Financial Services is to offer a wide range of mutual funds using the following criteria: • Product breadth and strong-performing funds • Financial strength of the firm Ameriprise Financial Services has a financial incentive for its affiliate to continue to maintain these cost reimbursement arrangements, including arrangements with Full Participation Firms, and for AEIS to continue to receive revenue. Because not all investments provide for cost reimbursement payments, Ameriprise Financial Services has an incentive to recommend or select investment products that make such payments within the Managed Accounts Programs. Ameriprise Financial Services addresses this conflict of interest by applying objective due diligence standards and requiring all mutual funds, ETFs, ETNs, CEFs, UITs and alternative investments offered in the Programs to meet these standards. • Marketing and sales support payments paid to our affiliate AEIS to support cost reimbursement services • Ability to provide product support and training to our financial advisors • Tax benefits offered by individual states • Overall quality of the 529 plan (specific to 529 plans) Ameriprise financial advisors may offer, and clients are free to choose mutual funds from the approximately 140 fund families available. However, certain aspects of the Mutual Fund Program create a conflict of interest or incentive if Ameriprise Financial Services promotes, or Ameriprise financial advisors recommend, the mutual funds offered by a firm participating in the Mutual AEIS receives a variety of payments for cost reimbursement services from affiliated products sponsored or managed by affiliated investment advisers (e.g., Columbia Management) and by non- affiliated investment product companies which reimburse the costs of beneficial client services provided by Ameriprise Financial Services and AEIS. The most significant of these payments are reimbursement for marketing support received from the product companies. AEIS receives cost reimbursement payments from product companies for the following products: mutual funds, 529 plans, actively managed ETFs, UITs, non-traded REITs, real estate private placements, tax-deferred real estate exchanges, non-traded BDCs, fixed annuities, variable annuities, structured annuities, fixed insurance, variable insurance, structured products, managed futures funds, private equity offerings, non-traded closed end funds and hedge fund offerings. Ameriprise Financial Services receives cost reimbursement payments on our affiliated and unaffiliated annuity and insurance products which are not eligible investments for Managed Accounts. These payments are discussed in the remaining paragraphs of this section. Fund Program versus mutual funds offered by nonparticipating firms. As further described below, these conflicts and incentives arise from the cost reimbursement related to Education, Training, Seminar Reimbursement and noncash compensation, provided to our financial advisors by, as well as the payments AEIS receives from, firms participating in the Mutual Fund Program and with other relationships with firms, including Columbia Management; see the section titled “Columbia Funds” below. If AEIS and its affiliates did not receive this compensation, Ameriprise Financial Services would likely charge higher fees or other charges to clients for the services provided. When evaluating the reasonableness of the fees and expenses incurred in a Managed Account, you should consider not just the Asset-based Fee, but also the fund-level fees and other To be included in the Mutual Fund Program, firms have agreed to pay AEIS a portion of the revenue generated from the sale and/or management of mutual fund shares. Full Participation Firms make cost reimbursement payments at a higher level than do firms that have arrangements discussed in the “Other 65 These arrangements vary between firms and may be subject to change or renegotiation at any time. If a firm ceases to make cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the mutual fund firm. Financial Relationships” section. For each year a client holds shares of a particular mutual fund, the mutual fund’s advisor or distributor may pay AEIS an amount based on the value of the collective mutual fund shares held in clients’ accounts (asset- based payment). AEIS receives an asset-based payment (up to 0.20% per year for mutual funds and 0.18% per year for 529 plans) on some or all of Ameriprise Financial Services clients’ assets managed by the participating firms. In instances where a new Full Participation Firm relationship is established, in certain instances, to offset AEIS expenses for providing cost reimbursement services, the cost reimbursement payments will initially be structured in the form of an annual flat fee in addition to 0.20% of assets invested, with the total dollar amount of such payment not to exceed $1,250,000. Full Participation. Thirty firms fully participate in the Mutual Fund Program. These fund firms include Columbia Threadneedle Investments, Allspring Funds , American Century Investments, Amundi, BlackRock Funds, BNY Mellon, Delaware Investments, DWS Investments, Eaton Vance, Eventide Funds, Federated Hermes, Fidelity, First Eagle Funds, Franklin Templeton, Goldman Sachs Asset Management, Hartford Mutual Funds, Invesco, Janus Henderson Investors, John Hancock Investments, JP Morgan Asset Management, Lord Abbett, MainStay Funds, MFS, Natixis Funds, Neuberger Berman, Nuveen, Principal, PGIM Investments, Virtus and Voya Funds. These firms are referred to as “Full Participation Firms.” We offer 529 plans from nineteen firms. Of those firms, fifteen are Full Participation Firms. These fund firms include American Century, BlackRock, Columbia Threadneedle Investments, Fidelity, Franklin Templeton, Goldman Sachs, Hartford, Invesco, John Hancock, J.P. Morgan, MFS, Nuveen, Principal, Virtus and Voya. Each of these firms is referred to as a “Full Participation Firm.” The most current Mutual Fund Program information, as well as the previous calendar year’s totals of cost reimbursement payments received from Full Participation firms, in addition to distribution support amounts, may be viewed online by visiting www.ameriprise.com/funds and clicking on “An Investor’s Guide to Purchasing Mutual Funds and 529 Plans at Ameriprise Financial”. Certain Full Participation Firms pay our affiliate AEIS more marketing support for certain types of mutual funds. In general, Full Participation Firms offer actively managed mutual funds that permit cost reimbursement payments to be included in the Investment Costs charged by the mutual fund. The Investment Costs of actively managed mutual funds are generally higher than those of (i) passively managed ETFs which do not make cost reimbursement payments; and (ii) actively managed ETFs which do make such payments. Ameriprise Financia Services has a financial incentive to offer actively managed mutual funds and ETFs that make cost reimbursement payments to our affiliate. As a result, Ameriprise financial advisors may have an indirect incentive to sell such mutual funds and ETFs. We address this incentive by offering a full range of investment product options, including actively managed mutual funds and both actively and passively managed ETFs. In addition, we do not offer actively managed ETFs that are clones of an actively managed mutual fund from the same firm. A similar actively managed ETF may have a lower or comparable management fee as an actively managed mutual fund. Ameriprise further addresses this conflict of interest by calculating the compensation paid to our financial advisors for all assets without regard to the amount of cost reimbursement payments we or our affiliates receive in connection with client investments in mutual funds and other investment products. Additionally, Ameriprise Financial Services does not share with our financial advisors the cost reimbursement payments we or our affiliates receive. Education, Training, Seminar Reimbursement and Noncash Compensation. Full Participation Firms provide to Ameriprise financial advisors and, in some cases, to their clients, education, training, and support services relating to the investment products they offer. These firms may reimburse Ameriprise Financial Services, and Ameriprise Financial Services may subsequently reimburse Ameriprise financial advisors, for client/prospect education events and financial advisor sales meetings, seminars and training events, consistent with Ameriprise Financial Services policies. Ameriprise Financial Services and its financial advisors may also receive nominal noncash benefits from time to time. As a result, Ameriprise financial advisors may have greater familiarity with and an incentive to sell investment products of Full Participation Firms. If your Managed Account’s Sweep Program uses a money market mutual fund, AEIS receives cost reimbursement payments of up to 0.37% of the amount held in that money market fund Sweep Program. The amount that AEIS receives may be reduced based on fee waivers that are imposed by the money market fund firm. Firms sponsoring alternative investments may also provide Ameriprise financial advisors (and, in some cases, their clients), education, training, and support services relating to the investment products they offer. 66 Payments for Product Implementation and Trading Technology Expenses. Certain 529 plans may pay AEIS a fee of up to 1% of assets for NAV rollovers. The mutual fund’s distributor or affiliate may also make payments to AEIS for networking and/or omnibus support and other client services and account maintenance activities. AEIS will also receive sub- transfer agency fees with respect to investments you make in affiliated and non-affiliated mutual funds. For most investment products, AEIS will receive payments of up to $25,000 per investment product per expense from third-party firms to reimburse expenses associated with each of (i) conducting due diligence on the investment product; and (ii) the implementation of certain technology platforms or capabilities related to the distribution of the investment product. For most model investment portfolios in Signature Wealth and certain SMA strategies in Select Separate Account, AFS will receive payments of (i) up to $25,000 per investment product per expense; or (ii) reimbursement of actual costs incurred to reimburse expenses associated with the implementation of certain technology platforms or capabilities related to the distribution of the investment product. These fees vary depending on the mutual fund family and on whether the mutual fund keeps a separate record for each account (i.e., networked accounts) or relies on AEIS’s recordkeeping (i.e., omnibus accounts). Compensation for sub-transfer agency services range up to $12 per position annually for networked accounts, and up to $19 per position annually for omnibus accounts or, if paid on an asset basis, from 0.10% to 0.15% annually of any amounts you have invested in such mutual funds. In the case of certain no-load fund families for which AEIS has a direct relationship, the compensation for sub- accounting, administrative and distribution support services may be bundled into one asset-based fee of up to 0.35% (which may include a service fee up to a 0.25%) annually of the value of such shares held in an Account. Payments from Investment Providers Offering SMA Investment Portfolios Within the Signature Wealth Program. AEIS receives cost reimbursement payments for the sale of SMA investment portfolios offered within the Signature Wealth Program. AEIS receives an asset-based payment of up to 0.04% per year on Ameriprise Financial Services clients’ assets invested in the SMA investment portfolios. If an Investment Provider ceases to make such cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the firm. Other Financial Relationships AEIS and its affiliates may have other relationships with firms whose mutual funds Ameriprise Financial Services offers. These relationships may include affiliates of firms acting as a sub-adviser to CMIA, CMIA acting as a sub-adviser to a third-party firm, or affiliates of a firm managing an investment portfolio within another Ameriprise Financial Services or affiliated product, such as a RiverSource variable annuity. Firms may use CMIA to manage an underlying investment option in products offered through the Mutual Fund Program. AEIS has a cost reimbursement agreement with BlackRock Advisors, LLC with respect to mutual fund positions held by Ameriprise Financial Services customers. BlackRock, Inc. owns more than 5% of the outstanding shares of Ameriprise Financial, Inc. stock. Our affiliate CMIA has a sub-transfer agent agreement with Vanguard Group, Inc. with respect to the distribution of its investment products. Vanguard Group, Inc. owns more than 5% of the outstanding shares of Ameriprise Financial, Inc. stock. Distribution Support Relationships. AEIS also has cost reimbursement arrangements with firms for distribution support services. These “Available for Sale Firms” make payments to AEIS for distribution support but do not provide marketing and sales support, such as those provided by Full Participation Firms, and make payments at a lower percentage rate than Full Participation Firms. These firms make cost reimbursement payments to AEIS of up to 0.10% on assets for these services, which support the distribution of the fund’s shares and 529 plans by making them available on one or more of Ameriprise Financial Services platforms. In addition, certain mutual funds’ distributors pay a fee to AEIS of up to 0.10% for cost reimbursement services provided for the mutual fund shares purchased during a given period (sales- based payment). These mutual fund firms do not provide marketing and sales support such as those provided by Full Participation Firms to Ameriprise financial advisors, thus they do not have the same access to financial advisors as Full Participation Firms. Ameriprise Financial Services sells 529 plans from seven firms that do not make cost reimbursement payments to AEIS. Moreover, 529 plans offered by these firms are available for sale to in-state residents only. Those firms are: American Funds, Ascensus, Invesco, MFS, Orion, Union Bank & Trust and Virtus. Columbia Funds. AEIS and other affiliates of Ameriprise Financial Services provide certain administrative and transfer agent services to the Columbia Funds whose shares are owned by Ameriprise Financial Services clients. Ameriprise Financial Services and its affiliates generally receive more revenue from sales of affiliated mutual funds than from sales of other mutual funds. Employee compensation and operating goals at all levels of the company are tied to the company’s success. Certain employees may receive higher compensation and other benefits based, in part, on assets invested in affiliated mutual funds. 67 a result, Ameriprise financial advisors may have greater familiarity with and an indirect incentive to sell ETFs participating in the ETF Program. Ameriprise Financial Services addresses this incentive as described above in the “Mutual Fund and 529 Plan Marketing and Sales Support Payments” sub-section. Participate in ETF Program Yes Access to Ameriprise financial advisors Yes Make cost reimburse- ment payments Yes Actively managed ETFs offered for purchase No No No American Funds. For both affiliated an unaffiliated mutual funds we offer, AEIS receives cost reimbursement payments from mutual fund firms of up to 0.20% of assets invested in those funds. With most mutual fund firms, these payments are paid on an ongoing basis and determined solely based on total assets invested in the funds of a particular fund family held in clients’ accounts. Rather than determining the amount of the payment solely on an asset-based basis, American Funds pays AEIS an annual negotiated platform fee based on a number of factors, including prior year assets, in accordance with their prospectus governing each mutual fund. This platform fee will not exceed 0.20% of assets and will also not exceed the limits set forth in the prospectus governing each fund. You can find the total dollar amounts we receive annually from American Funds, as of the previous calendar year, by visiting www.ameriprise.com/funds and clicking on “An Investor’s Guide to Purchasing Mutual Funds and 529 Plans at Ameriprise Financial.” Actively managed ETFs that are classified as Eligible to Hold Investments or Ineligible Investments No No No American Funds are generally no longer available for new purchases in Ameriprise brokerage accounts (other than add-on purchases into existing positions, which may continue), and thus new investments of American Funds can generally only be executed in Advisory Solution Programs. Passively managed ETFs Ameriprise Preferred Line of Credit and Loan AEIS receives compensation from Ameriprise Bank, FSB for its Ameriprise Preferred Line of Credit and Loan support services. Payments from Alternative Investments Sponsors. AEIS, in consideration for its cost reimbursement services, may receive ongoing investor service and support fee payments from product sponsors of alternative investments available in Ameriprise Managed Accounts. Depending on the product sponsor, AEIS will receive payments of up to 0.25% of the assets invested in these products. Payments from UIT Sponsors. Certain UIT sponsors with which AEIS has agreements may pay AEIS cost reimbursement payments to help promote and support the offer, sale and servicing of UITs. These UIT sponsors are granted full access to Ameriprise Financial Services and our financial advisors to provide direct financial advisor education or sales support to promote their products. UIT sponsors without such agreements do not provide direct financial advisor education or sales support, thus they do not have the same access to financial advisors as full access firms. Such marketing and sales support may create a conflict of interest if Ameriprise Financial Services promotes, or Ameriprise financial advisors recommend, the UITs from UIT sponsors that have been granted full access versus UITs offered by nonparticipating firms. These conflicts may arise from the marketing and sales support provided to our financial advisors by, as well as the payments AEIS receives from, firms that have entered into such agreements. AEIS will receive both a fixed dollar amount of cost reimbursement Payments from Other Non-Affiliated Product Companies Payments from Actively Managed ETF Sponsors. For certain actively managed ETFs offered for purchase in Ameriprise Managed Accounts, AEIS receives from the ETF manager or distributor both (i) ongoing asset- based cost reimbursement payments of up to 0.18% of the assets invested in these products; and (ii) an annual flat program fee of up to $400,000 per manager or distributor. AEIS receives these payments to help promote and support the offer, sale and servicing of actively managed ETFs. These payments form a structure referred to as the Ameriprise Financial ETF Program (“ETF Program”) and compensate AEIS for the costs of maintaining the ETF Program. Firms participating in the ETF Program are granted full access to Ameriprise Financial Services and our financial advisors to provide direct financial advisor education or sales support to promote their products. Passively managed ETFs and actively managed ETFs that are classified as Eligible to Hold Investments or Ineligible Investments do not participate in the ETF Program, do not have access to financial advisors for education or sales support and do not make cost reimbursement payments, as summarized below. As 68 payments, based in part on projected UIT sales, as well as sales-based volume concessions. The total amount of these payments will not exceed 0.20% of total UIT sales. for a fixed annual fee of up to $250,000, which when combined with the payments described above for these types of investment products may exceed the ranges noted. Payments from Insurance Companies. Cost reimbursement payments are received by Ameriprise Financial Services and/or its affiliate, AEIS, from affiliated and unaffiliated insurance companies. Ameriprise Financial Services sells annuity and insurance products to its clients manufactured by its affiliate, RiverSource, as well as from select unaffiliated insurance companies. RiverSource and potentially other unaffiliated insurance companies may be permitted to reimburse Ameriprise Financial Services or AEIS, and these entities may subsequently reimburse Ameriprise financial advisors, for client/ prospect educational events and financial advisor sales meetings, seminars, and training events consistent with Ameriprise Financial Services and AEIS policies, as applicable. These companies may also provide support to the Ameriprise Financial Services internal sales desk, which in turn provides support to financial advisors. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource insurance and annuity products and the unaffiliated insurance companies who provide added educational support. Generally, unaffiliated insurance companies that issue annuities and life and disability income insurance policies do not provide direct client or financial advisor education or sales support, other than product training materials, product sales literature and addressing client service issues. However, in some instances direct financial advisor product education may occur. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource products. From unaffiliated long-term care insurance product manufacturers, AEIS receives payments up to 27.5% of the commissionable premium. AEIS receives varying payments from unaffiliated life, disability and other insurance product manufacturers. Mutual Funds & ETFs Available to Investment Managers. Investment Managers that construct investment strategies utilizing mutual funds and ETFs may utilize any mutual fund or ETF available for sale in our Programs provided the fund selected meets operational and other requirements designed to facilitate transaction execution and ensure timely order processing. Ameriprise Financial Services does not require Investment Managers to limit the mutual funds and ETFs utilized to only those that a financial advisor may recommend to a client in an SPS Advantage or SPS Advisor account or for a nondiscretionary mutual fund or ETF transaction in an Investor Unified Account or Vista Separate Account. Mutual funds and ETFs available for financial advisor recommendations are subject to initial and ongoing due diligence by the IRG based on a quantitative and qualitative process. Investment Managers are responsible for conducting their own independent due diligence and research on the mutual funds and ETFs utilized in constructing an SMA investment strategy or model portfolio available through the Programs. This may result in an Investment Manager reaching a different opinion for a particular mutual fund or ETF than the opinion of the IRG on that same investment. The IRG conducts initial and ongoing due diligence on Investment Managers available through the Programs and provides recommendations to the Oversight Committee on matters including due diligence findings that could result in a recommendation for termination. Mutual funds meeting the operational and other requirements noted above primarily consist of mutual funds from “Full Participation Firms.” AEIS receives cost reimbursement payments from the fund family when Investment Managers select mutual funds from “Full Participation Firms” for an investment strategy. The amount of any cost reimbursement payments AEIS receives from mutual fund firms is not considered in determining which funds are available to Investment Managers. Investment Managers do not have access to specific information on which mutual funds are offered by “Full Participation Firms” or the rate of reimbursement a “Full Participation Firm” pays AEIS for cost reimbursement services. Payments from Structured Products Sponsors. AEIS receives cost reimbursement for the sale of structured products. Depending on the structured product, AEIS will receive payments between 0.25% and 0.60% of the amount you invest, multiplied by the product’s term up to a maximum of 1.6%. For example, a structured note with a three-year term and a 0.40% payout could have an upfront payment of 1.2% (three years x 0.40%). Payments for Financial Advisor Support. Separately, for alternative investment products, AEIS will receive marketing and sales support payments in the form of an optional subscription for financial advisor support Mutual Fund & ETF Recommended List (“Starting Point List”) Ameriprise financial advisors may make mutual fund recommendations based on a group of funds that appear on the Starting Point List. Financial advisors are not required to use the Starting Point List as their source for mutual fund and ETF recommendations, and mutual funds contained on the Starting Point List may not be equally available across both Managed Accounts and Ameriprise brokerage 69 be included in the Mutual Fund Program and be eligible for inclusion on the Starting Point List, each Full Participation Firm must meet a number of criteria that consider product breadth and strong-performing funds, financial strength of the firm and the ability to provide education and training to Ameriprise financial advisors, including marketing and sales support services relating to the funds they offer. Full Participation Firms have also agreed to pay our affiliate, AEIS, a portion of the revenue generated from the sale and/or management of fund shares as further described above. accounts. All ETFs and mutual funds offered by Full Participation Firms or Available for Sale Firms, as further discussed below, must meet Ameriprise Financial Services’ due diligence standards to be eligible for inclusion on the Starting Point List. In developing the Starting Point List, the IRG applies a quantitative and qualitative evaluation process that includes an analysis of a fund’s returns, risk and expenses; the tenure and quality of the investment team; the soundness of the process and consistent implementation; and the overarching health of the organization. Certain mutual funds and ETFs that would have otherwise been included on Starting Point were excluded due to their high investment minimums. Client suitability must be considered when trading mutual funds and ETFs, including breakpoint discount eligibility and NAV transfer ability. The funds on the Starting Point List are subject to change periodically, however changes to the Starting Point List should not be the sole reason to prompt trading. The universe of mutual funds eligible for purchase in Signature Wealth generally represents a sub-set of the funds that appear on the Starting Point List or are otherwise sponsored or managed by Full Participation Firms that make cost reimbursement payments to AEIS. The list of eligible funds for Signature Wealth is therefore designed to primarily include, and therefore favor, mutual funds from Full Participation Firms. The Starting Point List is developed by the IRG based on eligibility criteria established by Ameriprise Financial Services. The universe of ETFs includes funds sponsored or managed by firms in the ETF Program and ETFs available for sale at Ameriprise. Approximately 2,100 mutual funds are eligible for inclusion on the Starting Point List. The primary universe of mutual funds includes only mutual funds sponsored or managed by Full Participation Firms in the Mutual Fund Program. If a suitable mutual fund recommendation for a particular asset class cannot be found within the Full Participation Firms’ offerings, the IRG will proceed to look for mutual fund options sponsored or managed by Available for Sale Firms. While the Starting Point List is developed by evaluating the performance characteristics of each fund’s Class A shares, the analysis is ultimately intended to apply at the mutual fund level. Mutual funds included on the Starting Point List may or may not offer an Advisory Share class or other share class that is available in our Managed Accounts Programs. As a result, Managed Account clients may be unable to purchase a fund on the Starting Point List. Similarly, Ameriprise brokerage account clients may be unable to purchase a mutual fund on the Starting Point List if that fund does not offer a share class available in Ameriprise brokerage accounts. In addition, some mutual funds included on the Starting Point List may offer lower-cost share classes than the Advisory Share class or other share class available in Advisory Solutions. You should consider whether you may be eligible to purchase these lower- cost share classes outside the Programs. These eligibility criteria are designed by Ameriprise Financial Services to primarily include, and therefore favor, mutual funds from Full Participation Firms. To Available for Sale Firms make payments at a lower percentage rate than Full Participation Firms. They do not have the same wholesaling access to financial advisors as Full Participation Firms. As a result, Ameriprise financial advisors may have a greater familiarity with and an incentive to sell funds of Full Participation Firms. The payments made to AEIS by Full Participation Firms and Available for Sale Firms reimburse the costs of client beneficial services provided by Ameriprise Financial Services and AEIS to financial advisors and clients, including but not limited to distribution, marketing, administration and shareholder servicing support, due diligence, training and education, and other support related functions (e.g., cost reimbursement services) and increase the revenues and profitability of AEIS. The most significant of these payments are reimbursement for marketing support received from Full Participation Firms and other product companies. Full Participation Firms make cost reimbursement payments at a higher percentage rate than do Available for Sale Firms. This presents a conflict of interest as Full Participation Firms pay AEIS more revenue than Available for Sale Firms, and thus AEIS earns more revenue from the purchase of mutual funds offered by Full Participation Firms than from the purchase of mutual funds offered by Available for Sale Firms. Clients may choose to follow the recommendations provided by their Ameriprise financial advisor or they may select from any of the other funds offered through Ameriprise Financial Services regardless of whether that fund appears on the Starting Point List. More information on the Full Participation Firms that participate in the Program, specific arrangements we have with them, and conflicts of interest or incentives that exist for Ameriprise Financial Services to promote (and for Ameriprise financial advisors to recommend) one fund 70 over another fund is provided on our website at ameriprise.com/funds and click “Purchasing Mutual Funds Through Ameriprise.” is affiliated with us and on the payout rate for which your financial advisor qualifies. These affiliations and compensation structures are described in the “Financial Advisors Compensation & Benefits” section of this Disclosure Brochure. Revenue Sources for Ameriprise Financial Services, LLC Financial Planning and Advisory Service Fees These are fees you pay for financial planning and fee- based investment advisory account services, respectively. Ameriprise Bank Savings Account and CDs. Ameriprise Financial Services receives compensation from Ameriprise Bank of 0.05% of the average monthly balance, on an annualized basis. This amount is shared with your Ameriprise financial advisor based on how your advisor is affiliated with us and on the payout rate for which your financial advisor qualifies. These affiliations and compensation structures are described in the “Financial Advisors Compensation & Benefits” section of this Disclosure Brochure. Ameriprise Brokerage Account Sales Charges. Sales charges, commissions and/or selling concessions are paid when you buy or sell equities or fixed income products including corporate bonds and municipal securities, mutual funds, ETFs, 529 plans, closed- end funds, preferred securities, UITs, non- traded REITs, non-traded BDCs, non-traded closed-end funds, hedge fund offerings, exchange funds, private equity offerings, managed futures funds, real estate private placement offerings and structured products. In addition, you may pay a markup or markdown in bond transactions executed in a principal capacity with AEIS. These charges vary by product and product type. Payments for Referrals to Structured Settlements Annuity Brokers. Ameriprise Financial Services receives a fee, shared with financial advisors, for referrals to non- affiliated structured settlement professionals for both client and non-client referrals. The amount and basis for the referral fee varies by relationship multiplied by the notional sales amount of the product. Underwriters’ Compensation. Ameriprise Financial Services receives a fee comprised of a selling concession, management fee, underwriting fee, and in some cases, a structuring fee for the sale of initial public offerings (“IPOs”) such as closed-end funds and preferred securities. The specific amounts vary by individual offering, and are disclosed in the prospectus of each offering. For example, with respect to mutual funds, the sales charge for a stock mutual fund is typically greater than that for a bond mutual fund. For other product types such as non-traded REITs, the sales charge you pay may also include a portion of the distribution, organization and offering fees and expenses. See the Working in Your Best Interest – Regulation Best Interest Disclosure for more information about costs, compensation and potential conflicts of interest relating to brokerage products and services. Periodic Fees. Periodic fees include IRA custodial fees, brokerage fees (i.e., account maintenance and order handling fees), and a portion of the fees associated with certain banking products and services (i.e., personal trust services). Transaction Charges. Ameriprise Financial Services does not assess online transactions charges in Managed Accounts to financial advisors. Franchisee financial advisors are assessed a transaction charge if entering an order by phone for SPS Advantage or SPS Advisor accounts. For employee financial advisors, this transaction charge is assessed to the employee’s branch, and not paid by the advisor. Direct payment by the financial advisor of phone-in transaction charges may be a disincentive for a franchisee financial advisor to recommend an SPS Advantage or SPS Advisor account or to recommend trades in the account(s). Periodic Expenses. Periodic expenses are paid from product assets, such as 12b-1 shareholder servicing fees paid from mutual fund assets (including 12b-1 fees paid on certain funds that serve as underlying investment options for 529 plan assets) and distribution fees paid from Ameriprise Certificate Company assets. 12b-1 shareholder servicing fees assessed in Ameriprise brokerage accounts may be used to pay for marketing, distribution and shareholder service expenses. Any 12b-1 shareholder servicing fees received for the share class utilized in Managed Accounts will be rebated to clients. For Managed Accounts, Ameriprise financial advisors pay the same mutual fund transaction rate for orders entered by phone for all mutual fund firms. Not all mutual fund families are available for purchase in a Managed Account. For more information about payments and potential conflicts of interest, please see the applicable prospectus, term sheet, application or other client disclosure forms. Distribution Access Fees As described above, Ameriprise Financial Services directs securities purchase and sale transactions through our affiliate, AEIS, on a fully disclosed basis. In Ameriprise Preferred Line of Credit and Ameriprise Preferred Loan. Ameriprise Financial Services receives compensation from Ameriprise Bank of 0.25% of the outstanding balance on the credit line or loan on an annualized basis. This amount is shared with your Ameriprise financial advisor based on how your advisor 71 exchange, Ameriprise Financial Services receives reimbursements from AEIS for our non-distribution related expenses. Financial Interest in Products amount invested, and share class purchased. Financial advisors receive compensation only from 12b-1 fees for mutual funds held in brokerage accounts. Ameriprise Financial Services and financial advisors receive more compensation for sales of certain types of products, such as insurance, rather than others. Economic Benefits of Affiliates’ Products and Services Ameriprise Financial Services has a financial interest in the sales of proprietary products that are manufactured by its affiliates. Ameriprise Financial Services and its affiliates receive more revenue from the sale of some financial products and services, particularly those products and services sold under the Ameriprise, Columbia Threadneedle Investments and RiverSource brands, than for the sale of other products and services. As with all financial services firms, a portion of our revenue and compensation can generate a profit for the firm. The revenue and compensation we receive helps us cover our expenses in providing and servicing these products and services. Employee and financial advisor compensation and operating goals at all levels of Ameriprise Financial, Inc. are tied to the success of its businesses. As a result, certain incentives and conflicts of interest may exist for Ameriprise Financial Services, our affiliates and our financial advisors if you purchase certain products or services recommended by your financial advisor. Generally, among other things, Ameriprise Financial Services and our affiliates will receive: Generally, Ameriprise Financial Services receives more revenue for securities or products sold in a fee-based account than for those sold with only a sales charge or commission. Higher revenue generally results in greater profitability for Ameriprise Financial Services. Employee compensation (including management and field leader compensation) and operating goals at all levels of the company are tied to the company’s success. Management, sales leaders and other employees generally spend more of their time and resources promoting Ameriprise, Columbia Threadneedle Investments and RiverSource branded products and services. • More revenue, in aggregate, from the purchase of products sponsored or managed by Ameriprise, Columbia Management and RiverSource (“proprietary products”) than from the purchase of products sponsored or managed by firms that aren’t affiliated with Ameriprise Financial, Inc. (“nonproprietary products”). Ameriprise Financial Services actively promotes the products of our affiliates through advertising, direct mail, and product support and training events. • More revenue from the purchase of products and services than from Asset-based Fees. • More revenue as the size of any margin account or Ameriprise Preferred Line of Credit balance increases. • More revenue when you purchase certain types of products, such as insurance and annuity products and direct investments. Any 12b-1 fees received by Ameriprise Financial Services for mutual funds held in any Managed Accounts will be rebated to clients, and financial advisors do not receive compensation from 12b-1 fees assessed on mutual funds held in Managed Accounts. For brokerage accounts, both Ameriprise Financial Services and individual financial advisors are compensated when clients buy mutual funds through Ameriprise Financial Services. Generally, financial advisors receive a portion of the sales charge and 12b-1 fees paid to the firm in connection with mutual fund purchases for as long as clients own the mutual fund shares. Sales charges and 12b-1 fees vary from mutual fund to mutual fund and from share class to share class. Ameriprise Financial Services and the financial advisor receive more compensation on fund or share classes that pay higher fees. • More revenue from products and services that generate ongoing revenue streams, such as mutual funds that pay ongoing 12b-1 fees, an investment advisory account service, and insurance and annuity products with mortality and expense charges. • More revenue when you purchase shares of Ameriprise Financial Services and the financial advisor generally receive less compensation when the sales charge and/or 12b-1 fee is reduced, waived completely, or where there is no sales charge or 12b-1 fee. Therefore, for brokerage accounts there is an incentive for our financial advisors to sell a fund that pays a load or a fund that pays a 12b-1 fee over funds that do not. mutual funds or 529 plans from Full Participation Firms than from firms with other distribution support relationships, as described in the “Cost Reimbursement Services and Third Party Payments” section of this Disclosure Brochure. • More revenue when you purchase investment Ameriprise Financial Services and Ameriprise financial advisors are paid in different ways for helping you choose mutual funds, depending on the type of fund, products for which we receive cost reimbursement 72 payments or have similar financial arrangements, as described in the “Cost Reimbursement Services and Third Party Payments” and “Revenue Sources for Ameriprise Financial Services, LLC” sections of this Disclosure Brochure. • Less revenue when a sales charge or commission is reduced or waived completely, or where there is no sales charge. • More revenue when you move assets (including retirement plan accounts) from another institution to Ameriprise Financial Services or RiverSource or into a product managed by Columbia Management or another affiliate. Financial advisors are required to take training on complex products developed by Ameriprise Financial Services and its affiliates and non-affiliated product manufacturers, prior to soliciting certain insurance and annuity products and a targeted subset of nonproprietary products. Additionally, it is possible that Ameriprise Bank would send an order on behalf of a trust account to AEIS and at the same time AEIS would execute the opposite order for a brokerage client. Investments may be made for Ameriprise Bank’s trust accounts in which Ameriprise Financial Services or its related persons have a position or interest. Although Ameriprise Financial Services and its related persons may own securities suitable for or held by clients, in no case will holdings of Ameriprise Financial, Inc., its subsidiaries or their employees or directors be directly sold to or purchased from Ameriprise Bank’s trust accounts. AEIS, an affiliate of Ameriprise Financial Services, may buy or sell for its own account securities that Ameriprise Financial Services may recommend for Ameriprise Bank’s trust accounts. Ameriprise Financial Services does not anticipate that conflicts of interest will arise because we have adopted policies and procedures prohibiting Ameriprise Financial Services and our related persons from engaging in trading activity that creates a conflict of interest with our clients, as discussed in the “Code of Ethics, Participation or Interest in Transactions and Personal Trading” section. Financial Advisors Compensation & Benefits The compensation programs for our financial advisors may vary based on, among other factors, the financial advisor’s industry experience, tenure with Ameriprise Financial Services, the type of practice structure (solo or team), and whether the financial advisor was formerly associated with a firm acquired by Ameriprise Financial, Inc. Additional general product training is available and specific product training is required for a number of complex products, including Columbia Threadneedle Investments and RiverSource branded products. It is likely that a product recommendation from your financial advisor will be drawn from the universe of products on which they were trained. Ameriprise Financial Services may enter into strategic alliances with companies that offer products or services that Ameriprise Financial Services and its financial advisors do not sell. As part of those alliances, Ameriprise financial advisors may receive gifts or non- cash compensation from the other companies, which are subject to SEC and FINRA regulations as well as Ameriprise Financial Services’ internal compliance policies. Some, but not all, of the financial planning software tools available for use by your financial advisor were developed by Ameriprise Financial Services or by unaffiliated third parties and may make it more convenient for your financial advisor to select proprietary products. An Ameriprise financial advisor is assigned to every investment advisory service. Ameriprise financial advisors have a wide range of business and educational backgrounds. They are required to have appropriate licenses and registrations to transact business, including Financial Industry Regulatory Authority (“FINRA”) registration, required state securities and insurance licenses and carrier appointments, and, where required, a state investment adviser representative registration. Most Ameriprise financial advisors are also appointed agents of RiverSource Life and, in New York only, RiverSource Life of New York, affiliates of Ameriprise Financial Services. Many financial advisors hold advanced academic degrees and/or professional designations, including Certified Financial Planner™ (CFP®) designation. In addition, ongoing training is available to financial advisors. For additional important information about an advisor check FINRA BrokerCheck at www.finra.org/brokercheck or call 800.289.9999. Ameriprise Financial Services grants RiverSource access to Ameriprise financial advisors and provides RiverSource with limited information related to Ameriprise clients to promote sales of RiverSource products and to assist financial advisors in understanding the features and benefits of those products. Ameriprise Financial Services does not grant this access to other non- affiliated companies offering similar products, thus they do not have the same access to financial advisors as RiverSource. Your financial advisor earns a living by providing you with financial advice and product recommendations to suit your goals. To understand how your financial advisor gets paid, you should first know that there are four ways Ameriprise financial advisors can be affiliated with us. 73 • Independent Contractor Franchisees. These financial advisors are not employed by Ameriprise Financial Services and they do not receive a salary from us. • Employee Financial Advisors. These financial advisors are employed by Ameriprise Financial Services. • Associate Financial Advisors. These financial advisors are employed by or contract with the independent contractor franchisees and they do not receive a salary or other compensation from Ameriprise Financial Services. A portion of the Advisory Fee including the AFPS Fee, if applicable is paid to your financial advisor for their role that supports your participation in a Program, including introducing you to the service, gathering the information necessary to prepare your service, helping you establish needs and goals, preparing and presenting your service, and/or providing financial advice on behalf of Ameriprise Financial Services. The remaining portion of the Advisory Fee goes to Ameriprise Financial Services for the supervisory, technical, administrative, and other support that is provided to all financial advisors, as further discussed in the “Fees and Compensation” section. • Financial Institution Employee Financial The actual portion of the Advisory Fee paid to your financial advisor depends on the payout rate for which your financial advisor qualifies and the amount of Advisory Fees you pay. • Advisors. These financial advisors are employed by the financial institution where they provide services and are compensated by the financial institution from the portion of fees and commissions it receives from Ameriprise Financial Services. The financial institution serves as paying agent for such compensation on our behalf in accordance with applicable law. Financial institution employee financial advisors’ compensation is based on their employment agreement with the financial institution. Independent contractor franchisees generally receive 72% to 91%, and employee financial advisors generally receive 0% to 46%, of the Advisory Fee (the “advisor payout rate”). In addition, the financial advisor may qualify for a bonus which could increase the effective advisor payout rate up to 91% for independent contractor franchisees and 57% for employee financial advisors, respectively. • Financial institution employee financial advisors generally receive 0% to 91% of the Advisory Fee based on their employment agreement with the financial institution. All Ameriprise financial advisors are licensed registered representatives. Depending on the affiliation, our financial advisors are compensated differently. Financial advisors may choose to change how they are affiliated with Ameriprise Financial Services over time. • Salary and Bonus If you are a client of the Ameriprise Personal Wealth Group, your employee financial advisor does not receive a portion of the Advisory Fee but may receive compensation in the form of a bonus based in part on revenue generated through your Advisory Fee. • In addition to the fees described below, employee financial advisors may receive a salary or wage from Ameriprise Financial Services. Associate financial advisors may receive either a salary or a flat fee from the independent contractor franchisee for whom they work, at the discretion of the employing or contracting independent contractor franchisee. In general, Advisory Fees generated by an associate financial advisor are paid to the employing or contracting independent contractor franchisee. At the discretion of the employing or contracting independent contractor franchisee, the associate financial advisor may receive financial advisory or referral fees. Financial advisors may also have the potential to receive bonus compensation. At the discretion of the employing or contracting independent contractor franchisee, the associate financial advisor may receive a bonus. Advisory Fees and Compensation Importantly, financial advisor compensation does not vary depending upon the investment(s) recommended to you within a Managed Account. However, the amount of this compensation may be more or less than what your financial advisor would receive if you paid separately for investment advice, brokerage and other transaction-based services. Therefore, your financial advisor may have a financial incentive to recommend a Program over a transaction-based brokerage account. Ameriprise Financial Services seeks to address this conflict of interest through a combination of disclosures and through our policies, procedures and supervision, related to the review and The Advisory Fee is the only component of the Asset- based Fee you pay that is shared between Ameriprise Financial Services and your financial advisor. Both independent contractor franchisee financial advisors and employee financial advisors receive advisor is paid a portion of the Advisory Fee and, if applicable, a portion of the AFPS Fee as compensation for your participation in a Program. Independent contractor franchisee financial advisors, however, receive a higher portion, or payout rate. 74 determination that a Managed Account is appropriate for you based on your financial and risk profile information and investment objectives (“Client Information”) in accordance with all applicable regulatory requirements. financial advisors. Discuss with your financial advisor the products he or she offers and the compensation your financial advisor receives, as some investment product companies and issuers, including RiverSource, may pay higher compensation than others. The portion of the Advisory Fee allocated to your financial advisor is impacted by factors including: Generally, among other things, your financial advisor may earn: • The type of affiliation that your financial advisor has with Ameriprise Financial Services; • More depending on how your financial advisor is affiliated with Ameriprise Financial Services, as described above • Whether your financial advisor was assisted by • More on the sale of certain fixed life and disability another person (which may be a financial advisor or another individual who makes a referral) in providing services to you; • The total and average assets his or her clients have invested in Managed Accounts; insurance products because of special compensation programs that provide increasing levels of compensation the more a financial advisor sells of these products from each individual insurance company. • • More on the purchase of annuity and insurance The specific level of Managed Account assets within a given client’s household; and • In which Program your Managed Account is held. products and direct investments, because they are more complex than other products and take more time to service. Information for Certain Clients investing in Manager Directed Programs • More revenue from products and services that generate ongoing revenue streams, such as mutual funds that pay ongoing 12b-1 fees, an investment advisory account service, and insurance and annuity products with mortality and expense charges. • More from certain sales incentive programs to increase overall assets under management. • Less on individual purchases within a transaction- based brokerage account because of the higher transaction charges your financial advisor pays on these accounts compared to a fee-based investment advisory account. • Less when a sales charge or commission is reduced or waived completely, or where there is no sales charge. • Typically, less when you exchange an existing annuity contract, mutual fund or insurance policy for certain like or similar products from the same company, unless you have held the existing product for a certain period of time. Your financial advisor must make recommendations based on your best interests without regard to their compensation. The portion of the Advisory Fee shared with your financial advisor is determined by several factors including the total assets their clients (or clients within an advisor’s team) have invested in Managed Accounts. Franchisees and certain financial institution financial advisors that contract with Ameriprise Financial Services on an independent contractor basis (“AFIG Independent Contractors”) receive a greater portion of the Advisory Fee for than for the SPS Advantage and SPS Advisor Programs. This difference in allocation creates is a conflict of interest for Franchisee financial advisors, their associate financial advisors and AFIG Independent Contractor financial advisors because there is a greater incentive to recommend the Manager Directed Programs. Ameriprise Financial Services manages this conflict of interest through a combination of policies, training, and disclosure and by supervising the suitability of recommendations made by its financial advisors in accordance with all applicable regulatory requirements. • More revenue if you purchase securities on margin that you could not otherwise purchase in a cash account. • A higher payout rate based on the level of product sales, on the number of financial plans sold, and on higher face value and/or death benefit amount for certain insurance products. Depending on these factors, your financial advisor may retain a larger portion of the Advisory Fee and, in those instances, may earn more than Ameriprise Financial Services’ portion, however your financial advisor must make recommendations based on your best interests and without regard to how much compensation will be received. • More when you move accounts (including Other Compensation Available to Financial Advisors retirement plan accounts) from another institution to Ameriprise Financial Services, CMIA or RiverSource. Ameriprise Financial Services offers a vast range of investment solutions to clients. Some products and services may be offered only by certain Ameriprise 75 • make on the life insurance or annuity product increases. If your financial advisor is a shareholder of Ameriprise Financial through our deferred compensation program, more compensation the more profitable the firm is. • Compensation for servicing trust accounts held with Ameriprise Bank. Generally, the compensation that the financial advisor will receive is calculated by a formula. Compensation may also increase as the financial advisor sells increasing amounts of life and disability income insurance products issued by that insurer. • Compensation for performing certain activities associated with your mortgage if that loan is purchased and serviced by Ameriprise Bank. In instances where a customer already owns a financial product sold by Ameriprise Financial Services, the amount of a financial advisor’s compensation may vary in connection with the sale of an additional or replacement product, due to formulas relating to the cancellation of a product that is already owned. • Compensation for providing services related to your Ameriprise Preferred Line of Credit based on an annualized fixed percentage of the client’s average daily outstanding balance. • Compensation for your Ameriprise Bank Savings Account and CD balances based on an annualized fixed percentage of the client’s average monthly balance. • Compensation for marketing that leads to you As a result, the financial advisor in such a transaction may have an incentive to recommend the purchase of additional or replacement insurance or annuity products or, conversely, an incentive to recommend that you not purchase additional or replacement insurance or annuity products, depending on the relevant compensation formula. opening a co-branded credit card account provided you activate the card and meet the initial spend requirements. Financial Advisors Compensation - Credit Products & Insurance Referral • Compensation for marketing that leads to your opening of an Ameriprise Bank Checking Account provided you meet the initial funding and other balance duration requirements. • Compensation for the sale or renewal of Your financial advisor receives compensation for the marketing that leads to your opening of a co-branded credit card account provided you activate the card and meet initial spend requirements. Ameriprise Certificates. Financial Advisors Compensation - Insurance and Annuity Products Ameriprise financial advisors will earn compensation for providing services related to your Ameriprise Preferred Line of Credit based on an annualized fixed percentage of the client’s average daily outstanding balance. Your financial advisor will receive compensation for performing certain activities associated with your mortgage if that loan is purchased and serviced by Ameriprise Bank. Our financial advisors primarily offer life and disability insurance and annuity products from RiverSource and certain pre-approved, but unaffiliated, insurance companies. However, in some situations where the client’s needs may be met more effectively by another company’s product, and RiverSource and other pre- approved providers do not offer such a product, Ameriprise financial advisors may offer insurance products issued by unaffiliated insurance companies. Your financial advisor receives referral fees when you purchase and maintain American Family Insurance, insurance products under a long-term distribution agreement between Ameriprise Financial Services, American Family Insurance Group and American Family Insurance (formerly Ameriprise Auto & Home). American Family Insurance is not affiliated with Ameriprise Financial Services and is owned by the American Family Insurance Group. If Ameriprise Bank accepts a trust based upon a referral from your financial advisor, Ameriprise Financial Services will receive a referral fee from Ameriprise Bank. A portion of this referral fee is shared with your financial advisor. The referral fee is paid by Ameriprise Bank from the fees earned for its services and is not an additional cost to the trust account. Your financial advisor also receives a referral fee for referrals to non- affiliated structured settlement professionals for both client and non-client referrals. If an unaffiliated insurance product is offered, the financial advisor is an appointed agent of the insurer and receives, directly or indirectly, compensation from the unaffiliated insurer for the sale and service of that product. The compensation for these nonproprietary products and RiverSource products is separate from, and in addition to, any fee you pay for investment advisory services and may vary depending on the type and size of the life insurance or annuity product that you purchase, the insurer that issues the product, the total number of life insurance and annuity products sold by the financial advisor for that insurer, and other factors. This compensation typically will increase as the size of the insurance policy or annuity contract increases, or the amount of the payments that you 76 Financial Advisors Compensation - Incentives, Training and Education recommendations made by its financial advisors in accordance with all applicable regulatory requirements. Please review your financial advisor’s Form ADV brochure supplement or ask your advisor if you have questions about whether these transition arrangements apply to them. From time-to-time, Ameriprise Financial Services also provides compensation to financial advisors in connection with the sale of all or a portion of their client base to an Ameriprise financial advisor. Some of this compensation may be dependent on a certain percentage of the client base remaining as clients of Ameriprise Financial Services for a certain period of time. It is also determined based on valuations of the financial advisor’s practice, or book of business. Product companies with which we have agreements work with Ameriprise Financial Services and our financial advisors to promote their products. They may pay for training and education events or due diligence meetings; and may reimburse expenses for prospecting events such as seminars for employees, financial advisors, clients and prospective clients. For employees and financial advisors, these events may be held at off-site locations, and the travel, meals and accommodations may be paid for by the product company. Additionally, product companies may occasionally provide business or recreational entertainment or gifts of nominal value to employees and financial advisors. Ameriprise Financial Services or sales leaders may, from time to time, offer contests or incentive programs to individual financial advisors or groups of financial advisors in particular areas. These contests and programs are limited to such targets as new client acquisition, financial plan count, net flows, total assets under management and financial advisor recruiting. The practice valuation formula results in higher compensation for revenues received from Managed Accounts versus Ameriprise brokerage accounts. As a result, your financial advisor has an incentive to recommend the opening of new Managed Accounts or the investment of additional assets into existing Managed Accounts or, conversely, an incentive to recommend that you not open an Ameriprise brokerage account or invest additional assets into a brokerage account. In addition, if your financial advisor is selling all or a portion of their practice to another Ameriprise financial advisor, this program could incentivize your financial advisor to recommend that you remain a client of the acquiring financial advisor and/or Ameriprise Financial Services. Ameriprise Financial, Inc. Equity Programs Single product or product categories are not eligible for sales contests or incentive programs with the exception of fixed life and disability income insurance. These programs and incentives and the receipt of other cash/noncash compensation could affect your financial advisor’s recommendations of products and/or services to you. These programs and incentives and other cash and/or noncash compensation are subject to SEC and FINRA regulations as well as Ameriprise Financial Services’ internal compliance policies. Financial Advisors Compensation - Recruitment We encourage our financial advisors to take an ownership stake in our future by holding stock in our parent company, Ameriprise Financial, Inc. (NYSE: AMP). To make this possible for financial advisors, we have created equity compensation programs for them. Employee financial advisors and independent contractor franchisees may be eligible to receive an annual stock bonus. In addition, independent contractor franchisees may be eligible to defer a certain percentage of their compensation each year. They may choose to invest all or portion of this deferral into a notional account that tracks the performance of Ameriprise Financial, Inc. stock. Financial advisors who are independent contractor franchisees may build equity in their practices and may receive payments if they sell all or a part of their practices to other Ameriprise financial advisors. Loan Programs Clients may have access to information about lending products and services through marketing and/or lending relationships Ameriprise Bank has with third- party financial institutions. Ameriprise Financial Services from time-to-time recruits financial advisors from other firms to join Ameriprise Financial Services. In connection with these recruiting efforts, Ameriprise Financial Services may enter into arrangements with financial advisors for the payment of compensation and/or loans based upon the value of eligible assets or accumulated production of the recruited financial advisor at a pre- determined measurement date. The funds may be payable immediately, over time, as a bonus, or as a loan. These arrangements may be structured to include a provision requiring that payment of transition compensation and/or loans will be dependent upon the advisor meeting certain agreed-upon production and/or asset level benchmarks. The financial incentives associated with these transition arrangements could influence the type and amount of product and/or service recommended by your financial advisor. Ameriprise Financial Services manages this conflict of interest by supervising the suitability of 77 Ameriprise Financial Services-required training, to sell the investment advisory service, franchise consultants or registered principals, as described below. Ameriprise Bank partners with Rocket Mortgage, LLC (NMLS #3030) that offers mortgage lending products and services. Ameriprise Financial Services and Ameriprise financial advisors do not accept any mortgage loan applications or offer or negotiate terms of any such loans. Financial advisors do not earn compensation related to the origination or referral of mortgage lending products offered and originated by such third-party providers. Ameriprise Bank may purchase and service some loans originated by Rocket Mortgage, LLC. Ameriprise Financial Services and Ameriprise financial advisors may receive compensation for assisting clients with mortgages serviced by Ameriprise Bank. Ameriprise Financial, Inc. is not affiliated with Rocket Mortgage, LLC. Ameriprise Bank does not guarantee products or services offered by Rocket Mortgage, LLC. In cases where two or more financial advisors are assisting you, both financial advisors may share in the Advisory Fee. Your servicing financial advisor will present the Managed Account or AFPS, set the Advisory Fee, and oversee the analysis and advice prepared for you. Your servicing advisor may or may not be the financial advisor authorized to use discretion to purchase and sell securities in your Managed Account (e.g., your SPS Discretionary Advisor). In the instance that your servicing advisor is not authorized to use discretion, the financial advisor authorized to use discretion will oversee the analysis and advice prepared for you. Only the financial advisor authorized to use discretion will purchase and sell securities in your Managed Account. Ameriprise Bank has partnered with Elan Financial Services in offering Ameriprise co-branded credit cards. Your financial advisor receives compensation for marketing efforts that lead to your opening of a co- branded credit card account provided you activate the card and make sufficient purchases. Ameriprise Bank has partnered with Goldman Sachs to make available the Ameriprise Preferred Line of Credit and Loan. Ameriprise financial advisors will earn compensation for providing services related to your Ameriprise Preferred Line of Credit and Loan based on an annualized fixed percentage of the client’s average daily outstanding balance. Apart from margin lending, offered by AEIS, neither your Ameriprise financial advisor nor Ameriprise Financial Services may arrange, promote, suggest or knowingly permit you to use line or loan proceeds to purchase securities or other investment products. Advisor-to-Advisor Training Programs Your servicing advisor may or may not be the financial advisor who has completed the required training for a particular investment advisory service or product. A financial advisor who has not completed the required training may refer a client to a financial advisor who has completed the required training for the service or product. The financial advisor who has completed the required training may pay a fee to the financial advisor who has not completed the required training for that referral. The financial advisor who has not completed the required training may provide investment advisory services for services and products that do not require training, however, only the financial advisor who has completed the required training required for a particular service or product will provide the analysis and advice prepared for you with respect to a service or product that requires the training. The financial advisor who has not completed the required training may receive a share of the commission from any services or products sold to you by your financial advisor who has completed the required training. Ameriprise Financial Services or its affiliates may also pay its financial advisors for training other financial advisors on specific products and services that we offer. A portion of this payment may be based on incremental sales of these products and services sold by the financial advisor receiving the training. Shared Compensation Your financial advisor may work with a franchise consultant. In those situations, the franchise consultant, who is registered with Ameriprise Financial Services, may receive compensation based on services and products that you purchase, and for the training and leadership of your financial advisor. The cost of the product or service you purchase is not affected. Financial advisors may also choose to work together as a team to share fees and commissions generated from products and services you purchase. The cost of the product or service you purchase is not affected by the fact that your financial advisor is a member of a team or by the fact that the fee or commission may be split. Your financial advisor may employ staff or work with other Ameriprise Financial Services staff to assist with creating your financial planning recommendations. This may include leveraging services in geographic locations outside of your financial advisor’s location, including international locations. Services provided may include entering data into financial planning software, providing initial calculation Your financial advisor may be allowed to share a portion of the Advisory Fee he or she receives with one or more other Ameriprise financial advisor(s), including financial advisors who have not completed the 78 and assistance in creating solutions. Your financial advisor will provide final recommendations to you. For these services, your financial advisor may pay a fee or salary to employed staff. Financial advisors and field leaders may share compensation with their registered support assistants or recommend bonuses for their non-registered support staff. We will continue to collect and retain the full amount of any Asset-based Fees paid to us in connection with your Managed Account, less any Manager Fees paid to an applicable Advisory Service Provider, until the Managed Account is designated for potential transfer to an Ameriprise brokerage account or terminated. This includes the portion of the Advisory Fee that would have been paid to a financial advisor if one was assigned to your Managed Account(s). The fees retained are used in part to pay other employees and for the technology that supports the services Ameriprise Financial Services provides to you. Employee financial advisors and selling leaders may receive continuing commissions and fees for the sale of certain products and services for up to five years after leaving the securities industry. Ameriprise offers a Business Development Account (BDA) Program. Eligible employee financial advisors may create a voluntary BDA in a predetermined amount and use this account for business-related expenses above and beyond what the company provides. Managed Accounts Without a Financial Advisor Management Compensation and Bonus Programs Employee compensation and operating goals at all levels of the company are tied to the company’s success. All employees, directly or indirectly, may receive higher compensation and other benefits when the investment products of certain providers, particularly affiliates, are purchased. Management, sales leaders and other employees spend more of their time and resources promoting Ameriprise, Columbia Threadneedle Investments, and RiverSource branded products and services. In the event that you request Ameriprise Financial Services to remove your current financial advisor from your Managed Account or your financial advisor resigns from Ameriprise Financial Services or your Managed Account, is terminated, or, for the SPS Advisor Program, your financial advisor is no longer able to act as your SPS Discretionary Advisor for any reason, the applicable Managed Account(s) will no longer have a financial advisor assigned to the Accounts. Generally, investment products in Managed Accounts can only be purchased through an Ameriprise financial advisor. Field leaders receive a salary and a bonus and are responsible for an operating budget for expenses. Bonus programs for Ameriprise Financial Services field leaders are designed to include an amount based on the aggregate sales of all products sold by financial advisors, including proprietary products, in the regions of the country those leaders are responsible for overseeing. The bonus incentive and expense programs present a potential conflict because they are based in part on sales of these products. Code of Ethics, Participation or Interest in Transactions and Personal Trading Code of Ethics Ameriprise Financial Services may reassign your Managed Account to another financial advisor and notify you of the change. If your Managed Account is reassigned to another financial advisor prior to its termination, your Managed Account(s) will continue to be billed but the Asset-based Fee rate may change based on the Advisory Fee rate you negotiate with your new assigned financial advisor. We will attempt to notify you if your Managed Account is no longer assigned to a financial advisor. If you would like to retain your Managed Account, contact us within the timeframe set out in the notification to have a financial advisor assigned. If the Managed Account remains unassigned after the designated timeframe, it will transfer to an Ameriprise brokerage account in accordance with the Relationship Agreement. As part of an overall internal compliance program, Ameriprise Financial Services has adopted policies and procedures imposing certain conditions and restrictions on transactions for the account of Ameriprise Financial Services and the accounts of our employees. Such policies and procedures are designed to prevent, among other things, any improper or abusive conduct when potential conflicts of interest may exist with respect to a customer or client. In addition, from time to time, restrictions are imposed to address the potential for self-dealing and conflict of interest which may arise in connection with the business of Ameriprise Financial Services as a broker- dealer. Ameriprise Financial Services has adopted various procedures to guard against insider trading. Participation or Interest in Client Transactions If your Managed Account does not have a financial advisor assigned to it and certain client directed trades are permitted, you may contact our Service Center at 1.800.862.7919 for assistance with a transaction. From time-to-time Ameriprise Financial Services and/or its affiliates and related persons may invest in the 79 same or related securities that Ameriprise Financial Services and/or its affiliates recommend to clients. Such transactions may occur at or at about the same time that such securities are bought or sold for client accounts. Ameriprise Financial Services has adopted policies and procedures imposing certain conditions and restrictions on transactions in these securities, such as trading blackout periods and preclearance requirements. See the “Financial interest in products” subsection in the “Revenue Sources for Ameriprise Financial Services, LLC” section in this Disclosure Brochure for more information about our financial interest in the sale of certain products and services. client. Accordingly, should Ameriprise Financial Services or its related persons come into possession of material nonpublic information with respect to any company, they may be prohibited from communicating such information to, or using such information for the benefit of, their respective clients, and have no obligation or responsibility to disclose such information to, nor responsibility to use such information for the benefit of, their clients when following policies and procedures designed to comply with law. Ameriprise Financial Services and its affiliates have adopted an “Insider Trading Policy” in accordance with Section 204A of the Advisers Act that establishes procedures to prevent the misuse of material nonpublic information by Ameriprise Financial Services and its associated persons. Personal Trading Rules and Procedures Review of Accounts Ameriprise Financial Services has adopted personal trading rules and procedures within the Ameriprise Financial Code of Ethics and Personal Trading Policy. These rules are designed to list standards of business conduct and to mitigate potential conflicts of interest for all persons of Ameriprise Financial Services when they engage in personal securities transactions. You may request a copy of the Ameriprise Financial Code of Ethics and Personal Trading Policy from your financial advisor or by contacting us at 800.290.6663. Certain supervisory functions are performed by Ameriprise Financial Services corporate office personnel. Corporate registered principals review a sampling of financial advisor’s financial planning relationships, including written financial planning recommendations periodically based on certain key factors. At the time your Managed Account(s) is opened, our corporate registered principals will review your Managed Account(s) to confirm it is appropriate based on your stated investment goals, time horizon, risk tolerance, and investment objectives. The standards of business conduct include compliance with applicable laws and regulations and with policies and procedures such as those contained in the Ameriprise Global Code of Conduct. Under the personal trading rules, persons are required to report their personal securities holdings and transactions, including transactions in certain mutual funds; must pre-clear certain investments; are restricted with respect to the timing of certain investments; and are prohibited from making certain investments. In addition, the Personal Trading Policy requires (i) Ameriprise employee financial advisors and their employees, (ii) its independent contractor franchisee financial advisors and their employees, and (iii) its affiliated investment advisers to conduct most personal trades through one of three designated broker-dealers unless an exception has been granted and report any changes in their selected broker- dealer. Insider Trading Policy Additionally, we periodically evaluate your Managed Account(s) to help ensure the investments are within applicable Program rules. For SPS Advantage and SPS Advisor Programs, the evaluation might include a review of concentrated securities positions and low or excessive trading. If any of your Managed Accounts in the SPS Advantage Program are subject to a concentrated position review, we will allow the grouping of eligible advisory assets in related Managed Accounts that you (i) own individually and (ii) own jointly with a member of your household for the purpose of such evaluation, provided that the particular SPS Advantage Managed Account under review continues to remain appropriate based on your stated investment goals, time horizon, risk tolerance, and investment objectives. You and your financial advisor may be required to take action to satisfy Program guidelines and requirements, or to retain your Managed Account. When appropriate, our corporate registered principals may also decide to call you directly to discuss your understanding of the Account(s), including the fees and expenses you will be paying. Our Compliance department also conducts routine surveillance of financial advisor activities. If you are in a financial planning relationship, including the consolidated advisory fee arrangement, you will Ameriprise Financial Services and its related persons may, from time to time, come into possession of material nonpublic information that, if disclosed, might affect an investor’s decision to buy, sell or hold a security. Under applicable law, Ameriprise Financial Services and its related persons are prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether such other person is a 80 receive written reports relating to your financial planning goals from your financial advisor at least annually. An important part of an advisory relationship involves providing you with the opportunity to engage in periodic reviews with your financial advisor or a designated member of the team servicing your Managed Account. In these reviews, you and your financial advisor should discuss any changes to your individual circumstances, financial situations, investment objectives and/or risk tolerance, and whether you would like to impose any reasonable restrictions on your Managed Account(s). Brochure) to retail customers or members of the Third Party Financial Institutions. Under the terms of these networking arrangements, financial advisors may not be able to offer to retail customers or members of the Third-Party Financial Institutions certain products that are otherwise available through Ameriprise Financial Services or its affiliates. Also, because of these networking arrangements, Third Party Financial Institutions may receive, in the form of a networking payment, a portion of Asset-based Fees and securities and insurance commissions paid to financial advisors for sales to retail customers or members of the Third- Party Financial Institutions. Our supervision and surveillance do not substitute for your continued review and monitoring of your Managed Account(s). You should review your Managed Account statements, trade confirmations, and other information we send to you. If you have any questions, please discuss them with your financial advisor. Client Referrals and Other Compensation Referral Arrangements and Other Economic Benefits Ameriprise Financial Services has entered in partnership with Renaissance Charitable Foundation Inc. (“RCF”) for the referral of clients or prospects that have indicated an interest in establishing and maintaining a donor advised fund made available through RCF. No referral fee is paid by RCF to Ameriprise Financial Services or financial advisors however donor advised funds established by RCF because of the referral generally invest in eligible Programs that are advised and serviced by the referring financial advisor. The administration fee that you pay RCF for a donor advised fund solution may be more or less than if you were to purchase the donor advised fund services from RCF or another non-profit organization. Any fees charged by RCF for the administration of the donor advised fund are not shared with Ameriprise Financial Services or financial advisors. Ameriprise Financial Service and your financial advisor will receive Asset-based Fee revenue from a donor advised fund established by RCF and invested in a Program and no revenue if donor advised fund assets are invested with a third-party investment adviser, whether through RCF or another non- profit organization. We seek to address this conflict of interest through a combination of disclosure and through our policies, procedures and supervision related to the determination that a referral to RCF is appropriate for you based on your Client Information, and by treating assets in Managed Accounts owned and administered by RCF and assets in Managed Accounts owned directly by you as separate and distinct advisory relationships in accordance with all applicable regulatory requirements. Ameriprise Financial Services maintains investment advisory referral arrangements, the terms of which are disclosed to the client, with individual professionals, professional firms, and select corporate, institutional or membership organizations (“Promoters”). For each such arrangement, Ameriprise Financial Services pays the Promoter for referral of their clients or members to Ameriprise Financial Services for its financial advisory services. The manner and amount of compensation to be paid in connection with these agreements is subject to negotiation between Ameriprise Financial Services and the applicable Promoter. Prospective clients are provided with applicable disclosures, including whether the Promoter is a client, the material terms of compensation (if any) and the material conflicts of interest (if any), that results from the Promoter's relationship with Ameriprise Financial Services. The most common compensation arrangements include a flat fee at the time of the referral, a recurring flat fee, or a sharing of a portion of any total Asset-based Fees. You will not be charged an additional fee as a result of any referral arrangements. Compensation may include a one-time payment or ongoing payments for the duration of the investment advisory relationship. Review of Issuers of Financial Products Ameriprise Financial Services and its affiliates have policies and procedures in place to review the issuers of financial products such as alternative investments, structured notes, and annuity and insurance products that Ameriprise Financial Services permits its financial advisors to offer to some or all of its clients. This review includes publicly available information and reports Ameriprise Financial Services may form networking arrangements with financial institutions such as banks, credit unions, credit union service organizations, Farm Credit Services, and trust service providers (“Third Party Financial Institutions”) to allow its financial advisors to offer investment advisory services, financial planning services and certain other non-deposit investment and insurance products and services (described elsewhere in this Disclosure 81 issued by third parties and may in some cases include certain nonpublic information provided by the issuer. plans); assets of the fund’s adviser, sub-adviser or an affiliate of either; and assets of the fund’s distributor or an affiliate. This compensation benefits RiverSource. Ameriprise Financial Services periodically reassesses, but does not continuously monitor, the creditworthiness or financial solvency of third-party issuers. These policies and procedures are reasonably designed to mitigate our clients’ exposure to credit and default risks resulting from an inability of the issuer to repay the principal on a note or fulfill an insurance obligation. However, you should be advised that credit markets can be volatile, and the creditworthiness of an issuer may change rapidly. Ameriprise Financial Services, as a seller of these products, is prohibited by regulation from guaranteeing or providing any assurance that an issuer of financial products will be able to fulfill the issuer’s obligation to any purchaser of such a product through Ameriprise Financial Services. Revenue Sources for RiverSource RiverSource The amount of this revenue varies by fund, may be significant and may create potential conflicts of interest for RiverSource. The greatest amount and percentage of revenue that RiverSource receives comes from assets allocated to subaccounts investing in funds managed by its affiliates, CMIA, and Columbia Wanger Asset Management. In general, the revenue directly related to assets under management that RiverSource receives currently ranges up to 0.65% of the average daily net assets invested in the underlying funds through the variable annuity or variable life insurance contracts RiverSource issues. This revenue is in addition to revenues RiverSource receives from the charges you pay when buying, owning or surrendering your variable annuity contract or life insurance policy. In accordance with applicable laws, regulations and the terms of the agreements under which such revenue is paid, RiverSource may receive this compensation for various purposes including financial advisor training and compensation, marketing and distribution, customer servicing, transaction processing, record keeping, and other administrative services. Revenue Sources for Columbia Management and Threadneedle Sales charges. You pay sales and other charges under RiverSource variable annuity contracts and life insurance policies. You may incur transaction costs or fees associated with structured annuities. You may pay a contingent deferred sales charge, or surrender charge, if you withdraw funds during the applicable period. Periodic Fees and Expenses. You pay certain fees and expenses under RiverSource annuity contracts, life insurance policies and disability income insurance policies, including (depending on the type of contract or policy) mortality and expense, administrative, policy, contract, and cost of insurance fees or charges, in addition to costs associated with certain riders that may be available for both fixed and variable products. Periodic Fees and Expenses. Columbia Management and Threadneedle International Limited may receive management fees and certificate advisory and services fees for services, including, with respect to Columbia Management, investment management services for Active Portfolios® investments. These revenues may be received from the Columbia Funds, Columbia ETFs, Columbia closed-end funds, Ameriprise certificates and from other affiliated and nonaffiliated advisory clients of Columbia Management and Threadneedle International Limited. Revenue Sources for Other Ameriprise Financial, Inc. Companies Periodic expenses are also paid from product assets, such as 12b-1 fees paid on certain funds that serve as underlying investment options for variable annuities and variable life insurance. 12b-1 fees may be used to pay for marketing, distribution and shareholder service expenses. There are several other Ameriprise Financial, Inc. companies that will receive revenue from the charges and fees you pay, including the following: • Ameriprise Certificate Company receives Investment and Interest Income. Investment and interest income from insurance company general account assets derived, in part, from the amounts you pay for insurance and annuity benefits. investment spread income earned on, and any early withdrawal penalty related to, Ameriprise certificates. • Columbia Management Investment Services Corp. receives certain fees and expenses paid from the Columbia Funds and Ameriprise certificates in exchange for the transfer agent services it provides. Variable Annuity and Variable Life Insurance Financial Arrangements. RiverSource selects the funds available within your variable annuity contract or variable life insurance policy. In doing so, RiverSource may consider various objective and subjective factors. These factors include compensation RiverSource may receive from fund assets (for those funds with 12b-1 82 • American Enterprise Investment Services Inc. is Ameriprise Financial Services has a financial interest in the sale of Columbia Funds, Ameriprise certificates and RiverSource products and certain other mutual funds. • compensated for its services through the brokerage commission and other fees charged for each brokerage transaction, which may include transactions made in an Ameriprise Bank trust account, or through the brokerage commission which is included in the overall asset-based fee, depending on the account option you select. • If the Sweep Program for your Managed Account is AIMMA, AEIS receives compensation from the Program Banks based on the cash balance in the AIMMA program. If your Managed Account sweeps uninvested cash to ABISA or to Ameriprise Bank as a Program Bank in the AIMMA program, Ameriprise Bank does not compensate AEIS but reimburses AEIS for its direct out of pocket expenses related to the sweep services provided. • AEIS receives compensation in the form of Ameriprise Financial Services sells annuity and insurance products manufactured by its RiverSource affiliates, as well as products from unaffiliated providers. RiverSource is permitted to reimburse Ameriprise Financial Services for client/prospect education events and advisor sales meetings, seminars, and training events pertaining to annuity and insurance products, consistent with Ameriprise Financial Services policies and industry regulation; Ameriprise Financial Services may also receive nominal noncash benefits from time to time. Unaffiliated annuity and insurance providers may not provide some services, or the same level of services, to Ameriprise financial advisors. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource annuity and insurance products. • Ameriprise Bank charges fees, depending on the terms of trust documentation and applicable state laws governing trust administration, for its administrative trust services that are separate from investment management fees charged by financial advisors and are not shared with Ameriprise Financial Services. interest charged on your margin account balance, as well as from order handling fees. In transaction-based brokerage accounts, AEIS may also engage in principal trading of certain types of fixed income securities for brokerage accounts— that is, it may buy and sell these securities for its own account with the objective of making a profit in certain circumstances, AEIS may buy these securities from you or sell these securities to you on a principal basis, in which case you will pay a markup or markdown on the transaction. • AEIS performs, for the benefit of Ameriprise Financial Services, its financial advisors and clients, cost reimbursement and marketing support services as described in the “Cost Reimbursement and Marketing Support” section. In recognition of the above, product sponsors will compensate AEIS for these services performed by AEIS. • When Ameriprise Bank is a Program Bank in the AIMMA program or ABISA is the Sweep Program, Ameriprise Bank earns income by lending or investing the deposits it receives and charging a higher interest rate to borrowers, or earning a higher yield, than it pays on the deposits held through these sweep programs. The difference is known as the “spread.” • • Ameriprise Bank earns revenue based on the amount of credit extended and the interest rate on the Ameriprise Preferred Line of Credit and Loan. Custody The capacity in which AEIS acts in any particular transaction is disclosed on each transaction confirmation you receive. AEIS is also compensated for the shareholder services it provides for certain mutual fund companies. These services include but are not limited to delivering shareholder communications such as updated prospectuses and statements of additional information, transaction confirmations and annual tax reporting, and monitoring compliance with share class, discounted sales charge, market timing and other mutual fund company policies. • Ameriprise Financial, Inc. receives fees paid from Columbia and the Columbia Funds and Ameriprise certificates in exchange for the administrative services it provides. In establishing a Managed Account, you establish and maintain a Managed Account with Ameriprise Financial Services. Neither Ameriprise Financial Services, nor any Advisory Service Provider will act as custodian for the brokerage account or take possession of any assets in the Managed Account. AEIS, one of our broker-dealer affiliates, provides custody and safekeeping services for Managed Account assets, and will ordinarily act as the custodian for all assets held in Managed Account. Because our affiliate maintains custody of our clients’ assets, we are required by SEC rules and regulations to obtain from AEIS at least annually a written internal control report (the “ICR”) prepared by a qualified independent public accountant, and AEIS is required to undergo an independent verification of the assets under • Columbia Management Investment Distributors receives fees paid from the Columbia Funds in exchange for the distribution services it provides. 83 Ameriprise Financial Services’ Proxy Voting Policies and Procedures its control. The ICR that we receive from AEIS is intended to show that our affiliate has established appropriate custodial controls with respect to client assets under custody. Retirement Accounts where ATC acts as custodian or trustee, AEIS shall act as an agent or sub custodian of ATC with respect to custody of assets. When Ameriprise Financial Services has proxy voting authority for applicable Select Separate Accounts, Ameriprise Financial Services will apply the following general principles to meet its proxy voting responsibilities: • Seek to ensure that proxies are voted in the best Investment Discretion economic interest of clients; • Address material conflicts of interest that may arise; and • Comply with disclosure and other requirements as required by law. Your Ameriprise financial advisor does not manage your securities or other investments on your behalf as part of AFPS. However, your financial advisor may offer a discretionary investment advisory service separately as part of our SPS Advisor Program. Voting Client Securities Ameriprise Financial Services intends to vote all proxies of which it becomes aware prior to the vote deadline. However, in certain limited circumstances, Ameriprise Financial Services may determine to refrain from voting. Ameriprise Financial Services and your financial advisor do not take any action or give advice regarding the voting of proxies solicited by or with respect to the issuers of securities in which assets of your Managed Account(s) may be invested, except for certain Select Separate Accounts where you delegate proxy voting authority to Ameriprise Financial Services. For all other Advisory Solution Programs, Ameriprise Financial Services and your financial advisor do not take any action or give any advice regarding the voting of proxies solicited by or with respect to the issuers of securities in which assets of your Managed Account(s) may be invested. Ameriprise Financial Services will forward to you or your designated agent, all proxy solicitations and materials related to other corporate actions that are received by Ameriprise Financial Services with respect to assets in your Managed Account(s). You are responsible for voting proxies and effectuating other corporate actions relating to the securities held in your respective Managed Account(s). Ameriprise Financial Services will use an independent third-party proxy service for its fundamental research on proxy questions and subsequent recommendations and has adopted the third-party provider’s proxy voting guidelines covering certain types of proposals. The guidelines indicate whether to vote for, against or abstain from a particular proposal. In circumstances where proposals are not covered by the guidelines or a voting determination must be made on a case-by-case basis, the Oversight Committee will make the voting determination. The Oversight Committee may consider the voting recommendations of analysts, Investment Managers and information obtained from outside resources. The Oversight Committee reserves the right to consider each proxy vote, whether covered by the guidelines or a third-party recommendation, based on the facts and circumstances of the proposal presented, and submit a vote that it believes is in the best economic interest of its clients. Ameriprise Financial Services has implemented policies reasonably designed to identify potential material conflicts of interest to help us vote proxies without undue influence from individuals or groups who may have an economic interest in the outcome of a proxy vote. These policies include: • Employing predetermined voting guidelines; For Signature Wealth, Active Portfolios®, Select Separate Account, including Select Strategist UMA, Vista Separate Managed Account, Investor Unified Accounts and Access Account Programs, you have the right to vote proxies on the securities in which your Managed Account assets may be invested from time to time, or you may delegate the authority to vote these proxies to the Investment Manager for your Managed Account. You may alternatively delegate the authority to vote proxies on your behalf to another person. • Causing proxies to be voted in accordance with recommendations of an independent third party; • Causing the proxies to be delegated to an Independent third party, which may include Ameriprise Financial Services’ proxy voting service provider; or • Neither Ameriprise Financial Services, your financial advisor nor any Advisory Service Provider are responsible for any other corporate actions relating to the assets in your Managed Account(s), including administrative filings such as proofs of claims related to bankruptcy or claims in class actions. In unusual cases, with the client’s consent and upon ample notice, forwarding the proxies to 84 Financial Information Ameriprise Financial Services’ clients so that they may vote the proxies directly. We are not required to include a balance sheet in this Disclosure Brochure because we do not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance. We do not have any financial conditions that are reasonably likely to impair our ability to meet our contractual commitments to clients. Ameriprise Financial Services has not been the subject of a bankruptcy petition during the past 10 years. Each Investment Manager to which you delegate voting authority will vote proxies according to its own applicable voting policies and procedures. Where you own both a Select Separate Managed Account and another discretionary Managed Account and both Managed Accounts invest in the same SMA strategy managed by the same Investment Manager, this may result in different voting determinations by Ameriprise Financial Services and the Investment Manager for the same particular proposal. We maintain proxy voting records to meet our obligations under applicable law. You may obtain a copy of our proxy voting policy, and other information regarding how your proxies were voted, upon request by writing to us at the address set forth on the first page of this Disclosure Brochure or calling the phone number that appears on that page. 85 Glossary • • • • “ABISA” means Ameriprise Bank Insured Sweep Account. “Access Account” means Ameriprise® Access Account. “Active Portfolios” means Ameriprise® Active Portfolios®. “Active Portfolios® Investment Fact Sheet” means the applicable Active Portfolios® investment fact sheet that includes biographical information about the Investment Manager and/or portfolio strategist, investment philosophy and style information, portfolio characteristics and composite performance. • “Additional Fees and Expenses” are any additional transaction related fees that may be incurred in connection with your Managed Account based on the nature of your investments. • “Advisers Act” means the Investment Advisers Act of 1940, as amended. • “Advisory Service Providers” refers, collectively, to affiliated and third-party investment advisory firms whose services Ameriprise Financial Services uses to provide discretionary and non-discretionary advisory services that include investment management, asset allocation and/or rebalancing, or providing investment models, as applicable, for certain Manager Directed Programs. • “Advisory Solutions” means the wrap fee program sponsored by Ameriprise Financial Services offering a variety of investment advisory programs. • “Advisory Shares” means advisory, institutional or other share classes that do not have a sales-load, do not have a sales-load and do not assess 12b-1 shareholder servicing fees. • “AEFA” means American Express Financial Advisors, Inc. • “AEIS” means American Enterprise Investment Services Inc. • “AFIG” means Ameriprise Financial Institutions Group. • “AFPS” means Ameriprise Financial Planning Service. • “AFPS Agreement” means the applicable financial planning service agreement, as it may be amended from time to time, that includes the specific terms under which the client will receive those services. • “AIMMA” means Ameriprise Insured Money Market Account, an FDIC insured interest-bearing multi- bank deposit product. • “Ameriprise” means Ameriprise Financial, Inc. • “Ameriprise Bank” means Ameriprise Bank, FSB. • “Ameriprise Financial Services”, “Ameriprise Financial”, “AFS”, “Sponsor” or “we”: means Ameriprise Financial Services, LLC. • “Asset Allocation Strategist” means strategist who solely provides asset allocation recommendations to the Investment Manager. • “Asset-based Fee” means our component-based pricing framework in which the sub-components of the Asset- based Fee (referred to as “fee components”) are separately itemized. • “ATC” means Ameriprise Trust Company. • “Available for Sale Firms” are firms that sponsor or manage mutual fund options to whom IRG will proceed to look for if a suitable mutual fund recommendation for a particular asset class cannot be found within the Full Participation Firms’ offerings. • “BDA” means Business Development Account. • “BDC” means a business development company. • “Brochure” or “Disclosure Brochure” means Ameriprise Managed Accounts Client Disclosure Brochure. • “Brokerage Agreement” means, collectively, the Ameriprise Brokerage Client Agreement, as it may be amended from time to time, along with the Other Important Brokerage Disclosures Document and Schedule of Account & Service Fees. • “CD” means a certificate of deposit. • “CEF” means a close-end fund. • “CFA” means Chartered Financial Analyst. 86 • “CFP®” means Certified Financial Planner™. • “CFTC” means the Commodity Futures Trading Commission. • “Client Information” means client’s financial and risk profile information and investment objectives. • “CMG” means Columbia Management Group, LLC. • “CMIA” or “Columbia Management Investment Advisers” means Columbia Management Investment Advisers, LLC. • “Columbia” or “Columbia Management” refers, collectively, to Columbia Management Investment Advisers, LLC and Columbia Wanger Asset Management, LLC. • “Columbia Funds” means investment companies and other funds advised by affiliated companies, Columbia Management Investment Advisers, LLC and Columbia Wanger Asset Management, LLC. • “Columbia Management Investment Distributors” means Columbia Management Investment Distributors, Inc. • “Columbia Wanger Asset Management” means Columbia Wanger Asset Management, LLC. • “Committee” or “Oversight Committee” means Ameriprise Financial Services, LLC’s Managed Accounts Program Oversight Committee. • “Covered shares” or “Covered Securities” means shares or securities for which Ameriprise is required to track costs basis, holding period, and certain other tax information, and report such information to the client and the IRS on Forms 1099-B (Proceeds from Broker and Barter Exchange Transactions).”CTA” means Commodity Trading Advisor. • “Discretionary Managers” refers, collectively, to Advisory Service Providers with investment selection discretion and SPS Discretionary Advisors. • “DRP” means a dividend reinvestment plan. • “ERISA” means the Employee Retirement Income Security Act of 1974, as amended. • “ETF” means an exchange-trade fund. • “ETN” means an exchange-traded note. • “Eligible Investments” means investment products (i) that meet Ameriprise Financial Services’ due diligence standards; and (ii) for which we have a selling or distribution agreement in place are offered and are available for purchase in SPS Advantage Accounts, SPS Advisor Accounts, Vista Separate Accounts and Investor Unified Accounts. • “Eligible to Hold Investments” means investment products for which our due diligence standards are met but either: (i) we do not have a selling or distribution agreement in place; or (ii) the investment is not otherwise available for purchase in Managed Accounts. • “Eligible to Hold Share Class” means a share class that is less expensive than the Advisory Share or other share class Ameriprise Financial Services offers for purchases in a given mutual fund available in the Advisory Solutions Programs. • “Envestnet” means Envestnet Asset Management, Inc. • “Envestnet Manager” means an SMA Investment Manager who entered into a sub-management agreement with Envestnet to provide discretionary Investment Manager or Model Provider investment management services. • “Exchange Act” means the Securities Exchange Act of 1934, as amended. • “Executing Party” refers, collectively, to the broker-dealer or stock exchange. • “FDIC” means the Federal Deposit Insurance Corporation. • “Feature” means the SPS Advantage automatic rebalancing feature. • “FIFO” means first in first out. • “FINRA” means the Financial Industry Regulatory Authority. • “Frequency Interval” means the rebalancing frequency interval. • “Full Participation Firms” are mutual fund firms that fully participate in the Mutual Fund Program. • “HIFO” means highest in first out. • “Household” is generally defined as an individual, his or her spouse or domestic partner, and the unmarried children under age 21 who reside at the same address and is applied separately by each Program. • “ICR” means an internal control report. • “Ineligible Investments” are investment products (i) that do not meet our due diligence standards, (ii) where due diligence has not been completed; or (iii) that are not otherwise eligible to be held more than 180 days in Managed Accounts. 87 • “Internal Revenue Code” means the Internal Revenue Code of 1986, as amended. • “IPO” means an initial public offering. • “IRA” means an individual retirement account. • “IRG” means Ameriprise Investment Research Group. • “IntraFi” means IntraFi Network LLC. • “Investments and Infrastructure Support Credit” is a credit to SPS Advisor Account clients for all sub- transfer agency fees and networking fees that AEIS receives from mutual funds firms. • “Investments and Infrastructure Support Fee” is a fee to support the cost of maintaining and serving the SPS Advisor Program. • “Investment Costs” are the underlying fees related to investment products client purchases within their Managed Account. • • “Investment Manager” is a manager with discretionary authority to purchase or sell securities or make other investments for client’s Account. “Investor Unified Account” means Ameriprise® Investor Unified Account. • “LIFO” means last in first out. • “Managed Account” means an Ameriprise investment advisory account for which you pay an ongoing Asset-based Fee • “Manager Directed Program” refers to the discretionary Programs, specifically Active Portfolios® investments, Select Separate Account, Vista Separate Account, Investor Unified Account and Access Account Programs that use the discretionary investment advisory services of Advisory Service Providers. Collectively we refer to these Programs as the Manager Directed Programs throughout this Disclosure Brochure. • “Mutual Fund Program” means Ameriprise Financial Mutual Fund Program, the structure formed by the payment of the mutual fund and 529 plan marketing and sales support payments that are received from certain mutual fund firms. • “NASD” means the National Association of Securities Dealers, a predecessor of FINRA. • “NFA” means National Futures Association. • “Non-covered” refers to securities that are not subject to mandatory tax reporting of cost basis and holding period. For more information on “covered” and “non-covered” securities, see the Cost Basis Reporting FAQ on Ameriprise.com. • “Non-Matching Shares” refer to mutual fund share classes that do not match the Advisory Share class or other share class offered by Ameriprise Financial Services as the only share class available for a particular mutual fund. • “Non-Target Securities” means securities that are purchased or transferred into the SPS Advantage • Account that are not a part of your Target Allocation. • “NYSE” means the New York Stock Exchange LLC. • “NYSE: AMP” means Ameriprise Financial, Inc. stock symbol on the NYSE. • “Outside Workplace Retirement Plan” means additional retirement plan assets not included in the Managed Account and that are held outside of Ameriprise Financial Services in a participant-directed defined contribution plan. • “Portfolio Strategist” means Portfolio Strategist who provides asset allocation and investment recommendations to the Investment Manager. • “Program” means each investment advisory program offered under Advisory Solutions. • “Program Banks” means FDIC member banks that participate in AIMMA. • “Program Bank List” means the list that identifies the Program Banks participating in AIMMA. • “Promoter” means any individual professional, professional firm, or select corporate, institutional or membership organization that provides testimonials or endorsements of Ameriprise Financial Services for its investment advisory services. • “Reasonable Restrictions” are client imposed reasonable stock or sector restrictions on the management of his/her discretionary Account(s). • • “Rebalancing Date” means the next rebalancing date for rebalancing your eligible assets to the targeted allocation. “Relationship” means an Ameriprise® Custom Advisory Relationship. • “Relationship Agreement” means the investment advisory agreement made between Ameriprise Financial Services and the client, as it may be amended from time to time. 88 • “REIT” means a real estate investment trust. • “RiverSource” refers, collectively, to RiverSource Life Insurance Company and RiverSource Life Insurance Co. of New York. • “RiverSource Distributors” means RiverSource Distributors, Inc. • “RiverSource Life” means RiverSource Life Insurance Company. • “RiverSource Life of NY” means RiverSource Life Insurance Co. of New York. • • “SEC” means the United States Securities and Exchange Commission. “Select Separate Account” means Ameriprise® Select Separate Account. • “Select Separate Account Model Provider” is a Model Provider who constructs a model portfolio according to the specific investment strategy. • “SEP” means a Simplified Employee Pension. • “Signature Wealth Investment Manager” means a non-affiliated third-party registered investment adviser as the discretionary Investment Manager for the Signature Wealth Program. The Signature Wealth Investment Manager is also the Active Portfolios® Investment Manager. • “Programs Investment Provider” means non-discriminatory investment advisers who construct the recommended model investment portfolios within the Signature and Active Portfolios® Programs. • “SIMPLE” means a Savings Incentive Match Plan for Employees. • “SIPC” means the Securities Investor Protection Corporation. • • • “SMA” means a separately managed account that follows an investment strategy offered by an Advisory Service Provider in Select Separate Account, Vista Separate Account, Investor Unified Account and Access Account Programs. SMAs typically invest in individual equity and bond securities. “SPS Advantage” means Ameriprise® Strategic Portfolio Service Advantage. “SPS Advisor” means Ameriprise® SPS Advisor. • “SPS Discretionary Advisor” means Ameriprise financial advisor authorized to use discretion in SPS Advisor. • “Sponsor” refers to Ameriprise Financial Services as the sponsor of the wrap fee program described in this Disclosure Brochure. • “Starting Point List” means mutual funds and ETF recommended list developed by IRG. • “Sweep Program” means money settlement feature offered by Ameriprise Financial Services that is intended to hold cash. • “Target Allocation” means your predetermined allocation in accordance with your instruction for Ameriprise Financial Services to rebalance your eligible assets. • “Third Party Execution Fees” means additional costs incurred when an Investment Manager directs transactions for execution with or through Executing Parties other than AEIS. • “Third Party Financial Institutions” means third party financial institutions such as community banks, credit unions, credit union service organizations, Farm Credit Services and trust service providers with whom Ameriprise Financial Services may form alliances and networking arrangements with to allow its financial advisors to offer investment advisory services, financial planning services and certain other non-deposit investment and insurance products and services, to retail customers/members of the Third Party Financial Institutions. • “Third Party Payments” means the portion of Investment Costs paid to AEIS by third parties who manage, sponsor or distribute investment products held in your Managed Account. • “TSCA” means Tax-Sheltered Custodial Account. • “UIT” means a unit investment trust. • • “UMA” means a managed account that enables you to own SMAs, mutual funds and/or eligible ETFs in a multi- account investment portfolio. “Vista Separate Accounts” means Ameriprise® Vista Separate Account. 89 Intentionally Left Blank 90 Intentionally Left Blank 91 Financial Planning I Retirement I Investments I Insurance 91 © 2025 Ameriprise Financial, Inc. All rights reserved. 413021 AY (03/26)

Additional Brochure: AMERIPRISE MANAGED ACCOUNTS AND FINANCIAL PLANNING SERVICE (2026-03-27)

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Ameriprise ® Managed Accounts and Financial Planning Service Client Combined Disclosure Brochure (Wrap Fee Program) (Part 2A Appendix 1 of Form ADV) This Wrap Fee Program Client Combined Disclosure Brochure provides clients with information about the qualifications and business practices of Ameriprise Financial Services, LLC and Ameriprise® Managed Accounts services. If you have any questions about the contents of this Combined Disclosure Brochure, please contact us at 800.862.7919. The information in this Combined Disclosure Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration with the SEC or any state securities authority does not imply a certain level of skill or training. Additional information about Ameriprise Financial Services, LLC is available on the SEC website at www.advisorinfo.sec.gov. March 2026 Sponsor: Ameriprise Financial Services, LLC 70400 Ameriprise Financial Center Minneapolis, MN 55474 ameriprise.com SEC Registration No. 801-28543 402422 AN (03/26) Material Changes This Combined Disclosure Brochure dated March 2026 is filed as an update to the Form ADV Part 2A, Appendix 1 and includes material changes that have occurred since the last annual update of our Brochure in March 2025. Following is a summary of the material changes: June 2025 • The “Fee Information for Managed Account Programs” sub-section of the “Fees and Compensation” section has been updated to include that effective August 2025, Ameriprise Financial Services began charging a Platform Fee on SPS Advantage, SPS Advisor and Active Portfolios® Programs. September 2025 • The “Types of Advisory Service Providers” sub-section of the “Overview of Ameriprise Managed Accounts” section has been updated to add the following definition: o Investment Providers (effective December 2025). Investment Providers for the Active Portfolios® Program construct the recommended holdings for a model investment portfolio according to their specific investment strategy and may include their proprietary mutual funds and/or ETFs in the model investment portfolios. Our affiliate CMIA also participates in the Active Portfolios® Program as an Investment Provider. Each Investment Provider’s disclosure document (Part 2A of Form ADV) is available to you at ameriprise.com/investmentproviders. The Investment Providers provide non- discretionary investment and asset allocation recommendations to the Investment Manager. Investment Providers do not have any investment discretion or trading authority to purchase or sell securities in your Account. The Investment Manager exercises investment discretion for the Active Portfolios® Accounts. Different Investment Providers may arrive at different investment and asset allocation recommendations regarding investments in a certain sector, market capitalization, or other category of investments, depending on the model portfolio’s investment objective. Oversight of the discretionary Investment Manager, Investment Provider and the model portfolio’s investment strategy is provided by the Oversight Committee, as described above. • The “Signature Wealth” sub-section of the “Managed Account Programs and Services” section has been updated to reflect that SMA model investment portfolios will become available in the Program effective on or around December 1, 2025. • The “Signature Wealth” and “Select Separate Account” sub-sections of the “Managed Account Programs and Services” section have each been updated to reflect that concurrent with the addition of SMA model investment portfolios to the Signature Wealth Program in late 2025, certain SMA strategies that are currently available in the Select Separate Account Program will become available in our Signature Wealth Program as our initial step to transition such SMA strategies from the Select Separate Account Program into the Signature Wealth Program. The full transition process will include the following steps: Ameriprise Financial Services will (i) first close the SMA strategy in the Select Separate Account Program to new investments prior to offering the SMA strategy in the Signature Wealth Program; (ii) generally allow pending new accounts for the SMA strategy to continue to be processed in the Select Separate Account Program; and (iii) subsequently migrate existing accounts investing in the SMA strategy from the Select Separate Account Program into the Signature Wealth Program. During this transition, if you currently hold an impacted SMA strategy in an existing Select Separate Account the Platform Fee rate you pay is higher for your Select Separate Account than it would be if you held the same SMA strategy in the Signature Wealth Program. If your Select Separate SMA strategy will go through this transition, Ameriprise Financial Services will notify you. This creates a conflict of interest as Ameriprise Financial Services receives a higher Platform Fee for Select Separate Accounts than we receive for Signature Wealth Accounts, including the transition period when the same SMA strategy is held in both Programs. Ameriprise Financial Services addresses this conflict through a combination of disclosures and by closing any duplicative SMA strategies through the transition process described above. Additionally, the transition process does not impact the Manager Fee that compensates the Advisory Service Provider and does not affect the portion of the Asset-based Fee received by your financial advisor. However, the transition process will result, for a limited period of time, in Sponsor receiving a higher Platform Fee from impacted SMA strategies held within Select Separate Accounts than it would from the same SMA strategy invested in Signature Wealth Accounts. Beginning in the second half of 2026, Ameriprise Financial Services plans to eliminate this conflict of interest by migrating any Select Separate Account with an impacted SMA strategy from the Select Separate Account Program to the Signature Wealth Program, in accordance with the Relationship Agreement. As noted above, if your Select Separate Account SMA strategy is a part of this transition, Ameriprise Financial Services will notify you so that you may work with your financial advisor to transition your Select Separate SMA Account to the Signature Wealth Program at a date of your choosing so that you can benefit sooner from the reduced Platform Fee rate the Signature Wealth Program provides. • The “Active Portfolios” sub-section of the “Managed Account Programs and Services” section has been updated to reflect that effective on or around December 1, 2025, your current Investment Manager will begin providing investment advisory services as a non-discretionary Investment Provider and will no longer have discretionary authority. All discretionary investment management will be provided by the Signature Wealth Investment Manager, a non-affiliated third-party Advisory Service Provider, which will also become the Investment Manager for all Active Portfolios® Accounts. Investment Providers will provide asset allocation and investment selection recommendations for their specific portfolio(s) to the new Investment Manager. The new Investment Manager will have the discretionary authority to purchase or sell securities or make other investments for your Account, however, you directly own the underlying securities in the portfolio. The new Investment Manager will invest your Account assets into the portfolio you select with your financial advisor and will be responsible for the ongoing investment management and trading of your Active Portfolios® Account, subject to any Reasonable Restrictions or other instructions provided by you. Your financial advisor will continue to provide recommendations regarding which portfolio to hold in your Active Portfolios® Account. The new Investment Manager, not your financial advisor or the Investment Provider, will provide you with discretionary investment management services for your Active Portfolios® Account according to your Account’s target asset allocation and the portfolio you select. March 2026 • The “Cost Reimbursement Services and Third-Party Payments” section was updated to include the following sub-section: o Payments from Investment Providers offering SMA investment portfolios within the Signature Wealth Program. AEIS receives cost reimbursement payments for the sale of SMA investment portfolios offered within the Signature Wealth Program. AEIS receives an asset-based payment of up to 0.04% per year on Ameriprise Financial Services clients’ assets invested in the SMA investment portfolios. If an Investment Provider ceases to make such cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the firm. • The “How our financial advisors get paid” section was retitled “Financial Advisor Compensation and Benefits” and was updated in general for clarity and overall readability as well as the addition of the following sub-section: o Information for certain clients investing in Manager Directed Programs. Your financial advisor must make recommendations based on your best interests without regard to their compensation. The portion of the Advisory Fee shared with your financial advisor is determined by several factors including the total assets their clients (or clients within an advisor team) have invested in Managed Accounts. Independent contractor franchisees (each a "Franchisee") and certain financial institution financial advisors that contract with Ameriprise Financial Services on an independent contractor basis ("AFIG Independent Contractors") will be allocated a larger portion of the Advisory Fee for the Manager Directed Programs than for the SPS Advantage and SPS Advisor Programs. This difference in allocation is a conflict of interest for Franchisee financial advisors, their associate financial advisors and AFIG Independent Contractor financial advisors because there is a greater incentive to recommend the Manager Directed Programs. Ameriprise Financial Services manages this conflict of interest through a combination of policies, training, and disclosure and by supervising the suitability of recommendations made by its financial advisors in accordance with all applicable regulatory requirements. You may request at any time a current copy of this Combined Disclosure Brochure, and if applicable, Part 2A of your Investment Manager’s Form ADV Brochure (as defined below in the Overview of Ameriprise Managed Accounts section of this Disclosure Brochure) from your financial advisor. The current Combined Disclosure Brochure replaces any earlier version you receive. You may also request copies of the Combined Disclosure Brochure(s) by writing Ameriprise Financial Services, LLC at 2661 Ameriprise Financial Center, Minneapolis, MN 55474, or by calling 800.297.6663. Please retain a copy of this Combined Disclosure Brochure for your records. Table of Contents Ameriprise ® Managed Accounts and Financial Planning Service Combined Disclosure Brochure ........................ 6 Ameriprise consolidated advisory fee service ................................................................................................. 6 Appropriateness of a consolidated advisory fee service for you ........................................................................ 6 Establishing and maintaining a consolidated advisory fee service .................................................................... 7 Asset-based fee for your consolidated advisory fee service ............................................................................. 7 Renegotiating Advisory Fees ......................................................................................................................... 7 Terminating your consolidated advisory fee service ......................................................................................... 7 Managed Accounts services, fees and compensation ................................................................................. 8-60 Appropriateness of a Managed Account for you .......................................................................................... 8-11 Overview of Ameriprise Managed Accounts ........................................................................................... 11-22 • Advisory Service Providers ...................................................................................................... 18-22 The Ameriprise Custom Advisory Relationship .......................................................................................... 22 Advisory Solution Programs and Services for Managed Accounts ........................................................... 22-26 • SPS Advantage ....................................................................................................................... 27-30 • SPS Advisor ........................................................................................................................... 30-32 • Signature Wealth .................................................................................................................... 32-36 • Active Portfolios® .................................................................................................................... 36-38 • Select Separate Account ......................................................................................................... 38-41 Managed Accounts offered with Envestnet Asset Management, Inc. ........................................................ 42-43 • Vista Separate Account ............................................................................................................... 42 • Investor Unified Account ......................................................................................................... 42-43 • Access Account .......................................................................................................................... 43 Supplementary Managed Accounts Information ..................................................................................... 43-50 Fees and Compensation ...................................................................................................................... 50-58 • Sweep Program and Expenses ................................................................................................. 58-62 Account requirements and types of clients ............................................................................................. 62-63 • Establishing and maintaining Accounts .................................................................................... 62-63 • Terminating a Relationship Agreement ......................................................................................... 63 Client Information provided to Advisory Service Providers ....................................................................... 63-64 Ameriprise Financial Planning Service .................................................................................................... 64-70 • AFPS planning goals ................................................................................................................... 65 • • • Financial fundamentals ............................................................................................................... 65 Additional financial planning areas .......................................................................................... 65-66 Initial recommendations .............................................................................................................. 66 • Ongoing relationship ................................................................................................................... 66 • Changing your planning goals ...................................................................................................... 66 • Implementation of your financial planning recommendations ..................................................... 66-68 • How to make the most of your financial planning relationship .................................................... 68-69 • Other advisory services ............................................................................................................... 69 • Fees and Compensation ......................................................................................................... 69-71 Performance-Based Fees and Side-by-Side Management .......................................................................................... 71 Types of Clients ...................................................................................................................................................... 71 Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................ 71-73 Disclosure of interest and capacity ........................................................................................................ 73-74 Privacy Notices ......................................................................................................................................... 75 Additional Information ............................................................................................................................... 75 • • Disciplinary Information .............................................................................................................. 75 Other financial industry activities and affiliations ..................................................................... 75-78 How we get paid ................................................................................................................................... 78-87 • Cost Reimbursement Services and Third Party Payments ........................................................... 78-85 • Revenue Sources for Ameriprise Financial Services, LLC Financial planning and advisory service fees. ....................................................................................................... 85-86 • Economic benefits of affiliates’ products and services .............................................................. 86-87 Financial Advisor Compensation and Benefits ......................................................................................... 87-95 • Code of Ethics, Participation or Interest in Transactions and Personal Trading ............................ 93-95 Client Referrals and Other Compensation ................................................................................................... 95 • Referral arrangements and other economic benefits ................................................................. 95-96 • Review of issuers of financial products ........................................................................................ 96 • Revenue Sources for RiverSource ................................................................................................ 96 • Revenue Sources for Columbia Management and Threadneedle ..................................................... 96 • Revenue Sources for other Ameriprise Financial, Inc. companies ................................................... 97 • Custody ..................................................................................................................................... 97 • Investment Discretion ................................................................................................................. 98 • Voting Client Securities ............................................................................................................... 98 • Ameriprise Financial Services’ Proxy Voting Policies and Procedures .......................................... 98-99 • Financial Information .................................................................................................................. 99 Glossary ........................................................................................................................................... 100-103 If there is any conflict in the description of the investment advisory services or the details regarding fee information between the Ameriprise® Custom Advisory Relationship Agreement (“Relationship Agreement”) and the Combined Disclosure Brochure, the Combined Disclosure Brochure will control. Appropriateness of a Consolidated Advisory Fee Service for You Ameriprise ® Managed Accounts and Financial Planning Service Combined Disclosure Brochure This Combined Disclosure Brochure covers important information that is divided into four key components outlining information about the: • consolidated advisory fee service; • Ameriprise® Managed Accounts offered by Ameriprise Financial Services, LLC; Before selecting a consolidated advisory fee service, you should consider, among other things, the costs and potential benefits of a combined advisory service and your investment objectives. The costs associated with a consolidated advisory fee service that you should consider include: • Ameriprise® Financial Planning Service; and • A consolidated advisory fee service may be • important information about Ameriprise Financial Services, LLC. appropriate for you if you wish to receive AFPS and pay for the service through one or more eligible Managed Accounts. • The cost of a consolidated advisory fee service will be included in the Asset-based Fee for your Managed Account(s) and a portion of the Asset- based Fee will be allocated to cover AFPS (the “AFPS Fee”), as further described in this Combined Disclosure Brochure. Each section of this Combined Disclosure Brochure offers important information about engaging in a consolidated advisory fee service that allows you to have both Managed Account and financial planning services for a single asset-based fee (“Asset-based Fee”). The Asset-based Fee is a wrap fee. Ameriprise Consolidated Advisory Fee Service • When you pay for AFPS separately, you are paying a flat fee that you negotiate and agree upon with your financial advisor. When you pay for AFPS as part of a consolidated advisory fee service, you agree to allocate a portion of the Advisory Fee to cover your AFPS expenses. This portion will rise and fall with your Managed Account balance, which is impacted by the markets, deposits and withdrawals. As such, you may pay more or less for AFPS than you would if you did not elect to pay for both AFPS and Managed Accounts with a single, asset-based fee. • In addition, you may pay more or less for AFPS in the consolidated advisory fee service than other AFPS clients with a comparable level of complexity. Clients of Ameriprise Financial Services, LLC (“Ameriprise Financial Services”, “Sponsor,” or “we”) may elect to pay for the Ameriprise® Financial Planning Service (“AFPS”) and Managed Account service either separately or through a consolidated advisory fee service. Ameriprise Financial Services, LLC sponsors a wrap fee program offering a variety of investment advisory accounts (collectively, “Advisory Solutions”). Within Advisory Solutions, Ameriprise Financial Services offers a number of investment advisory programs (each a “Program” and collectively the “Programs”) that have different features and services, supporting a wide array of investment strategies. When you decide upon a Program, you may open an investment advisory account (“Managed Account”). Please review the information in this Combined Disclosure Brochure carefully before you make a decision and contact your financial advisor if you have any questions about the types of fees and expenses that may be associated with your consolidated advisory fee service. A consolidated advisory fee service charges an Asset- based Fee, which combines the fees you pay for advisory services you receive for an AFPS and at least one Managed Account, both of which are described more fully in this Combined Disclosure Brochure. For these two services you will pay a single, Asset-based Fee as described in the “Fees and Compensation” sub- section of the “Ameriprise® Managed Accounts services, fees and compensation” section. 6 alternate non-qualified brokerage account or a non- qualified Managed Account. Establishing and Maintaining a Consolidated Advisory Fee Service To establish the consolidated advisory fee service, you will be asked to: • Review this Combined Disclosure Brochure, the Relationship Agreement and documents that you sign to establish your consolidated advisory fee service; and ask your financial advisor any questions; You can renegotiate your Advisory Fee applicable to each Account and your AFPS Fee, if applicable, with your financial advisor at any time. Your financial advisor will complete the appropriate documents reflecting the new Advisory Fee and/or AFPS Fee. Your signature will not be required if the new sum of your Advisory Fee and AFPS Fee does not exceed the higher of your Account’s current Assessed Advisory Fee or the applicable Negotiated Advisory Fee, if the Account is part of a Relationship. • Provide accurate and complete information to your financial advisor to complete the relevant consolidated advisory fee service documents; • Establish and maintain at least one Managed Account as part of the consolidated advisory fee service; and Your Negotiated Advisory Fee is the highest Advisory Fee that you agree could apply to an Account opened under the Relationship without obtaining an additional signature. The Assessed Advisory Fee is the sum of the Advisory Fee and AFPS Fee that you agreed to be applied to and charged on a specific Account. The negotiated Advisory Fee may be different than the Assessed Advisory Fee. • Select a sweep option as described in the and “Sweep Option and Expenses” section. Asset-Based Fee for Your Consolidated Advisory Fee Service Your financial advisor can reduce, increase, re-allocate or remove your AFPS Fee without requiring your signature, provided unless the total of the Advisory Fee and AFPS Fee increases and exceeds the higher of your Account’s current Assessed Advisory Fee or the applicable Negotiated Advisory Fee, as described in your Relationship Agreement. The portion of the annual Asset-based fee you pay for your consolidated advisory fee service (referred to as the “Advisory Fee”) is negotiated with your financial advisor and you and is deducted from the sweep option related to the Managed Account(s) that you select. For a consolidated advisory fee service, your Advisory Fee includes investment advisory services provided (i) to your Managed Account(s); and (ii) your AFPS, each as further described in this Combined Disclosure Brochure. The Asset-based Fee change will become effective at the start of the next billing period, following the period in which the request is received and accepted by Sponsor. For each instance of a fee change, we will send you a confirmation, regardless of whether your signature was required. Terminating Your Consolidated Advisory Fee Service You may terminate your entire consolidated advisory fee service at any time either by telephone or in writing. In addition, you may elect to terminate the AFPS component of the consolidated advisory fee service. The maximum total annual Advisory Fee you will pay for a consolidated advisory fee relationship is 2.0%. The Advisory Fee is based upon the level of assets in your associated Managed Account(s) and includes the AFPS Fee. When establishing a consolidated advisory fee service, you and your financial advisor will agree to the portion of the Advisory Fee that is allocated to AFPS. This allocation will be in five basis point increments. You may not pay general financial planning fees from your IRA or other qualified account; therefore, the entire Advisory Fee for consolidated advisory fee arrangements in IRA accounts must be paid from an If you do so, your Managed Account will remain active. If the Managed Account is terminated, the AFPS component of the services will be terminated as well. If the AFPS component is also attached to other Managed Accounts, AFPS will continue under those Accounts and your financial advisor may discuss Advisory Fee changes in those Accounts with you. Termination fees, as described elsewhere in this Combined Disclosure Brochure, will apply. 7 • Ameriprise ® Managed Accounts Services, Fees and Compensation Appropriateness of a Managed Account for you Advisory Solutions allow you to receive ongoing investment advice and feature an asset-based fee structure. The annual Asset-based Fee you pay for your Managed Account is a percentage of the total value of the assets in your Managed Account and as a result, the total amount you pay will increase if the asset value of your Managed Account increases, and vice versa. The Asset-based Fee is assessed monthly and deducted from your Managed Account in advance. This allows you to implement your investment strategy, generally without paying individual trading costs for each trade placed within the Managed Account. Many of the Programs under our Advisory Solutions feature professional portfolio management including asset allocation, risk management, investment selection, tax- harvesting and dynamic account rebalancing. Your financial advisor will provide you with Managed Account monitoring and ongoing advice to develop and maintain your Managed Account(s) investment portfolio, which will be designed to help you meet your financial goals and investment objectives. • Ameriprise Financial Services, LLC (“Ameriprise Financial Services”, “Sponsor,” or “we”) sponsors a wrap fee program (“Advisory Solutions”) offering a variety of investment advisory programs (each a “Program” and collectively the “Programs”). Each Program available within Advisory Solutions has different features and services, supporting a wide array of investment strategies. When you decide upon a Program, you may open an investment advisory account, (“Managed Account”). You will pay an ongoing asset-based fee (“Asset-based Fee"). The Asset-based Fee is a wrap fee. Prior to establishing an Ameriprise® Managed Account, you should carefully review this Wrap Fee Client Disclosure Brochure (“Disclosure Brochure”). If there is any conflict in the description of the investment advisory services or the details regarding fee information between the Ameriprise® Custom Advisory Relationship Agreement (“Relationship Agreement”) and this Disclosure Brochure, the Disclosure Brochure will control. Common terms used throughout this Disclosure Brochure are defined in the “Glossary” section. Ameriprise Financial Services offers the following Programs: Ameriprise brokerage accounts feature a commission-based fee structure where investors typically pay commissions, sales charges and/or other fees on products purchased and sold in your brokerage account. Brokerage accounts enable you to invest in many different types of investments including mutual funds, stocks, bonds, exchange- traded products, unit investment trusts, annuities and alternative investments. Your financial advisor may provide you with point-in-time recommendations related to your investment portfolio and may review your Ameriprise brokerage account; however, your brokerage relationship does not include account monitoring. The performance of your Managed Account(s) will not be monitored on a day-to-day basis. Past performance is no guarantee of future performance. In addition, forecasting of future performance of financial markets may prove to be incorrect. – Ameriprise® Strategic Portfolio Service (SPS) Advantage – Ameriprise® SPS Advisor – Ameriprise® Signature Wealth – Ameriprise® Active Portfolios® – Ameriprise® Select Separate Account – Ameriprise® Investor Unified Account – Ameriprise® Vista Separate Account – Ameriprise® Access Account Information to help you evaluate the benefits, risks, and costs of the investments and services we offer as part of a brokerage relationship, as well as information about material conflicts of interest associated with recommendations we or our financial advisors make to our retail brokerage clients may be found at https://www.ameriprise.com/bestinterest. More detail about the differences between Advisory Solutions and brokerage accounts may be viewed online by visiting www.ameriprise.com/disclosures and expanding the sub- heading “Managed Account Client Disclosure Brochures” and then clicking on “Evaluating differences between brokerage and managed accounts”. Ameriprise Financial Services also offers Ameriprise brokerage accounts. Selecting the account type(s) that best meet your needs is an important decision. There are circumstances where you may benefit from both a Managed Account and a brokerage account for different portions of your investment portfolio. When evaluating the differences between an Ameriprise brokerage account and an Advisory Solution, you should consider the following key differences: 8 for a Program and any Managed Account you open with us can be found in the Managed Account application and Relationship Agreement, the Ameriprise Brokerage Client Agreement, the Other Important Disclosures Document, Working in Your Best Interest – Regulation Best Interest Disclosure, and any other related disclosures and documents, all of which are available from your financial advisor. Please review all applicable information carefully before you make an investment decision and contact your financial advisor if you have any questions about the types of fees and expenses that may be associated with your Managed Account. The costs associated with a Managed Account that you should consider include: The Asset-based Fee that you pay for a Managed Account may be more or less than if you were to purchase the investment products and investment advisory services separately or in a transaction-fee based brokerage account paying commissions and sales-loads. Depending on your individual situation and the frequency and volume of trading, a Managed Account may cost more than a brokerage account, but the reverse could be true as well. Generally, Ameriprise Financial Services, our affiliates, and your financial advisor will receive more revenue from a Managed Account that generates an ongoing revenue stream than a transaction fee-based brokerage account. At the time of Managed Account opening and throughout your relationship we seek to address this conflict of interest through a combination of disclosure and through our policies, procedures and supervision related to the review and determination that a Managed Account is appropriate for you based on your financial and risk profile information and investment objectives (“Client Information”) in accordance with all applicable regulatory requirements. The same or similar services provided to you under the Asset-based Fee may be available to you at a lower fee from another service provider. • Asset-based Fee. This is the ongoing wrap fee you pay for (i) investment advisory services provided by Ameriprise Financial Services and your financial advisor; and (ii) investment management fees charged by the Advisory Service Provider providing advisory services to SMA strategies held in your Managed Account, if applicable. The components of the Asset-based Fee are separately itemized as an Advisory Fee, a Platform Fee and a Manager Fee as further described in the “Fees and Compensation” section. Based on the Program you select, the components of your Asset-based Fee will vary. • Before selecting a Managed Account, you should consider, among other things, the costs and expenses, your investment objectives, and the types of investments you hold and intend to purchase. Discuss with your financial advisor any accounts you may hold elsewhere. Investments and Infrastructure Support Fee and Credit for SPS Advisor Accounts. In addition to your Asset-based Fee, for SPS Advisor Accounts, Ameriprise Financial Services assesses a quarterly asset-based fee of 0.03% of the total advisory assets in your Managed Account. Our affiliate AEIS credits to clients all sub-transfer agency fees and networking fees AEIS receives for SPS Advisor Accounts from mutual fund firms, as further described in the “Fees and Compensation” section. This Investments and Infrastructure Support Credit may be more or less than the Investments and Infrastructure Support Fee. • The total cost to you of a Managed Account will include (1) the Asset-based Fee, a portion of which you negotiate with your financial advisor, and which includes any investment management fees charged by Advisory Service Providers for SMA strategies; (2) for SPS Advisor Accounts, the Investments and Infrastructure Support Fee; (3) Investment Costs; and (4) Additional Fees and Expenses which are any additional transaction related fees that may be incurred in connection with your Managed Account based on the nature of your investments. These costs are summarized below and are discussed in more detail and in the “Fees and Compensation” section. Investment Costs. These are the underlying fees related to investment products you purchase within your Managed Account. These may include investment management fees and distribution fees charged by mutual fund firms and other fees that are disclosed in the fund prospectus or other offering document. These costs are in addition to the Asset- based Fee that you pay directly from your Managed Account. They are paid indirectly by you, for example, as a shareholder in a mutual fund, through the product. They are not a direct fee deducted from your Managed Account. Investment Costs reduce the value of your investment in the product and reduce the investment performance of your Managed Account. Before opening a Managed Account or investing in any Program or investment product, it is your responsibility to understand and consider all fees, expenses and other charges. Specific information concerning the fees and other charges of each investment product in which your Managed Account invests is available in the product’s prospectus or other offering document. Additional fee information 9 the nature of your investments; for example, for Select Separate Account and Managed Accounts offered with Envestnet, if the Investment Manager for the investment strategy you select engages in “step- out trades” you will be assessed any Third Party Execution Fees for these trades as defined and described in the “Brokerage Practices” section; these fees will be in addition to the Asset-Based Fee that you pay to Ameriprise Financial Services and are not compensation to Ameriprise Financial Services or AEIS. In determining whether a Managed Account is appropriate for you at the time of opening the Managed Account and throughout your relationship with Ameriprise Financial Services, you should also consider: • Impact of the total costs of a Managed Account described above on the overall value and net performance of your Managed Account; • Investment Costs apply whether the investment product is sponsored or managed by an unaffiliated third party or by an affiliate of Ameriprise Financial Services, such as CMIA, a wholly owned subsidiary of Ameriprise Financial, Inc., Ameriprise Financial Services’ parent company. When you invest in investment products managed by CMIA, CMIA or its affiliates will receive compensation for managing those investments and for other services they provide based on the amount you invest, just as they would if you invested in CMIA investment products through another service provider. Investment Costs received by CMIA are not direct compensation to Ameriprise Financial Services, however, Ameriprise Financial Services, CMIA and their affiliates receive more revenue, in aggregate, from the purchase of affiliated investment products offered by CMIA than from the purchase of investment products offered by firms that are not affiliated with Ameriprise Financial, Inc. and therefore it is more profitable for Ameriprise Financial Services’ parent company when you purchase or own a CMIA investment product in your Managed Account. Total cost of purchasing and holding any underlying securities, products and services outside of a Managed Account or at another firm, including the anticipated amount of trading; • That you will typically not recover any front-end loads previously paid on mutual funds that are transferred into a Managed Account and you may be possibly subject to contingent-deferred sales charges on mutual funds that charge such a fee if sold or exchanged after they are transferred into a Managed Account. The cost basis on any mutual fund with front-end loads will carry over to any mutual fund positions converted in a tax-free exchange and will be included in the tax calculation of gains and losses for those converted positions held in non-qualified Managed Accounts; • A Managed Account may not be appropriate for you if you prefer a long-term buy-and-hold investment strategy or otherwise purchase mutual funds and other securities infrequently. • Your preferences to be involved in individual investment decisions and your comfort with granting discretion to your financial advisor or other investment managers for investment decisions. • Custodial services provided. • Amount of Assets in your Managed Account. • Third Party Payments. A portion of Investment Costs that you pay indirectly to third parties are subsequently received by our affiliated clearing agent, American Enterprise Investment Services Inc. (“AEIS”), from those third parties as certain cost reimbursement payments and other servicing and account maintenance fees (e.g., sub-transfer agent or networking fees) related to your Managed Account. AEIS also receives marketing support and distribution support payments. For qualified SPS Advisor Accounts, inherited IRAs in qualified SPS Advantage Accounts where a trust has inherited the IRA and Ameriprise Bank acts as trustee of the trust and eligible trustee-directed retirement plans in Select Separate Accounts AEIS either does not collect Third Party Payments or credits them back to client Accounts as described in the “Fees and Compensation” section. Third Party Payments and cost reimbursement services and payments are further described in the “Mutual Fund Share Classes in Managed Accounts”, “Fees and Compensation”, and “Cost Reimbursement Services and Third- Party Payments” sections. These payments are generally funded directly, or indirectly, from Investment Costs. • Your ability to independently select and retain professional asset management services. • You should consider this total compensation • Terms and conditions of the Relationship Agreement. • received by Ameriprise Financial Services and AEIS when evaluating the reasonableness of our fees. The type of investment products (including mutual fund share classes) that are available for purchase in each Advisory Solutions Program. • Additional Fees and Expenses are any additional transaction related fees that may be incurred in connection with your Managed Account based on • How much of your assets you expect to be allocated to cash. Because cash is included in the Asset- 10 (v) for settling transactions in your Managed Account. Available money settlement options include either a free credit balance held in your Managed Account covered by SIPC, or a program that provides for the automatic movement or “sweep” of uninvested cash balances in your Managed Account into the money settlement program (each, a “Sweep Program”). A Sweep Program is not an investment strategy and is not intended as an investment option for you to maintain a significant cash balance for an extended period of time. As noted above, Ameriprise Financial Services offers investment products that offer capital preservation that generally have a higher rate of return for the cash component of your asset allocation than a Sweep Program. The terms of our cash sweep programs can be found in the “Other Important Brokerage Disclosures” document you received when you set up your Managed Account or Relationship, as applicable. For a copy of this document, visit our website at ameriprise.com/disclosures or call our service line at 800.862.7919. • In addition, it is important that you review any applicable mutual fund or ETF prospectus and/or other product offering documents prior to investing to learn about fund expenses, investment minimums, availability of sales charge breakpoints or rights of accumulation and other benefits and costs when purchased outside of a Managed Account. You should consider whether you will be eligible for the sales charge breakpoints, rights of accumulation and other benefits before purchasing or transferring mutual funds into a Managed Account. Overview of Ameriprise® Managed Accounts based Fee for your Managed Account, it will cost you more and Ameriprise Financial Services and our financial advisors will receive more revenue when you hold cash in a Managed Account rather than an Ameriprise brokerage account. It is not recommended to hold large amounts of cash and/or positional money market funds in a Managed Account for extended periods of time. Prior to establishing a Managed Account or as you consider remaining in a Managed Account, and particularly for the SPS Advantage and SPS Advisor Programs, consider whether you have a short-term investment horizon, or whether you are holding cash for asset safety purposes (such as during periods of volatile or uncertain market conditions). In those cases, you should consider and discuss with your financial advisor other investment products within an Ameriprise brokerage account or other commission-based account that may offer capital preservation with a higher rate of return for the cash component of your asset allocation. These investment products include Ameriprise Certificates, brokered certificates of deposit, treasuries and positional money market mutual funds and are a more appropriate choice for investing cash than maintaining a significant cash balance in your Managed Account for an extended period. Not all of these investment products are available or appropriate to hold in large amounts within Managed Accounts. Your financial advisor can provide you with information about the cash management products available to you, including whether it may be appropriate to allocate assets between your Managed Account and an Ameriprise brokerage account. We offer tools on our client website that permit you to transfer cash between your Managed Account and certain other brokerage accounts you maintain at Ameriprise. This may help you avoid the ongoing Asset-based Fee. All Programs, except SPS Advantage, are discretionary investment advisory Programs. Advisory Service Providers with investment selection discretion and SPS Discretionary Advisors (“Discretionary Managers”) have discretionary authority granted by you to (i) select investments for your Managed Account; and (ii) purchase or sell securities or make other investments for your Managed Account without your prior authorization. • You should also review the available money settlement option available to you in your Managed Account. A money settlement option is a feature offered by Ameriprise Financial Services that is primarily intended to hold cash (i) pending investment into your Managed Account; (ii) to cover your Asset-based Fee and if applicable, SPS Advisor Investments and Infrastructure Support Fee; (iii) to cover systematic cash withdrawals you have established for your Managed Account(s); (iv) for certain pre-existing non- qualified SPS Advantage Accounts check writing or debit card activity and to make bill payments (cash management activities); and For the SPS Advisor Program, you authorize one or more financial advisors to exercise discretion regarding the investment selection and asset allocation strategy in your SPS Advisor Account as an SPS Discretionary Advisor. For all other discretionary Programs, specifically Signature Wealth, Active Portfolios® investments, Select Separate Account, Vista Separate Account, Investor Unified Account and Access Account Programs (the “Manager Directed Programs”) use the discretionary investment advisory services of Advisory Service Providers, as described below, which may or may not be 11 Client Rights and Responsibilities affiliated with Ameriprise Financial Services depending upon the Program offered and selected. • • You may impose reasonable security and mutual fund restrictions on any discretionary Managed Account(s) and reasonable sector restrictions (“Reasonable Restrictions”) on Manager Directed Managed Account(s) that you select by completing and signing the appropriate documents and when accepted by Ameriprise Financial Services, your financial advisor or the Investment Manager as described in each Program description within this Disclosure Brochure. • You may not impose restrictions which apply to underlying securities held in any mutual fund, exchange traded fund (“ETF”), closed end fund (“CEF”), unit investment trust (“UIT”) or other pooled investment products. • You are responsible for promptly notifying Ameriprise Financial Services in writing of any changes to these Reasonable Restrictions. Ameriprise Financial Services will determine whether a Managed Account is appropriate for you at the time you seek to open a Managed Account based on information you provide then and thereafter as described in this Disclosure Brochure. Ameriprise Financial Services also reserves the right to limit or close any Managed Account that is used for excessive securities trading. At both Account opening and on an ongoing basis, Ameriprise Financial Services conducts additional monitoring and supervision regarding the appropriateness of a Managed Account for you, including the internal transfer of securities from an existing Ameriprise brokerage account into the Account and the transfer of securities from an external account into the Account. • • You are responsible for providing Ameriprise Financial Services with accurate Client Information when you establish a Custom Advisory Relationship (as described below) and open any Managed Account. Your financial advisor will conduct an annual review of Account appropriateness and document at least annually whether each Managed Account continues to be appropriate. • • Periodically, you will be notified in writing to contact Ameriprise Financial Services if there have been any changes in your Client Information and/or Reasonable Restrictions. It is your responsibility to promptly notify Ameriprise Financial Services, in writing or by contacting your financial advisor, of any changes. Failure to do so could affect the services provided to you. If at any time we determine that your Managed Account or a position(s) within your Managed Account is no longer appropriate for you, your Managed Account may be closed and/or transferred into an Ameriprise brokerage account with thirty (30) days prior notice. See the “Terminating a Managed Account Client Agreement” section for more detail and for information regarding your right to terminate your Managed Account(s). • • Review this Disclosure Brochure and, if applicable, the Advisory Service Provider’s, as defined below, disclosure document (Part 2A of Form ADV) and the investment strategy/portfolio fact sheets prior to investing. • Review available information about the trading practices of the Investment Manager including the average cost of step-out trades for the investment strategy as defined and discussed in the “Brokerage Practices” section. • In SPS Advantage Accounts, review any applicable mutual fund or ETF prospectus, as well as any other offering or disclosure document prior to investing. Overview of Services and Fees You will pay Asset-based Fees and certain other fees and incur expenses and costs when you select a Service, as summarized above. These fees, expenses and costs are further detailed and described in the Managed Accounts charts later in this section and in the “Fees and Compensation” and the “Brokerage Practices” sections. Ameriprise Financial Services and its affiliates receive revenue as described in the “How We Get Paid” section. Your Ameriprise financial advisor receives compensation for investment advisory services provided to you. Importantly, the compensation we pay your financial advisor does not vary depending upon the investment(s) recommended to you within a Managed Account. The sources of financial advisor compensation are described in the “Financial Advisors Compensation & Benefits” section. Ameriprise Financial Services is a registered investment adviser under the Investment Advisers Act of 1940 (the “Advisers Act”) and a broker-dealer under the Securities Exchange Act of 1934 (“Exchange Act”). Investment advisory services are provided by Ameriprise Financial Services as an investment adviser and brokerage 12 • services are provided by Ameriprise Financial Services as an introducing broker. Ameriprise Financial Services and/or its affiliates provide the following services: For Managed Accounts invested in Signature Wealth, providing portfolio construction recommendations using a portfolio proposal that is designed to assist with aligning the recommended portfolio to your Client Information. • • Acting as wrap program sponsor and introducing broker-dealer for the Programs described in this Disclosure Brochure; Potentially serving as a liaison between you and any Advisory Service Provider via Ameriprise Financial Services; • • Providing brokerage services through our affiliate, American Enterprise Investment Services Inc. (“AEIS”), in connection with your Managed Account(s), as described in the Relationship Agreement and the Ameriprise brokerage agreement, Other Important Brokerage and Schedule of Account & Service Fees Documents (collectively referred to as the “Brokerage Agreement”); • Training to and supervision of the Ameriprise financial advisor authorized to use discretion in SPS Advisor (“SPS Discretionary Advisor”); Annually, reviewing your Client Information, investment objectives and any applicable Reasonable Restrictions with you to determine if, based on information you provided, they are still accurate, reviewing with you whether your Managed Account(s) and the investment strategy are still suitable for you, and reviewing with you whether the Asset-based Fee is still appropriate based on the services provided. In the event an Account has more than one owner, this review may occur with one or more of the owners. If applicable, your Attorney-in-Fact may also participate in this review. • Research and/or due diligence regarding the • Periodically reviewing and assessing your Managed Account(s) to answer any questions that you may have. Advisory Service Providers (as defined below) you select to provide discretionary investment advisory services in Manager Directed Programs; • Where requested and as part of your services, • Due diligence of investment products or investment strategies available through the Programs including initial and ongoing analysis based on a quantitative and qualitative process through Ameriprise Financial Services or its affiliates; • The execution of brokerage transactions on an agency or, in limited circumstances, principal basis through Ameriprise Financial Services’ clearing agent, AEIS; • Custodial services; custody of the securities and other assets you hold within a Managed Account and consolidated account reporting regarding those assets; • Regular reports to clients; and • Year-end tax information reporting. Your financial advisor performs certain services on behalf of Ameriprise Financial Services in connection with your Managed Account. A financial advisor will be assigned to each Managed Account and will provide services including: • Assisting you by defining the parameters that will form the basis for the management of your Managed Account(s), including your Client Information; • For Managed Accounts invested in SPS Advantage and SPS Advisor, providing advice in consideration of an asset allocation strategy for the Account; providing guidance relating to both your Managed Account and your additional retirement plan assets not included in the Managed Account and that are held outside of Ameriprise Financial Services in a participant-directed defined contribution plan (e.g., 401(k) plans) (“Outside Workplace Retirement Plan”). Any guidance provided to you is based on information provided by you about your Outside Workplace Retirement Plan and is limited to investments offered through the core line up of funds established by your retirement plan sponsor. Your Outside Workplace Retirement Plan may include investment options not available in our Programs or for which your financial advisor may not have access to detailed information. Neither Ameriprise Financial Services nor your financial advisor is responsible for the selection of the available investment options in your Outside Workplace Retirement Plan. Your financial advisor may not make recommendations related to employer stock that may be available within your Outside Workplace Retirement Plan or with respect to any current portfolio holdings or investment options available through a self- directed brokerage account associated with your Outside Workplace Retirement Plan. You are responsible for placing any transactions recommended by your financial advisor. If you desire ongoing guidance on your Outside Workplace Retirement Plan, it is important that you provide your financial advisor with updated information, including statements and a list 13 they are not always the least expensive share class made available by the mutual fund. of funds available in your Outside Workplace Retirement Plan, on a regular basis. Your investment objectives and risk tolerance for your Outside Workplace Retirement Plan may differ from those of your Managed Account, however any guidance provided for your Outside Workplace Retirement Plan is provided in consideration of the overall investment objectives and risk tolerance of any Managed Accounts you hold. Your financial advisor is instructed to inform Ameriprise Financial Services if your personal and/or financial information have changed. Mutual Fund Share Classes in Managed Accounts Many mutual funds offer institutional shares or other types of shares for a mutual fund that are less expensive than the Advisory Share or other share class we offer for that particular fund in our Advisory Solutions Programs. All share classes of a particular mutual fund represent the same underlying investments, and you may be eligible to purchase a less expensive share class of that mutual fund outside of Ameriprise Financial Services. Because Ameriprise Financial Services chooses to offer only one share class per mutual fund in our Managed Accounts Programs, we limit the availability of other share classes of those mutual funds that you may otherwise be eligible to purchase at a lower cost. For SPS Advantage and SPS Advisor Accounts, you can hold, but not purchase, share classes that are less expensive than the Advisory or other share class we offer for purchase in a particular mutual fund (each, an “Eligible to Hold Share Class”). You may choose to reinvest, or receive in cash, fund dividends and capital gains distributions in such funds if available. An Eligible to Hold Share Class is assessed the Asset-based Fee while held in your Managed Account. Upon transfer into your Managed Account, you can (i) transfer the Eligible to Hold Share Class to an Ameriprise brokerage account; (ii) liquidate the Eligible to Hold Share Class and purchase an Eligible Investment; or (iii) continue to hold the Eligible to Hold Share Class in your Managed Account. When determining which share class to offer as the only share class available for purchases in a particular mutual fund, if a mutual fund offers multiple share classes that do not have a sales-load and do not charge a 12b-1 fee, Ameriprise Financial Services will choose to utilize the share class that permits, pursuant to the fund’s prospectus, the payment of Third Party Payments such as cost reimbursement and other servicing and account maintenance fees, even though certain clients may hold an Eligible to Hold Share Class in a Managed Account or our clients in general are currently eligible for a less expensive share class or may become eligible in the future, including when a mutual fund introduces a lower- cost share class into an existing mutual fund. None of the mutual funds currently offered in Ameriprise Managed Accounts Programs impose a front-end sales charge. For most mutual funds, a share class that does not have a sales-load and does not assess 12b-1 fees (collectively “Advisory Shares”) is offered in all Programs within Advisory Solutions as the only mutual fund share class available for purchase, where available to us through a selling agreement. If not available to us through a selling agreement or if the mutual fund does not offer an Advisory Share class, we offer Class A shares that may pay a 12b-1 fee or a no-load share class that does not have a sales-load but that may pay a 12b-1 fee. 12b-1 fees are paid by a mutual fund out of fund assets to cover distribution expenses and sometimes shareholder service expenses. The share class offered for purchase by Ameriprise Financial Services for a particular mutual fund is the only share class we allow for additional purchase within your Managed Account. As discussed below, any 12b-1 fees received by Ameriprise Financial Services will be promptly rebated to your Managed Account. The share class offered for purchase by Ameriprise Financial Services for each applicable fund is listed in our Mutual Fund Screener Tool. Access the tool by logging into your Ameriprise Secure Site account and navigating to “Trade & Research” and then, “Screeners” followed by “Mutual Fund”. From there, apply the Product Type filter and choose either SPS Advantage or SPS Advisor to view the funds and share classes available for purchase. Specifically, we prefer to offer a share class that makes Third Party Payments that will (i) reimburse our affiliate AEIS for certain services it provides for the benefit of clients such as record keeping, administration, shareholder servicing, and client telephonic and other servicing; and (ii) help increase profitability for the firm. As a result, in almost all instances our affiliate earns higher revenues from the share class available to purchase in Advisory Solution Programs than from Eligible to Hold Share Class positions. Ameriprise Financial Services seeks to make available to client’s mutual funds, and share classes of those mutual funds, that Ameriprise Financial Services believes are suitable for investment. We take mutual fund expenses into account in determining which mutual funds to offer in our Programs, as further discussed in the “Investment Product Due Diligence Services” paragraphs of this section. Advisory Shares are less expensive than share classes that charge investors a 12b-1 fee or assess a sales charge, but 14 marketplace for a given mutual fund, please refer to the mutual fund’s prospectus or statement of additional information. Please review the mutual fund prospectus and contact your financial advisor for information about any limitations on share classes available for purchase through a Managed Account. For more information on fund families and mutual funds offered in our Advisory Solution Programs, including the applicable Advisory Share class or other share class utilized, please refer to our Mutual Fund Screener Tool available by logging into your Ameriprise Secure Site account and selecting Trade & Research and then Screeners and select the “Availability” tab. Please refer to the mutual fund’s prospectus(es) or website to determine whether your investment would qualify for an institutional or other share class outside a managed account service, with corresponding lower expenses and fees. Class A share and Class C share positions, as well as other share classes that pay a 12b-1 fee and that do not match the Advisory Share class or other share class offered by Ameriprise Financial Services for a particular mutual fund (“Non-Matching Shares”) are processed as follows: Our determination of which share class to offer as the only share class available for purchase in a particular mutual fund presents a conflict of interest for Ameriprise Financial Services due to a financial incentive to place you in the higher-cost share class that pays AEIS for cost reimbursement services as described in the “Cost Reimbursement Services and Third Party Payments” section. Ameriprise Financial Services addresses this conflict of interest through a combination of disclosure and policies, procedures and related controls designed to ensure that the fees we charge to clients are fair and reasonable. We also permit clients to hold Eligible to Hold Share Class positions at a lower cost to you and, in almost all instances, we do not receive Third Party Payments for such positions. Another way we address this conflict is by not sharing Third Party Payments with your financial advisor in connection with the investment products recommended for your Managed Account, which eliminates any personal financial incentive for your financial advisor to make recommendations based on whether Third Party Payments are received. Your financial advisor may receive compensation based on the profitability of the firm, as further described in the “Financial Advisor Compensation and Benefits” section. Before selecting a Managed Account Program, you should consider, among other things, that the total compensation received by Ameriprise Financial Services and our affiliate in the aggregate includes Third Party Payments received for cost reimbursement services as discussed in the “Appropriateness of a Managed Account for you” section. • Where Non-Matching Share classes that pay a 12b- 1 fee are held in or transferred into your Managed Account, we will convert such shares to an Advisory Share class where one is available to us through a selling agreement provided the mutual fund company allows the conversion to be processed on a tax-free exchange basis for non-qualified account holdings. We will not assess transaction fees or other charges in connection with conversions to Advisory Shares. For Manager Directed Programs the conversion to the Advisory Share class of the same mutual fund may occur on a non-exchange basis. Such transactions generally result in tax consequences in non- qualified Accounts. You authorize Ameriprise Financial Services to convert applicable Non-Matching Shares to an Advisory Share class of the same mutual fund by establishing a new Relationship or by continuing to accept the services in the Program after we notify you of an upcoming conversion. Our decision to offer a particular share class that may not be the least expensive share class and a financial advisor’s recommendation that you participate in a Program will cause you to pay higher internal expenses for certain mutual funds than you would otherwise pay (i) if participating in another provider’s managed account service which uses a lower-cost share class; (ii) if holding a lower-cost share class as an Eligible to Hold Share Class; or (iii) by buying the mutual funds directly from the distributor outside of a managed account service, if possible. This difference in internal expenses between share classes of a particular mutual fund will also affect the investment performance of your Managed Account by reducing returns over time. Your participation in a Program that does not offer or allow additional purchases of the least expensive share class may still be an appropriate choice depending on the facts and circumstances of your individual situation and in light of the features and benefits of the particular Program. For a listing of all share classes that may be available in the • Non-Matching Share classes that pay a 12b-1 fee in SPS Advantage Accounts and SPS Advisor Accounts will not be converted to the corresponding Advisory Share if Ameriprise Financial Services is not able to complete the exchange (e.g., the mutual fund company does not allow it or a corresponding Advisory Share class is not offered), the exchange cannot be processed on a tax-free basis, or if Ameriprise Financial Services determines they are subject to a short- term redemption fee or deferred sales charge. Instead, to the extent 15 identified by Ameriprise Financial Services, those Non-Matching Shares will generally be transferred to an Ameriprise brokerage account in accordance with the Relationship Agreement. Similarly, Class C share positions that Ameriprise Financial Services is unable to convert to Advisory Shares for any reason will be transferred to an Ameriprise brokerage account. Any such positions pending transfer to an Ameriprise brokerage account will be subject to the Asset-based Fee. • the entire 12b-1 fee rebate will be considered miscellaneous income if the originating Account is a non- qualified Account. Account holders receiving aggregate miscellaneous income of $600 or more annually will receive an IRS Form 1099-MISC, Miscellaneous Information, from AEIS. Account holders receiving miscellaneous income amounts under $600 annually generally will not receive an IRS Form 1099-MISC from AEIS but will be responsible for reporting the income to the IRS. Holders of IRAs and qualified retirement plan Accounts will not experience a taxable event as a result of a rebate and will instead be taxed only on amounts when they are distributed from the Account. SPS Advantage and SPS Advisor Accounts are more likely to hold Class A shares or no-load share class mutual fund positions. Investment Product Due Diligence Services and Investment Availability for Purchases. Prior to initially offering any mutual fund, ETF, exchange traded note (“ETN”), CEF or UIT in the Programs and on at least an annual basis thereafter the Ameriprise Investment Research Group (“IRG”) manager research and due diligence team conducts research and quantitative analysis, and may also conduct qualitative analysis, of investment products. For the Signature Wealth Program, Ameriprise Financial Services further defines the mutual funds and ETFs available for use in the Program. As with full Account transfers to an Ameriprise brokerage account, if you do not have an Ameriprise brokerage account with the same account registration, beneficiaries and other account level attributes as your Managed Account, a new brokerage account will be opened for you with the same attributes. The Brokerage Agreement will govern your Ameriprise brokerage account relationship including fees charged in connection with maintaining a brokerage account, transaction fees and applicable terms and conditions such as mandatory pre-dispute arbitration. Advisory Shares and certain other share classes used as the only share class available for a particular mutual fund are not available for purchase in an Ameriprise brokerage account. Such share classes can be held in an Ameriprise brokerage account subject to any restrictions or conversion requests received from the mutual fund company. 12b-1 Fee Rebates This process, depending on the type of investment, may include evaluation of the historical performance or tracking difference, amount of assets with Ameriprise Financial Services, expenses, premium, offering documents, financial statements, portfolio holdings and other information requested from the product manufacturer. Investments Available for Purchase. Advisory Shares typically do not pay 12b-1 fees. As described above, where Ameriprise Financial Services does not offer an Advisory Share class for a particular mutual fund, we offer either a Class A share or a no- load share class that may pay a 12b-1 fee. To the extent that Ameriprise receives 12b-1 fees for share classes held in any Managed Accounts, they will be rebated to clients. Rebates are generally deposited into the applicable client Accounts within a week after we receive the 12b-1 fees. Investment products (i) that meet Ameriprise Financial Services’ due diligence standards; and (ii) for which we have a selling or distribution agreement in place are offered and are available for purchase in SPS Advantage Accounts, SPS Advisor Accounts, Signature Wealth Accounts, Vista Separate Accounts and Investor Unified Accounts (“Eligible Investments”). In circumstances where the aggregate value of these rebates exceeds the Asset-based Fees paid from your non-qualified account, the excess will be considered miscellaneous income for tax reporting purposes. For Accounts with alternative fee billing arrangements, Signature Wealth Accounts may only hold Eligible Investments. Eligible to Hold Share Classes, Eligible to Hold Investments and Ineligible Investments are not permitted. 16 Investments Eligible to Hold but Not Purchase. The types of investments that can be held, but not purchased, in SPS Advantage and SPS Advisor Accounts are summarized in the chart below and further described below and in the “Mutual Fund Share Classes in Managed Accounts” paragraphs of this section. Type of Investment SPS Advantage and SPS Advisor Account Activity Ameriprise Financial Institutions Group (“AFIG”) financial advisors may transfer Eligible to Hold Investments and Ineligible Investments from an Ameriprise brokerage account into your Managed Account at account opening and for initial transition purposes only. After the initial transition is complete such assets may no longer be transferred from an Ameriprise brokerage account to a Managed Account. Any Ineligible Investments that are either transferred into your Managed Account from non- Ameriprise accounts or reclassified as an Ineligible Investment may be either sold or transferred to an Ameriprise brokerage account, however if no action is taken with respect to Ineligible Investments held in your Managed Accounts by 180 days after transfer, or 180 days after the position was reclassified, as applicable, the position(s) will be automatically transferred into an Ameriprise brokerage account in accordance with the Relationship Agreement. This process may be delayed for certain position(s) where Ameriprise Financial Services requires coordination with the applicable mutual fund firm for the orderly processing of the transfer to an Ameriprise brokerage account. While not available for purchase, you may only transfer in from an external account and hold these investments. Positions will be billable while held in eligible Programs. While not available for purchase, you may only transfer in from an external account and hold these investments. Positions will be billable while held in eligible Programs. Occasionally, Ineligible Investments may be reclassified as Eligible to Hold Investments, for example when an investment product meets our due diligence standards but is otherwise unavailable for purchase in Advisory Solution Programs. In this case, you will be permitted to continue to hold such investments in eligible Programs. Eligible to Hold Share Class Share class that is less expensive than the advisory or other share class offered for purchase in a given mutual fund in our Programs. Eligible to Hold Investments Investment products for which our due diligence standards are met but either: (i) we do not have a selling or distribution agreement in place; or (ii) the investment is not otherwise available for purchase in Managed Accounts. While not available for purchase, you may only transfer in from an external account and hold these investments for up to 180 days. Positions will be billable while held in eligible Programs. Ineligible Investments Investment products (i) that do not meet our due diligence standards; (ii) where due diligence has not been completed; or (iii) that are not otherwise eligible to be held more than 180 days in Managed Accounts. Your financial advisor may recommend that you sell, or may sell in an SPS Advisor Account, any Ineligible Investments within your Managed Account to purchase Eligible Investments. Such transactions generally result in tax consequences in non-qualified Accounts. While such recommendation or sale and subsequent purchase in an SPS Advisor Account must be suitable and appropriate for your Managed Account, your financial advisor will generally receive more revenue from a Managed Account that generates ongoing revenue streams than in an Ameriprise brokerage account. Therefore, your financial advisor has a financial incentive to reposition any Ineligible Investments within your Managed Account into positions that are available for purchase. Ameriprise Financial Services seeks to address the conflict of interest through its policies, procedures and supervision of the suitability of recommendations related to your Managed Account based on your Client Information and in accordance with all applicable regulatory requirements. You may hold these types of investments as described above; however, your Managed Account will be subject to our ongoing determination that the Account is appropriate for you, including our belief that an SPS Advantage Account is appropriate if you primarily seek and act on the asset allocation and investment advice of your financial advisor. Investments Not Eligible to Hold or Purchase Non-advisory assets are not allowed to be purchased or held beyond initial transitional and administrative processing upon transfer from an external account You may not transfer Eligible to Hold Share Classes, Eligible to Hold Investments, or Ineligible Investments from an Ameriprise brokerage account into your Managed Account. In certain instances, clients of 17 to either a SPS Advantage or SPS Advisor Account. These positions are not billable during processing. Managed Accounts Program Oversight Committee and Due Diligence Services. The Managed Accounts Program Oversight Committee (“Oversight Committee”) of Ameriprise Financial Services is responsible for the oversight of such Advisory Service Providers. The Oversight Committee provides oversight of the advisory services provided to the applicable Program(s) such as investment strategies, model portfolios and asset allocation models, as applicable. The Oversight Committee, acting on behalf of Ameriprise Financial Services, is the Investment Manager of Select ETF Portfolios, a variety of portfolios that invest in non- proprietary ETF investments in partnership with Portfolio Strategists or Asset Allocation Strategists. Non-advisory assets include investments such as non-traded exchange funds, 1031 exchange offerings, Class C, Class B or any other mutual fund share class with a contingent deferred sales charge, leveraged and inverse ETFs and mutual funds, and other illiquid securities. Any non-advisory assets that are (i) transferred into your SPS Advantage Account or SPS Advisor Account, or (ii) that are subsequently reclassified such that they are no longer allowed to be held in your Managed Account will be promptly transferred into an Ameriprise brokerage account in accordance with the Relationship Agreement. Each of the Portfolio Strategists and Asset Allocation Strategists for Select ETF Portfolios, as applicable, develops asset allocation models, conducts qualitative and/or quantitative research on mutual funds and ETFs, and constructs model portfolio or asset allocation recommendations, as applicable. The Oversight Committee reviews and approves these recommendations as part of its ongoing oversight. The Oversight Committee may remove a Portfolio Strategist or an Asset Allocation Strategist from the Select ETF Portfolios Service and/or adjust an asset allocation or model portfolio as appropriate. In addition, trustee-directed retirement plans are not allowed to hold affiliated mutual funds and investment products advised or sub-advised by CMIA or their affiliates in qualified SPS Advantage Accounts and eligible qualified Select Separate Accounts. Similarly, these affiliated mutual funds and investment products are not allowed to be held in qualified SPS Advisor Accounts and Tax-Sheltered Custodial Accounts (“TSCAs”) invested in SPS Advisor and will be promptly transferred into an Ameriprise brokerage account in accordance with the Relationship Agreement. The IRG conducts initial and ongoing research and due diligence on Advisory Service Providers, their applicable investment strategies and the investment advisory services available or utilized in the Programs and provides recommendations to the Oversight Committee on matters including the addition or termination of an Advisory Service Provider, benchmark allocations, and security trading. The Oversight Committee determines which Advisory Service Providers are available within Programs. For all transfers of non-advisory assets or affiliated mutual funds and investment products, as with full Account transfers to an Ameriprise brokerage account, if you do not have an Ameriprise brokerage account with the same account registration, beneficiaries and other account level attributes as your Managed Account, a new brokerage account will be opened for you with the same attributes. Solely the Brokerage Agreement will govern your Ameriprise brokerage account relationship including fees charged in connection with maintaining a brokerage account, transaction fees and applicable terms and conditions such as mandatory pre-dispute arbitration. The IRG also conducts due diligence and provides ETF recommendations to the Oversight Committee for all Select ETF Portfolios investments where an Asset Allocation Strategist provides solely asset allocation services. Advisory Service Providers More detail on how Ameriprise Financial Services selects and reviews Advisory Service Providers for each Program are described in the “Advisory Solution Programs and services” sub-sections for Signature Wealth, Active Portfolios®, Select Separate Account and Managed Accounts Offered with Envestnet Asset Management, Inc. Types of Advisory Service Providers. The types of Advisory Service Providers that may provide services to your Managed Account include: Ameriprise Financial Services uses the services of affiliated and third party investment advisory firms (collectively, “Advisory Service Providers”) to provide discretionary and non-discretionary investment advisory services that include investment management, asset allocation and/or rebalancing, or providing investment models, as applicable, for the following Manager Directed Programs: Signature Wealth, Active Portfolios®, Select Separate Account, Vista Separate Account, Investor Unified Account and Access Account. 18 • more information about its investment advisory business. Due Diligence of Signature Wealth Investment Manager. Investment Managers. Investment Managers are Discretionary Managers with discretionary authority to purchase or sell securities or make other investments for your Managed Account. Such transactions generally result in tax consequences in non-qualified accounts. Investment Managers include (i) the Oversight Committee acting on behalf of Ameriprise Financial Services, and (ii) affiliated and non- affiliated third-party investment advisers. The Oversight Committee is the Investment Manager of Select ETF Portfolios. • Signature Wealth Investment Manager. Ameriprise Financial Services selected a non- affiliated third-party registered investment adviser as the discretionary Investment Manager for the Signature Wealth and Active Portfolios® Programs (“Signature Wealth Investment Manager”). The Signature Wealth Investment Manager: The IRG conducts an annual review of the Signature Wealth Investment Manager. This review is based on applicable information gathered from various sources, including information from the Signature Wealth Investment Manager, disclosure documents, historical performance and assets under management. As a result of these reviews, Ameriprise Financial Services may identify actual or potential concerns regarding the Signature Wealth Investment Manager and may request them to take corrective action to address such concerns. This review may result in the removal of the Signature Wealth Investment Manager. If the Signature Wealth Investment Manager is removed, you and your financial advisor will receive notice and direction on what actions you will need to take. If no action is taken, your Managed Account will be closed and moved in-kind to an Ameriprise brokerage account. • Investment Providers. o Receives asset allocation and investment selection recommendations from the Signature Wealth Model Providers. o Has with discretionary authority to purchase or sell securities or make other investments for your Account without your prior approval, except for mutual funds and ETFs you work with your financial advisor to select for your client directed model. o For the portion of your Account that is not Investment Providers for the Signature Wealth and Active Portfolios® Programs construct the recommended holdings in each model investment portfolio according to their specific investment strategy and may include their proprietary mutual funds and/or ETFs in the model investment portfolios. Each Investment Providers’ disclosure documents (Part 2A of Form ADV) are available to you at ameriprise.com/investmentproviders. invested in model investment portfolios and consists of individual mutual funds/ETFs that are recommended by your financial advisor (the “client directed model”) has trading authority only and is responsible for the ongoing trading and rebalancing of your client directed model. o Provides administrative and/or trading instruction to AEIS as the clearing / custody broker-dealer. o Provides rebalancing services to maintain to your Account’s asset allocation. Our affiliate, CMIA, participates in the Signature Wealth and Active Portfolios® Programs as an Investment Provider. The Investment Providers make non- discretionary investment and asset allocation recommendations to the Signature Wealth Investment Manager. For Signature Wealth Accounts with a client directed model, you will select the investments according to your personal portfolio, and the discretionary Signature Wealth Investment Manager will invest that portion of your overall Managed Account according to your direction and will be responsible for the ongoing trading and rebalancing of your Signature Wealth Managed Account, subject to any Reasonable Restrictions or other instructions provided by you. o Selects replacement mutual funds and ETFs for your client directed model in instances where the investment is no longer eligible for use in the Signature Wealth Program, as applicable. o Acts on any Reasonable Restrictions that you may impose on the management of your Account(s). The Signature Wealth Investment Manager exercises investment discretion for the Signature Wealth and Active Portfolios® Managed Accounts. Investment Providers do not have any investment discretion or trading authority to purchase or sell securities in your Managed Account. Different Investment Providers may arrive at different investment and asset allocation recommendations regarding Review the Signature Wealth Investment Manager’s Form ADV, Part 2A Appendix 1, for 19 investments in a certain sector, market capitalization, or other category of investments, depending on the model portfolio’s investment objective. Oversight of the Investment Provider and the model investment portfolio’s investment strategy is provided by the Oversight Committee, as described above. offer a wide variety of SMAs and asset allocation strategies (each, an “Envestnet Strategy”) with a wide range of investment objectives and risk tolerances. Envestnet Strategies are available in the Vista Separate Account, Investor Unified Account and Access Account Programs. Review Envestnet’s Form ADV, Part 2A Appendix 1 for more information about its investment advisory business. o Envestnet Advisory Services Include: • Portfolio Strategists. Portfolio Strategists provide asset allocation and investment recommendations to the Oversight Committee as Investment Manager. Portfolio Strategists do not have discretionary authority or control to purchase or sell securities or make other investments for individual investors. – Providing access to a variety of SMA Investment Managers (“Envestnet Managers”). Certain Envestnet Managers have entered into a sub- management agreement with Envestnet to provide discretionary Investment Manager account management services. Envestnet is the discretionary Investment Manager where the Envestnet Manager has entered into a Model Provider sub-management agreement. • Asset Allocation Strategists. Asset Allocation Strategists solely provide asset allocation recommendations to the Oversight Committee as Investment Manager. The Asset Allocation Strategists do not have discretionary authority or control to recommend, purchase or sell securities or make other investments for individual investors. – Providing administrative and/or trading services as directed by Envestnet and/or the Envestnet Manager. – Facilitating the asset allocation • Select Separate Account Model Providers. Model Providers construct a model portfolio according to their specific investment strategy and, in that capacity, make investment selection decisions for the model portfolio strategy, which Ameriprise Financial Services implements, subject to any Reasonable Restrictions or other instructions provided by you. • The Model Provider does not have any recommendations and helping to identify Envestnet Managers mutual funds and/or ETFs for the Account(s), considering factors it deems relevant, including, but not limited to, your investment objective, risk tolerance and investment time horizon. – Rebalancing services to maintain your Managed Account’s asset allocation. – Acting on any Reasonable Restrictions that you may impose on the management of your Managed Account(s) including designation of particular securities or types of security that you do not want purchased for your Managed Account(s). Envestnet and/or the Envestnet Manager must accept any Reasonable Restrictions before they will be binding on the Account(s). Review Envestnet’s Form ADV, Part 2A Appendix 1 for more information about its investment advisory business. investment discretion or trading authority to purchase or sell securities in your Account. Ameriprise Financial Services exercises investment discretion for Managed Accounts utilizing Model Providers and implements securities transactions in your Account(s) in accordance with the model portfolio provided by the Model Provider. Different Model Providers may arrive at different investment selection decisions regarding investments in a certain sector, market capitalization, or other category of investments, depending on the model portfolio’s investment objective. Oversight of the Model Provider and the model portfolio’s investment strategy is provided by the Oversight Committee, as described above. Due Diligence of Envestnet Managers. • Envestnet Platform. Ameriprise Financial The IRG conducts an annual review of the Envestnet Strategies. This review is based on applicable information gathered from various sources, including information from Envestnet, disclosure documents, Services offers certain advisory services that are available through a web-based platform offered by Envestnet Asset Management, Inc. (“Envestnet”). Envestnet is a non-affiliated registered investment adviser and seeks to 20 historical performance and assets under management. In limited circumstances, the IRG conducts initial and/or ongoing reviews to supplement Envestnet’s reviews of an Envestnet Strategy. As a result of these reviews, Ameriprise Financial Services may identify actual or potential concerns regarding Envestnet and/or an Envestnet Strategy and may request that Envestnet and/or the Envestnet Manager take corrective action to address such concerns. These reviews may result in the removal of an Envestnet Strategy from the applicable Program. If an Envestnet Strategy is removed from one or more of the Programs, you and your financial advisor will receive notice to change to a new investment. If no change is made, your Managed Account will be closed and moved in-kind to an Ameriprise brokerage account. Review of Envestnet Strategies by Envestnet. reject: i) a prospective client and related Managed Account for Vista Separate Account and Investor Unified Account Programs, or ii) the transition of your related account to Ameriprise Financial Services for Access Account Program. Once your Managed Account is accepted by Envestnet and/or the Envestnet Manager, you will become an investment management client of Envestnet and/or the Envestnet Manager. Envestnet and/or Envestnet Manager will have full discretionary authority to act on behalf of your Managed Account purchases, sales and other transactions in SMA(s), mutual funds and/or ETFs, without seeking your prior approval, except for selecting which mutual funds and/or ETFs are held in your Investor Unified Account. Envestnet may delegate its discretionary authority for your entire Account or a portion of your Managed Account, known as an investment sleeve, to an Envestnet Manager. Neither Envestnet nor the Envestnet Manager will have the ability to withdraw, disburse or transfer funds or securities from your Managed Account without your prior authorization. Client Contact with Advisory Service Providers. Ameriprise Financial Services relies in part upon Envestnet for analysis, information and the selection and monitoring of the various Envestnet Strategies. All Envestnet Managers receive and are directed to return a completed due diligence questionnaire each year. Your financial advisor will be your primary source of support in addressing any questions or concerns relating to your Managed Account. Although Ameriprise Financial Services imposes no limitations on the ability of clients to consult with their Advisory Service Provider(s) directly, you are encouraged to first contact your financial advisor with any questions or concerns. Information Relating to Your Household The Envestnet Strategies are considered “Approved” or “Available,” depending on the level of due diligence performed by Envestnet. Envestnet reviews the Envestnet Strategies and performance of a wide range of Envestnet Managers and in its sole discretion determines if an Envestnet Strategy is considered “Approved” or “Available.” Envestnet personnel rely on investment professionals of the Envestnet Managers and a variety of data available from one or more independent databases when determining if an Envestnet Strategy is “Approved” or “Available”. We use information concerning your primary household group’s investment, insurance, annuity and certain bank products to provide a consolidated statement. A primary household group may consist of an individual client, his or her spouse or domestic partner, and their unmarried children under age 21 who reside at the same address. Envestnet makes available information received from industry databases, such as Morningstar, regarding the Envestnet Strategies, to your financial advisor. This information may help your financial advisor to identify the strengths and weaknesses of each of the Envestnet Strategies. For certain products and services, the householding of your Managed Accounts may help you qualify for advantageous pricing or fees. See the “Householding of Account Assets and Minimum Asset-based Fee” sub- section of the “Fees and Compensation” section for more detail about householding’s impact on the Asset- based Fee. Please contact us at 800.862.7919 if you prefer to receive a statement covering only accounts that you own and not to participate in householding. Your financial advisor will be responsible for determining whether he or she has sufficient information about the Envestnet Strategies in order to recommend Envestnet and one or more of the Envestnet Strategies to you. Acceptance and Authority of Envestnet. Your Client Information along with a copy of your Statement of Investment Selection are provided to Envestnet as Investment Manager for review. Householding also permits us to deliver a single copy of certain shareholder documents – such as prospectuses, supplements, annual reports, semiannual reports and proxies – to clients who own the security and who reside at the same address. To opt out of this service, call 866.273.7429 and reference the client ID located in your statement. Envestnet in its sole discretion may determine based upon the applicable information whether to accept or 21 Multiple mailings will resume within 30 days of opting out. Tax documents are not eligible for householding. The Ameriprise® Custom Advisory Relationship The Relationship Agreement and this Disclosure Brochure, as amended, will apply to each Managed Account in the available Advisory Solutions Programs you are eligible to establish with us. Please retain these documents for future reference as they contain important information if you decide to add services or open new Managed Accounts with Ameriprise Financial Services. Advisory Solution Programs and Services for Managed Accounts The chart below provides an overview of the following Programs: for SPS Advantage, SPS Advisor, Signature Wealth, Active Portfolios® investments and Select Separate Account, including offering terms. Not all investment options listed for and SPS Advisor in the “Investment Products” row below may be available for new or additional purchases. Please refer to the “Programs and Services” section for a description of each Program and ask your financial advisor for more information about the investment products available to you. Fee information is included in the “Fees and Compensation” section following the description of the Programs. The charts also identify the primary mutual fund share class offered in the Programs and each Program’s corresponding minimum investment requirements. Minimum withdrawal amounts and Account minimums that may apply to the Program you select and are noted in the charts. Ameriprise Financial Services offers all new Managed Accounts to clients through a single Custom Advisory Relationship (“Relationship”). As used throughout this document, the defined term Relationship refers solely to an investment advisory relationship opened through the Relationship Agreement. By entering into a Relationship with us, you may establish Managed Accounts for the Advisory Programs described in this Disclosure Brochure, in many cases, without signing additional documentation. When you establish a Relationship, your initial signature will serve as your agreement to the terms and conditions of all of the Programs offered in this Disclosure Brochure and you may generally establish Managed Accounts and make many types of changes to your Managed Account by contacting your financial advisor and providing verbal instructions. We may ask you for written authorization to add certain features to an Account such as establishing margin or options trading, if available. The Access Account Program is a hold and service Program and, unlike the other Programs, requires you to complete additional paperwork and authorize the establishment of an Access Account by signature. When establishing a Relationship, you will make various elections that will be applied to your Managed Accounts opened in the applicable Program in the future. You can change some of these elections at Managed Account opening or any time for current Managed Accounts and/or Managed Accounts to be opened in the future by working with your financial advisor, although, changes to some elections require your written authorization. All Managed Accounts have a required (i) initial investment minimum; and (ii) maintenance minimum that varies by Program. For Signature Wealth Accounts, the maintenance minimum varies based on the mix of model investment portfolio(s) you select for your Managed Account. If an Account falls below the ongoing maintenance minimum, we will provide notice to you to add funds to the Account to bring it back to the initial investment minimum. If your Managed Account does not reach the initial investment minimum after 45 days, we will transfer the Account to an Ameriprise brokerage account in accordance with the Relationship Agreement. When reviewing the charts, please consider, among other factors: 1) your ability to meet initial investment and maintenance minimums for each Program using assets held in custody at Ameriprise or assets held elsewhere which might be aggregated; 2) whether the Program you select provides your financial advisor, the Oversight Committee or an Advisory Service Provider discretionary authority; 3) the impact of underlying investment product level fees on the overall performance of your portfolio; and 4) whether the rebate of any 12b-1 fees associated with your Managed Account may be a taxable event for you. Ameriprise Financial Services will send a confirmation letter to you when a Relationship is established, when a Managed Account is opened, or when your Asset-based Fee is changed as described in the “Fees and Compensation” section. You may make other changes verbally and we will send a confirmation letter reflecting such changes to you. Each confirmation letter becomes part of your Relationship Agreement unless you notify us that it is incorrect so it is important that you review and verify the information contained in it, such as your Managed Account elections, to ensure accuracy and notify your financial advisor immediately if you believe any information should be updated. 22 Programs SPS Advantage SPS Advisor Active Portfolios® Select Separate Account Signature Wealth Non-discretionary Discretionary Discretionary Discretionary Discretionary Investment Advisory Account Asset Structure Allocation Financial advisor recommends Financial advisor determines Financial advisor Recommends Investment Provider recommends Financial advisor recommends. For Select Strategist UMA Portfolios (“UMA Portfolios”), the Asset Allocation is determined by the Investment Manager. Investment Selection Financial advisor recommends Financial advisor determines Financial advisor recommends portfolios Financial Advisor recommends model investment portfolios and mutual funds1 and ETFs Financial advisor recommends portfolio/model. For UMA Portfolios, the investment selection of portfolios/models is determined by the Investment Manager. Investment Products Mutual funds and/or ETFs Mutual Fund/ETF model investment portfolios, SMA model investment portfolios, mutual funds and ETFs held within a single account Equity, ETF, balanced and fixed income separately managed account strategies (“SMA”). Some SMA managers may also invest in ETFs and certain mutual funds. UMA Portfolios invest in SMAs, ETFs and mutual funds. Includes, but not limited to: mutual funds1; (which could include fund of funds); ETFs; stocks; bonds; publicly traded REITs; options on indices and equities Includes, but not limited to: mutual funds1; (which could include fund of funds); ETFs; stocks; bonds; publicly traded real estate investment trusts (“REITs”); options on indices and equities; certain alternative investments (e.g., hedge funds, managed futures funds, non-traded REITs, non- traded BDCs, non- traded CEFs, real estate private placements, private equity offerings) Advisory Shares Advisory Shares Advisory Shares Advisory Shares Primary Share Class Offered for Purchase SMA strategies generally do not offer mutual funds. Where mutual funds are offered, Advisory Shares are offered for purchase $25,000 (for all accounts within a Household) $100,000 (for all accounts within a Household) Investment and Maintenance Minimums Initial investment minimum is $2,000, maintenance minimum is $1,000. Initial investment minimum $25,000, maintenance minimum $15,000. For Active Growth Builder Portfolios, initial investment minimum $5,000, maintenance minimum $4,000. Ameriprise Financial Services Initial investment minimum $2,000, maintenance minimum $1,000. Initial investment minimum $100,000 – $500,000 (depending on the SMA investment strategy or UMA portfolio). Ongoing minimums vary depending on the SMA investment strategy or UMA portfolio. Select ETF Portfolios have an initial investment minimum of $50,000. Each Signature Wealth Account has its own initial investment minimum and maintenance minimum and is determined by the investments you select within your personalized investment account asset allocation shown in the Signature Wealth Proposal. Ameriprise Financial Services may suspend or waive these amounts. Ameriprise Financial Services may suspend or waive these amounts. Each mutual fund/ETF portfolio investment model has its own initial investment minimum ranging from $5,000 - $50,000. Clients must invest in one or more model investment portfolios. Clients may also invest up to 25% of their Account in a client-directed model that holds individual mutual funds and/or ETFs. 23 N/A N/A N/A N/A Margin Trading Must be approved by Ameriprise Financial Services Cost Basis2,3 Open end mutual funds: Open end mutual funds: HIFO5, unless you select another option. Equities: HIFO5, unless you select another option. Average Cost2, unless you select another option. Equities: FIFO2, unless you select another option. Open end mutual funds: Non Average Cost Basis3 unless you elect a different option. Equities: Loss/Gain Utilization3 unless you elect a different option. Open end mutual funds: Average Cost2, unless you select another option. ETFs: HIFO5, unless you select another option. Open end mutual funds: Average Cost4, unless you select another option. Equities: FIFO4, unless you select another option. 1 Please contact your financial advisor or refer to our Mutual Fund Screener Tool for a current list of mutual funds offered in any of these accounts. Access the tool by logging into your Ameriprise Secure Site account and navigating to the “Trade & Research” and then, “Screeners” followed by “Mutual Fund”. From there, apply the Product Type filter and choose either SPS Advantage or SPS Advisor to view the funds and share classes available for purchase. 2 Below are the cost basis options available for SPS Advantage, SPS Advisor, Active Portfolios and Select Separate Account. You may elect to sell specific shares outside of the cost basis option you have selected. If you elect to change from average cost to another method after disposing of any mutual fund shares (i.e., sale, journal, transfer, etc.), the method change will apply only to covered shares acquired after the date of the most recent disposition. If you transfer securities into a Managed Account the cost basis method applied to the Managed Account receiving the securities will be applied to such securities. If you hold bonds in your Managed Account, you have the option to make tax elections which may affect the income on your bonds and the character of your bond income. These elections can be made by filing form 402459. Revoking certain bond elections may require IRS consent. Cost Basis for Equities: • First In, First Out (FIFO): The first tax lots purchased are the first tax lots sold. The tax lots remaining each maintain their individual tax lot cost and holding period. • Highest In, First Out (HIFO): The tax lots with the highest cost basis are the first tax lots sold. The tax lots remaining each maintain their individual tax lot cost and holding period. • Last In, First Out (LIFO): The last tax lots purchased are the first tax lots sold. The tax lots remaining each maintain their individual tax lot cost and holding period. • Loss/Gain Utilization (SPS Advisor Accounts only): Evaluates losses and gains and strategically selects shares to deplete based on the loss/gain in conjunction with the holding period. The loss/gain utilization method depletes shares with losses before shares with gains, consistent with the objective of minimizing taxes. For share lots that yield a loss, short-term share lots will be redeemed ahead of long-term share lots. For gains, long-term share lots will be redeemed ahead of short-term share lots. For SPS Advantage: If lot-specific identification of securities sold is desired, that must be done at the time of sale. For SPS Advisor: Note, that your financial advisor has the discretion to override these methods and use another cost basis method or specific identification. If lot-specific identification of securities sold is desired, that must be done at the time of sale. Cost Basis for Open End Mutual Funds: • Average Cost Basis: Each mutual fund’s cost basis is the total amount invested averaged over the number of shares purchased, giving each share the same basis. As new tax lots are purchased, or other adjustments are made, the average cost of the shares is recalculated. For holding period purposes, the first tax lots purchased are the first tax lots sold. Average cost is calculated separately for covered and non-covered shares. • Use Lot Relief Method selected above (FIFO, HIFO, LIFO): The lot relief method for the mutual fund account will be the same lot relief method elected for equities on this account, even if there are no equities in the account. For SPS Advisor Accounts, see footnote 4 (below). For SPS Advantage: If lot-specific identification of securities sold is desired, that must be done at the time of sale, and with a default lot relief election other than average cost made prior to sale. For SPS Advisor: Note, that your financial advisor has the discretion to override these methods and use another cost basis method or specific identification. If lot-specific identification of securities sold is desired, that must be done at the time of sale, and with a default lot relief election other than average cost made prior to sale. Cost Basis for Equities in Dividend Reinvestment Plans (DRP), as available: • Use Lot Relief Method selected above (FIFO, HIFO, LIFO): The lot relief method for the account will be the same lot relief method elected for equities on this account, even if there are no equities in the account. • Average Cost Basis: The cost basis for the shares is the total amount invested averaged over the shares purchased, giving each share the same basis. As new tax lots are purchased, or other adjustments are made, the average cost of the shares is recalculated. For holding period purposes, the first tax lots purchased are the first tax lots sold. Average cost is calculated for covered shares only. 24 3 Below are the cost basis options available in the Signature Wealth Program. You may elect to sell specific shares outside of the cost basis option you have selected. If you elect to change from average cost to another method after disposing of any mutual fund shares (i.e., sale, journal, transfer, etc.), the method change will apply only to covered shares acquired after the date of the most recent disposition. If you transfer securities into a Managed Account the cost basis method applied to the Managed Account receiving the securities will be applied to such securities. If you hold bonds in your Managed Account, you have the option to make tax elections which may affect the income on your bonds and the character of your bond income. These elections can be made by filing form 402459. Revoking certain bond elections may require IRS consent. Cost Basis for Mutual Funds • Non Average Cost Basis: The lot relief method for the mutual fund account will be the same lot relief method elected for equities on this account, even if there are no equities in the account. If shares have been sold using average cost, specific identification may be prospectively accounted. Cost Basis for Equities • Loss/Gain Utilization: Evaluates losses and gains and strategically selects shares to deplete based on the loss/gain in conjunction with the holding period. The loss/gain utilization method depletes shares with losses before shares with gains, consistent with the objective of minimizing taxes. For share lots that yield a loss, short-term share lots will be redeemed ahead of long-term share lots. For gains, long-term share lots will be redeemed ahead of short-term share lots. For Signature Wealth Accounts, if you indicate a preference, trades generally use that cost basis method. If you don’t indicate a preference, the cost basis selected by Ameriprise Financial Services listed above will generally be used for the Program. Further, the Signature Wealth Investment Manager with investment discretion may elect to sell specific investment products for tax-harvesting purposes regardless of the cost basis option you have selected. 4 For SPS Advisor accounts, open end mutual funds generally use average cost, but may use the Loss/Gain Utilization Method (defined above). Equities will generally use the Loss/Gain Utilization Method when your advisor is using certain trading systems. The FIFO preference may be used for the trades that do not use the Loss/Gain Utilization Method. Note, that your financial advisor has the discretion to override these methods and use another cost basis method or specific identification. 5 For discretionary Programs (other than SPS Advisor), if you indicate a preference, trades generally use that Cost Basis method. If you don’t indicate a preference, the cost basis selected by Sponsor and listed above will generally be used for the Program. Further, for Select Separate Accounts, the Advisory Service Provider with investment discretion may elect to sell specific investment products for tax-harvesting purposes regardless of the cost basis option you have selected. Programs Offered With Envestnet Asset Management, Inc. The chart below provides an overview of the following Programs: Vista Separate Account, Investor Unified Account and Access Account, including offering terms. Please refer to the “Programs and Services” section for a description of each Program and ask your financial advisor for more information about the investment products available to you. Fee information is included in the “Fees and Compensation” section following the description of the Programs. The charts also identify the primary mutual fund share class offered in the Programs and each Program’s corresponding minimum investment requirements. Minimum withdrawal amounts and Account maintenance minimums may apply to the Program you select and are available from your financial advisor. When reviewing the charts, please consider, among other factors: 1) your ability to meet investment minimums for each Program using assets held in custody at Ameriprise or assets held elsewhere which might be aggregated; 2) whether the Program you select provides your financial advisor, the Oversight Committee or an Advisory Service Provider discretionary authority; 3) the impact of underlying investment product level fees, on the overall performance of your portfolio; and 4) whether the rebate of any 12b-1 fees associated with your Managed Account may be a taxable event for you. Vista Separate Account Investor Unified Account Discretionary Discretionary Access Account2 Discretionary Investment Advisory Account Structure Asset Allocation Financial advisor recommends Financial advisor recommends Portfolio Strategist and/or Investment Manager determines Investment Selection Financial advisor recommends portfolio/model Financial advisor recommends portfolio/model and mutual funds/ETFs Financial advisor recommends portfolio/model Investment Products SMA strategies in multiple Accounts SMA strategies, mutual funds and ETFs within in a single account Mutual funds and/or ETF portfolios in one or more Accounts Advisory Shares Advisory Shares Advisory Shares Primary Share Class Offered for Purchase 25 Program minimum – Program minimum – Generally $25,000 to $250,000 Investment and Maintenance Minimums Program minimum - $100,000 Each SMA strategy has its own initial minimum and maintenance minimum. Client must invest in at least one SMA. Each SMA strategy has its own initial minimum and maintenance minimum. $50,000 depending on portfolio. Each Access portfolio has its own initial minimum and maintenance minimum. Client must invest in more than one investment product (e.g., one or more SMA, mutual fund or ETF, or combination thereof). Margin N/A N/A N/A Cost Basis3 Open end mutual funds: Average Cost, unless you select another option. Equities: HIFO4, unless you select another option. Open end mutual funds: Average Cost, unless you select another option. Equities: HIFO4, unless you select another option. Open end mutual funds: Average Cost, unless you select another option. Equities: HIFO4, unless you select another option. 1 In certain circumstances, your financial advisor may have discretion to select the asset allocation and investments for inclusion in your Managed Account. 2 This program is accommodation only. 3 Below are the cost basis options available. If you hold bonds in your Managed Account, you have the option to make tax elections which may affect the income on your bonds and the character of your bond income. These elections can be made by filing form 402459. Revoking certain bond elections may require IRS consent. Cost Basis for Equities: • First In, First Out (FIFO): The first tax lots purchased are the first tax lots sold. The tax lots remaining each maintain their individual tax lot cost and holding period. • Highest In, First Out (HIFO): The tax lots with the highest cost basis are the first tax lots sold. The tax lots remaining each maintain their individual tax lot cost and holding period. • Last In, First Out (LIFO): The last tax lots purchased are the first tax lots sold. The tax lots remaining each maintain their individual tax lot cost and holding period. Cost Basis for Open End Mutual Funds: • Average Cost Basis: Each mutual funds cost basis is the total amount invested averaged over the number of shares purchased, giving each share the same basis. As new tax lots are purchased, or other adjustments are made, the average cost of the shares is recalculated. For holding period purposes, the first tax lots purchased are the first tax lots sold. Average cost is calculated separately for covered and non-covered shares. • Use Lot Relief Method selected above (FIFO, HIFO, LIFO): The lot relief method for the mutual fund account will be the same lot relief method elected for equities on this account, even if there are no equities in the account. Cost Basis for Equities Dividend Reinvestment Plans (DRP), as available: • Use Lot Relief Method selected above (FIFO, HIFO, LIFO): The lot relief method for the account will be the same lot relief method elected for equities on this account, even if there are no equities in the account. • Average Cost Basis: The cost basis for the shares is the total amount invested averaged over the shares purchased, giving each share the same basis. As new tax lots are purchased, or other adjustments are made, the average cost of the shares is recalculated. For holding period purposes, the first tax lots purchased are the first tax lots sold. Average cost is calculated for covered shares only. 4 For discretionary Programs (other than SPS Advisor), if you indicate a preference, trades generally use that Cost Basis method; if you don’t indicate a preference, the cost basis selected by Ameriprise Financial Services and listed above will generally be used for the Program. Further, the Advisory Service Provider with investment discretion may elect to sell specific investment products for tax- harvesting purposes regardless of the cost basis option you have selected. 26 SPS Advantage logging into your Ameriprise Secure Site account and navigating to the “Trade & Research” and then, “Screeners” followed by “Mutual Fund”. From there, apply the Product Type filter and choose either SPS Advantage or SPS Advisor to view the funds and share classes available for purchase. See the “Revenue Sources for Ameriprise Financial Services, LLC” section regarding compensation for the sale of mutual funds. SPS Advantage is a non-discretionary Program which enables your financial advisor to provide investment advice relating to securities held in a single account, with access to a wide spectrum of investment choices. Advisory Shares are the primary share class for mutual funds offered for purchase in SPS Advantage Managed Accounts. SPS Advantage may be appropriate for clients who seek and act on the investment advice of their financial advisor. Your financial advisor makes regular investment recommendations in consideration of an asset allocation. You review and approve each recommendation. SPS Advantage is appropriate if you primarily choose transactions your financial advisor recommends to you (solicited). You may also choose transactions on your own (unsolicited). However, an SPS Advantage Account is not appropriate as a self- directed account or for day trading, highly active traders, or other excessive trading activity (solicited or unsolicited), including trading mutual funds based on market timing or if you plan to hold only a few mutual fund or securities holdings in your Managed Account. Dividends and distributions received on your investments held in your SPS Advantage Account may be reinvested, where allowed, if selected by you. The reinvestment of equity, ETF, preferred security, CEF or UIT. dividends will generally result in the purchase of a fractional share as further described in the “Fractional Shares and Principal Transactions” sub- section of the “Brokerage Practices” section and in your Relationship Agreement. Where reinvestment is not allowed or selected, your dividends and distributions will be deposited in your (“Sweep Program”), which is a vehicle for uninvested cash. Investment minimums may also apply to mutual funds you purchase through SPS Advantage. Review each applicable mutual fund’s prospectus for further details. Alternative Investments in SPS Advantage Accounts Ameriprise Financial Services will determine whether an SPS Advantage Account is appropriate upon account opening and thereafter. Ameriprise Financial Services, with thirty (30) days prior notice, also reserves the right to limit or close any Account that is used for excessive securities trading, or if it is determined that the Account is no longer appropriate for you. See the “Terminating a Relationship Agreement” section for more detail and for information regarding your right to terminate your SPS Advantage Managed Account(s). Ameriprise Financial Services offers certain types of alternative investments in SPS Advantage Accounts, including but not limited to hedge funds, managed futures funds, non-traded REITs, non- traded BDCs, non-traded closed end funds, real estate private placements, and private equity offerings. In order to be considered for inclusion in an SPS Advantage Account, the particular alternative investment must offer an eligible fee structure that is designed for use with advisory accounts and periodic redemptions. As a courtesy, annuities and life insurance policies may be displayed on your Managed Account statement. Such annuities and life insurance policies are not held in your Managed Account and any values provided by third parties are not validated by us. You will not receive recommendations or investment advice related to such annuities and life insurance policies as part of the SPS Advantage Program and the dollar value of any such annuity or life insurance policy is excluded from any portion of the Asset-based Fee calculation. Alternative investments that meet Ameriprise Financial Services’ due diligence standards are available for purchase. On an ongoing basis the product sponsor of the alternative investment determines the timing and amounts of funds that are available for redemption requests by investors. As a result, your investment in an alternative investment is less liquid than an investment in more common types of securities such as an equity, bond, mutual fund or ETF. Your ability to redeem all or a portion of your position will be impacted by these factors. In the event redemptions for a particular alternative investment are unavailable to you or otherwise significantly restricted for an extended period of time, or the alternative investment no longer meets our due diligence criteria, Ameriprise Financial Services will reclassify the investment as a non-advisory asset and promptly transfer the position into an Ameriprise brokerage account in accordance with the Relationship Agreement. Included among the available mutual funds for a SPS Advantage Account, except for trustee-directed retirement plans, are affiliated mutual funds and investment products which are managed or sub- advised by CMIA or their affiliates. For more information on fund families and mutual funds offered in our Managed Account services including the applicable Advisory Share class or other share class utilized, please contact your financial advisor or refer to our Mutual Fund Screener Tool. Access the tool by 27 You should choose investments that are comprised of an appropriate portfolio mix, based on a variety of factors including your age, risk tolerance, objectives, time horizon and historical performance of different asset classes. Keep in mind, however, that asset allocation analysis does not provide a comprehensive financial analysis of your ability to reach your goals, nor does it guarantee against losses in your portfolio. The valuation of alternative investments reflects the values as determined by and based on the records of the product sponsors and administrators of a given investment. While we apply reasonably designed due diligence procedures on an initial and ongoing basis, Ameriprise Financial Services does not guarantee the accuracy of valuation information. Valuation at time of redemption is based on various factors and therefore the value shown on your consolidated statement is not necessarily the value you will receive from the product sponsor if you choose to sell your position in an investment. While financial advisors do not pay transaction charges for trades they enter online, franchisee financial advisors are generally assessed a transaction charge for orders entered by phone. For employee financial advisors, this transaction charge is assessed to the employee’s branch. Payment of phone-in transaction charges in SPS Advantage Accounts may be a disincentive for a financial advisor to recommend an SPS Advantage Account or to recommend such trades in the Account(s). Optional Automatic Rebalancing Feature SPS Advantage has an optional feature that allows you to enable automatic rebalancing (the “Feature”). You may enroll in the Feature by completing the Ameriprise SPS Advantage Automatic Rebalancing Agreement with your financial advisor. Whether or not you enroll in the Feature you can direct your financial advisor to rebalance at any time. For purposes of calculating the Asset-based Fee, alternative investments will be valued as of the billing date using the values provided to us from the product sponsors and administrators of the investment. Valuation for alternative investments is often delayed, sometimes significantly, and is not guaranteed to be provided to Ameriprise Financial Services in a timely manner. As a result, the valuation used for purposes of calculating the Asset-based Fee may not be current with the actual value of your investments at the time billing is processed and, depending on the circumstances, can result in a higher Asset-based Fee. You should carefully consider the impact of these valuation delays on your Asset-based Fee when evaluating whether to invest in an alternative investment and when determining how much of your portfolio is appropriate to invest in alternative investments. Methods of Analysis After enrolling in the Feature, you can work with your financial advisor to establish a pre-determined allocation and frequency for Ameriprise Financial Services to rebalance your assets to your pre- determined allocation in accordance with your instructions (“Security Target”). When you have an active Security Target, Ameriprise Financial Services will effect the scheduled securities transactions in accordance with your instructions until your Security Target is inactivated, modified, or your Managed Account is terminated. Not all securities in your Managed Account need to be included in the Security Target (“Non-Target Securities”). Non-Target Securities are not subject to automatic rebalancing. Your financial advisor will review your financial and investment needs, objectives and risk tolerance. He or she may use asset value, current yield, yield projections as well as other assumptions you provide, as well as historical yield analysis, to provide you with investment recommendations. Investment recommendations will generally be made in consideration of an asset allocation strategy. Asset allocation is a strategy for diversifying investment assets among various types of investments or asset classes with the potential to move you toward your financial goals while mitigating portfolio risk. Diversification helps you spread risk throughout your investment portfolio. Different asset classes have different risk and potential return profiles, and they perform differently in different market conditions. Diversification will not guarantee a profit or protect against a loss. Any estimated returns, estimated asset values, and historical performance should not be used to project the performance of specific assets you currently own or may purchase. As with all investment strategies, past performance is no guarantee of future results. In addition, forecasts of future performance of financial markets may prove to be incorrect. You will be responsible for designating the securities in your allocation, as well as setting the Security Target percentage for each position. As part of activating a Security Target, you will select a rebalancing frequency interval (a “Frequency Interval”). The Frequency Intervals are quarterly (91 days), semi- annually (182 days), and annually (370 days). While these frequency intervals are generally long enough that you will not incur a short-term redemption fee from a mutual fund, it is possible that you will incur such a fee. When choosing the mutual funds to put in your Security Target, you should consider this. When you select a rebalancing Frequency Interval, the next rebalancing date (the “Rebalancing Date”) will be on or about the day following the end of the Frequency 28 Interval you have chosen in your most recent Security Target or the actual day that we were able to effect the automatic rebalancing in your Managed Account, whichever is later. The only permissible reason for a delay is an operational delay as described below. If you want to add to, delete, or otherwise modify your Security Target, you will confirm the change with your financial advisor. All Security Target modifications or activations will not be implemented until a minimum of a calendar quarter has elapsed. You will receive a confirmation letter setting forth your newly activated, modified, or inactivated Security Target. Notify your financial advisor immediately if the instructions confirmed to you are incorrect. account is subject to a trade correction, technology failures, operational failures, high trading volumes, corporate reorganizations, unusual market conditions, or any other condition which impedes our ability to process your instructions accurately. If automatic rebalancing has been delayed, generally it will take place in the next market session, however, we will attempt to rebalance your Managed Account on successive days for up to five (5) business days. If we have tried to rebalance your Managed Account five successive times and each rebalance has failed, your Security Target will be inactivated. Additionally, we will automatically inactivate your Security Target if we receive notice of death, divorce, or in the case where we receive returned/undeliverable mail. In each case, you will receive notice of your Security Target becoming inactivated. We will report any trades executed in connection with the Feature to you in your monthly account statement for the month in which the transaction took place. Eligible Assets and Eligible Securities. Only certain types of assets and securities are eligible for the Feature. The security types eligible for the Feature include mutual funds, ETFs, traded CEFs, and individual equities. Assets held on margin are ineligible for the Feature. Only securities already owned in your Managed Account may be a part of your Security Target. A rebalancing will fail if: the account has a pending or unprocessed trade correction, the Security Target includes a security that is not held in the account, the account becomes restricted from trading, a position is held on margin, the Security Target includes a mutual fund position that is not eligible for trading, or the account becomes ineligible to purchase additional shares of a mutual fund included in the Security Target. You can deposit cash, transfer in securities, or make additional purchases at any time while enrolled in the Feature. Additional cash deposited into your Managed Account may be invested at any time as you instruct. Cash in your Managed Account that exceeds the Security Target percentage will be automatically invested in accordance with your Security Target the next time your Managed Account rebalances. Margin Balances Held in SPS Advantage Accounts. The Rebalancing Process. Automatic rebalancing will be accomplished by buying and selling eligible securities. Overweighted securities will be sold and underweighted securities will be purchased, provided the transactions required to rebalance the Account meet the minimum trade requirement of $100. When rebalancing, the Feature will calculate whether the eligible securities included in the Security Target are over or underweight their target percentage relative to each other when calculating the automatic rebalancing; it will not take the value of Non-Target Securities into account and Non-Target Securities will not be rebalanced as a part of the Feature. Also, when you choose a security to be included in your Security Target, any purchases or transfers into your Managed Account of that same security will be included in and subject to your Security Target and rebalanced on the next Rebalancing Date, if applicable. Both pledge loans and margin are available in non- qualified SPS Advantage Accounts; however, you may not utilize both margin lending features and a pledge line of credit in the same Account. This section covers the specific benefits, costs and risks of using margin in a non-qualified SPS Advantage Account. For details regarding the Ameriprise Preferred Line of Credit and conflicts of interest associated with both types of products, see the “Securities-Based Lending Solutions” section. Automatic rebalancing will generally occur on or about the day after the last day of the Frequency Interval from the date your last Security Target instruction was accepted or the last automatic Rebalancing Date, whichever was later. The only permissible reason for a delay is an operational delay as described below. Such transactions generally result in tax consequences in non-qualified SPS Advantage Accounts. Investing on margin involves the extension of credit to you and your financial exposure could exceed the value of your securities. Ameriprise Financial Services, in its sole discretion, may approve your Managed Account for margin trading. Margin lending has specific risks outlined in the Margin Risk Disclosure document; review that document before opening a margin account. We may only delay processing your instructions under circumstances related to operational issues associated with the Security Target, and the delay may only persist to the extent that these operational issues impede our ability to process your instructions, including but not limited to: a Rebalancing Date falling on a day other than a business day, the Rebalancing Date falling on a day your Asset-based Fee is being deducted, the 29 Considerations Include: • margin activity in your SPS Advantage Account, the incremental fees paid to Ameriprise Financial Services and its affiliates may be significantly higher than in the absence of margin or than might otherwise be paid pursuant to a standard margin arrangement with us or another broker-dealer. The following is a hypothetical illustration of the impact on the compensation received by Ameriprise Financial Services and its affiliates. It compares an SPS Advantage Account that does not engage in margin activity to an Account with a margin arrangement with respect to 30% of the SPS Advantage Account assets. A decline in the value of securities that are purchased on margin or are in a margin account may require you to provide additional funds to AEIS to maintain your position and/or to maintain sufficient assets in the Sweep Program to meet fee requirements. If you do not provide the required additional funds or securities within the prescribed time, we will determine which securities to liquidate to address any margin call and can liquidate all or a portion of your holdings. You will be liable for any resulting deficit in your Managed Account. • Without buying on Margin With buying on Margin Account Value $100,000 $100,000 You can lose more funds than you deposit in the margin account. Margin trading can work against you as well as for you, leading to, for example, larger losses as well as the potential for larger gains. n/a $130,000 • Margin may be approved only for non-qualified SPS Advantage Accounts. Revised Account value including assets purchased on margin • $2,000 $2,600 Annual Asset-based Fee received by Ameriprise Financial Services (based on 2.0% Asset-based Fee) Tax-qualified SPS Advantage accounts, such as accounts established under the Employee Retirement Income Security Act of 1974 (“ERISA”), IRAs and Tax-Sheltered Custodial Accounts (“TSCAs”) are not available for margin accounts. n/a $1,800* • Margin interest received by AEIS $2,000 $4,400 Total Asset-based Fee and margin interest received by Ameriprise Financial Services and affiliates** Only one account per ownership registration (e.g., individual, joint) is allowed to establish margin at Ameriprise. For example, if you have already established margin borrowing in an Ameriprise brokerage account in an individual ownership, an SPS Advantage Account in the same individual ownership will not be approved for margin unless margin trading is removed from the Ameriprise brokerage account. • * This Assumes average daily outstanding margin loan balance of $30,000 over one-year period and 6% interest rate. For current interest rates consult your financial advisor. ** This example does not include any product-level fees that may be received by Ameriprise Financial Services on the mutual fund portion of the SPS Advantage Account(s). If these fees were included, total fees received by Ameriprise Financial Services would be higher. If you acquire/hold securities positions on margin, any margin account balance in SPS Advantage will be included in the calculation of your Asset-based Fee for that period. Therefore, if you engage in margin activity your Asset-based Fee will be higher and Sweep Program maintenance requirements will be impacted to the extent of the margin exposure. SPS Advisor Fees and Compensation Associated with Margin Activity. If you purchase securities in your non-qualified SPS Advantage Account using margin you will be subject to interest charges for the extension of credit in the margin account in addition to your Asset-based Fee based on total assets under management. In addition, your Asset- based Fee will increase as the value of your Managed Account increases and the compensation earned by your financial advisor will similarly increase. In situations where you engage in SPS Advisor is a discretionary Service that enables your SPS Discretionary Advisor to direct the purchase or sale of eligible securities and/or investment products within a single account on your behalf. Advisory Shares are the primary share class for mutual funds offered for purchase in SPS Advisor Accounts. The term SPS Discretionary Advisor refers to each individual that has discretionary authority to purchase or sell securities in your SPS Advisor Account without seeking your prior approval for each trade. Your financial advisor may be a part of a team. In this scenario, there may be more 30 statement. Such annuities and life insurance policies are not held in your Managed Account and any values provided by third parties are not validated by us. You will not receive recommendations or investment advice related to such annuities and life insurance policies as part of the SPS Advisor Service and the dollar value of any such annuity or life insurance policy is excluded from any portion of the Asset-based Fee calculation. than one SPS Discretionary Advisor authorized to use discretion on your Managed Account. For example, in the instance your SPS Discretionary Advisor(s) becomes unavailable or incapacitated, your Managed Account may temporarily be managed, and securities purchased and sold, by a designated back-up SPS Discretionary Advisor for the individual or team. Your primary, or servicing financial advisor, will recommend the Managed Account or AFPS, negotiate the Advisory Fee with you, and oversee the analysis and advice prepared for you. Your servicing financial advisor may or may not be your SPS Discretionary Advisor. In the instance that your servicing financial advisor is not your SPS Discretionary Advisor, your SPS Discretionary Advisor will oversee the analysis and investment advice prepared for you. Dividends and distributions received on your investments held in your SPS Advisor Account may be reinvested, where allowed, if selected by you. The reinvestment of equity, ETF, preferred security, CEF or UIT dividends will generally result in the purchase of a fractional share as further described in the “Fractional Shares and Principal Transactions” sub-section of the “Brokerage Practices” section and in the Relationship Agreement. Where reinvestment is not allowed or selected, your dividends and distributions will be deposited in your Sweep Program. Your SPS Discretionary Advisor will purchase and sell securities in your Managed Account that are suitable for you and consistent with your investment objectives, time horizon, financial situation, risk tolerance and in consideration of each Account’s asset allocation. You must promptly notify your financial advisor if these factors change. SPS Advisor Accounts are not appropriate for day trading, highly active traders, or other excessive trading activity, including trading mutual funds based on market timing. Such short- term trading activity may result in a short-term redemption fee from a mutual fund. Included among the available mutual funds for a non- qualified SPS Advisor Account are mutual funds which are managed or sub-advised by our affiliate, CMIA. For more information on fund families and mutual funds offered in our Managed Account Services including the applicable Advisory Share class or other share class utilized, please contact your financial advisor or refer to our Mutual Fund Screener Tool. Access the tool by logging into your Ameriprise Secure Site account and navigating to the “Trade & Research” and then, “Screeners” followed by Mutual Fund. From there, apply the Product Type filter and choose either SPS Advantage or SPS Advisor to view the funds and share classes available for purchase. See the “Revenue Sources for Ameriprise Financial Services, LLC” section regarding compensation for the sale of mutual funds. Your SPS Discretionary Advisor will not have the ability to withdraw, disburse or transfer funds or securities from your SPS Advisor Account without your prior authorization. You may impose Reasonable Restrictions on your SPS Advisor Account(s) by working with your financial advisor to reflect your restriction request(s). Although your SPS Discretionary Advisor will exercise discretion in your Managed Account, the performance of your Managed Account(s) will not be monitored on a day-to-day basis. Education and Business Standards Ameriprise Financial Services will determine whether an SPS Advisor Account is suitable upon account opening and thereafter. Ameriprise Financial Services, with thirty (30) days prior notice, also reserves the right to limit or close any Account if it is determined that the Program is no longer suitable for you. See the “Terminating a Relationship Agreement” section for more detail and for information regarding your right to terminate your SPS Advisor Account(s). Ameriprise Financial Services also reserves the right, with thirty (30) days prior notice, to transfer your SPS Advisor Account into an SPS Advantage Account as further described in the Relationship Agreement, which are available from your financial advisor and online at www.ameriprise.com/disclosures. As a courtesy, annuities and life insurance policies may be displayed on your Managed Account Financial advisors can choose whether or not to pursue certification as an SPS Discretionary Advisor and participate in the SPS Advisor Program. In order for a financial advisor to become eligible to provide discretionary investment management services to you in the SPS Advisor Program, Ameriprise Financial Services requires that financial advisors become certified as an SPS Discretionary Advisor. A financial advisor can become certified by meeting certain eligibility requirements and completing required training. Eligibility requirements include a minimum number of years of relevant experience, a particular level of assets under management, and industry certifications such as an Accredited Portfolio Management AdvisorSM (“APMA®”) program certificate or a Chartered Financial Analyst®(“CFA®”) or Certified Investment Management Analyst®(“CIMA®”) certification. Ameriprise Financial Services reserves the right to deny and withdraw a 31 Signature Wealth financial advisor's ability to offer SPS Advisor Accounts even though the financial advisor otherwise meets our certification requirements. SPS Discretionary Advisors are also subject to ongoing reviews to maintain their eligibility to continue offering discretionary investment management services to you in the SPS Advisor Program. These reviews and the eligibility requirements we impose may be a disincentive for a financial advisor to participate in the SPS Advisor Program and offer SPS Advisor Accounts. Methods of Analysis Your financial advisor will review your financial and investment needs, objectives and risk tolerance. Your SPS Discretionary Advisor may use asset value, current yield, yield projections, historical yield analysis, as well as other assumptions you provide, to make investment decisions. Investment decisions will generally be made in consideration of an asset allocation strategy. Asset allocation is a strategy for diversifying investment assets among various types of investments or asset classes with the potential to move you toward your financial goals while managing your risk tolerance. Diversification helps you spread risk throughout your investment portfolio. Different asset classes have different risk and potential return profiles, and they perform differently in different market conditions. The Signature Wealth Program, a flexible Unified Managed Account, is a discretionary investment advisory program, which offers clients the ability to combine multiple investment types such as mutual fund and ETF model investment portfolios, SMA model investment portfolios, and individual mutual funds/ETFs in an asset allocation within a single Account. With the assistance of your financial advisor, you will determine your investment objective, risk tolerance, and time horizon that will form the basis of your target asset allocation. From your Client Information, your financial advisor will create a personalized Signature Wealth Proposal and recommend investments from a broad range of model investment portfolios that are constructed by Signature Wealth Investment Providers and eligible mutual funds and ETFs to fulfill your Signature Wealth Account target asset allocation. You can further customize and round out the asset allocation in your Managed Account with a client directed model, the portion of your Managed Account that is not invested in model investment portfolios and where you select from individual eligible mutual funds and ETFs to hold in your Managed Account in addition to the model investment portfolio(s). A minimum of one model investment portfolio must be selected to participate in this Program. A client directed model is not required to participate in this Program. Advisory Shares are the primary share class for mutuals funds offered for purchase in a Signature Wealth Account. TSCA accounts are not eligible to invest in Signature Wealth. Diversification will not guarantee a profit or protect against a loss. Neither estimated returns, estimated asset values, nor historical performance should be used to project the performance of specific assets you currently own or may purchase. As with all strategies, past performance is no guarantee of future performance. In addition, forecasts of future performance of financial markets may prove to be incorrect. In addition, your SPS Discretionary Advisor will choose investments that are comprised of an appropriate portfolio mix, based on a variety of factors such as your age, risk tolerance, objectives, time horizon and historical performance of different asset classes. Keep in mind, however, that asset allocation analysis does not provide a comprehensive financial analysis of your ability to reach your goals, nor does it guarantee against losses in your portfolio. While financial advisors do not pay transaction charges for trades they enter online, franchisee financial advisors are assessed a transaction charge if entering an order by phone. For employee financial advisors, this transaction charge is assessed to the employee’s branch. Payment of phone-in transaction charges in SPS Advisor accounts may be a disincentive for a financial advisor to recommend an SPS Advisor Account or to place such trades in the Account(s). For Accounts in the Signature Wealth Program, all discretionary investment management is provided by the Signature Wealth Investment Manager, a third-party Advisory Service Provider. The Signature Wealth Investment Manager has the discretionary authority to purchase or sell securities or make other investments for your Managed Account; however, you directly own the underlying securities in the portfolio. Your financial advisor provides recommendations regarding which model investment portfolios, mutual funds and ETFs to hold in your Signature Wealth Account. The Signature Wealth Investment Manager, not your financial advisor, will provide you with investment management services for your Signature Wealth Account according to your Managed Account’s target asset allocation and the model investment portfolios, mutual funds and ETFs you select. The Signature Wealth Investment Manager will manage the assets in your Managed Account(s) according to your Account’s target asset allocation, subject to any Reasonable Restrictions or other instructions provided by you. 32 the following steps: Ameriprise Financial Services will (i) first close the SMA strategy in the Select Separate Account Program to new investments prior to offering the SMA strategy in the Signature Wealth Program; (ii) generally allow pending new accounts for the SMA strategy to continue to be processed in the Select Separate Account Program; and (iii) subsequently migrate existing accounts investing in the SMA strategy from the Select Separate Account Program into the Signature Wealth Program. If you have chosen to add a client directed model to your portfolio, you will work with your financial advisor to select the investments that make up your client directed model. The Signature Wealth Investment Manager has trading discretion over any client directed model and will be responsible for all trading and rebalancing of your client directed model along with the model investment portfolios you selected to maintain your Managed Account’s target asset allocation. In instances where a particular mutual fund or ETF is no longer eligible for use in the Signature Wealth Program, the Signature Wealth Investment Manager has limited investment discretion to select a replacement mutual fund or ETF for your client directed model. During this transition phase, if you hold an impacted SMA strategy in an existing Select Separate Account the Platform Fee rate you pay is higher for your Select Separate Account than it would be if you held the same SMA strategy in the Signature Wealth Program. As your Select Separate SMA strategy goes through this transition, Ameriprise Financial Services will notify you. Your Signature Wealth Account will generally only rebalance when (i) you make deposits into or withdrawals from the Signature Wealth Account, (ii) annually at least every 370 days, or (iii) when requested. However, if you make a change to your model investment portfolios or asset allocation, your Managed Account will be rebalanced to align with the appropriate asset allocation in effect for your investment objective and risk tolerance. Such rebalancing transactions generally result in tax consequences in non-qualified accounts. Your annual rebalance date will reset each time your Managed Account rebalances. The Signature Wealth Investment Manager will rebalance and reallocate your Signature Wealth Account, across each model investment portfolio and if applicable any client directed model. You may request Reasonable Restrictions on your Managed Account(s) by working with your financial advisor to complete and sign appropriate documents to reflect your restriction request(s). The Signature Wealth Investment Manager must accept any Reasonable Restrictions before they will be binding on the Account(s). If a Reasonable Restriction is accepted any impacted position(s) will be removed from the applicable model investment portfolio or client directed model and the proceeds reallocated to the remaining positions in any impacted model investment portfolio or client directed model on a pro rata basis. This creates a conflict of interest as Ameriprise Financial Services receives a higher Platform Fee for Select Separate Accounts than we receive for Signature Wealth Accounts, including the transition period when the same SMA strategy is held in both Programs. Ameriprise Financial Services addresses this conflict through a combination of disclosures and by closing any duplicative SMA strategies through the transition process described above. Additionally, the transition process does not impact the Manager Fee that compensates the Advisory Service Provider and does not affect the portion of the Asset-based Fee received by your financial advisor. However, the transition process will result, for a limited period of time, in Sponsor receiving a higher Platform Fee from impacted SMA strategies held within Select Separate Accounts than it would from the same SMA strategy invested in Signature Wealth Accounts. Beginning in the second half of 2026, Ameriprise Financial Services plans to eliminate this conflict of interest by migrating any Select Separate Account with an impacted SMA strategy from the Select Separate Account Program to the Signature Wealth Program, in accordance with the Relationship Agreement. As noted above, when your Select Separate Account SMA strategy is a part of this transition, Ameriprise Financial Services will notify you so that you may work with your financial advisor to transition your Select Separate SMA Account to the Signature Wealth Program at a date of your choosing so that you can benefit sooner from the reduced Platform Fee rate the Signature Wealth Program provides. Dividends and distributions received on your investments held in your Signature Wealth Account may be reinvested, where allowed, if selected by you. Inclusion and Management of Advisory Service Providers The following summarizes Ameriprise Financial Services’ research, due diligence and contractual efforts in connection with the inclusion of Advisory Service Providers in the Signature Wealth Program. Certain SMA strategies that are currently available in the Select Separate Account Program are / or will become available in our Signature Wealth Program as our initial step to transition such SMA strategies from the Select Separate Account Program into the Signature Wealth Program. The full transition process will include 33 Review of Advisory Service Providers Ameriprise Financial Services’ Contractual Relationship with Advisory Service Providers Ameriprise Financial Services conducts initial and ongoing reviews of the Signature Wealth Investment Manager and the available Signature Wealth Investment Providers, as further described in the “Advisory Service Providers” section. The Signature Wealth Investment Manager and each of the Signature Wealth Investment Providers have entered into a master advisory agreement with Ameriprise Financial Services, which governs the relationship and responsibilities of the respective parties. You may pay a Manager Fee for any of the Signature Wealth Investment Providers, you will pay the Signature Wealth Investment Manager a fee for their services. See “Fees and Compensation” section below for more information. Ameriprise Financial Services seeks to identify and make available a range of model investment portfolios within the Signature Wealth Program to provide clients with a choice of investment styles and corresponding risk levels. The evaluation process consists of gathering information on the Signature Wealth Investment Provider candidates from published materials, questionnaires and interviews. Screening factors are both quantitative and qualitative and include (but are not limited to): (i) management style and total assets under management; (ii) assets managed in a particular investment style; (iii) number of years the firm has managed assets; and (iv) the number and qualifications of investment professionals employed. Each evaluation factor may have a different weighting in the decision- making process. Generally, no one factor determines the outcome of any selection. Certain Signature Wealth Investment Providers may employ one or more affiliates to perform certain aspects of their portfolio construction, administrative support, sales and marketing for one or more model investment portfolios. In these situations, the affiliate is subject to the same duties and obligations as the Signature Wealth Investment Provider, including adherence to the master advisory agreement with Ameriprise Financial Services. In delegating responsibilities to an affiliate, the Signature Wealth Model Provider would not be relieved of any of its duties or obligations and remains responsible for the acts and omissions of the affiliate as if such acts and omissions were its own. Your Selection of Signature Wealth Firms, including affiliates of Ameriprise Financial Services, which pass the evaluation process are subject to a structured due diligence review by IRG. Ameriprise Financial Services may identify actual or potential concerns regarding a particular Signature Wealth Investment Provider as a result of the review and may request that the Signature Wealth Investment Provider take corrective action to address such concerns. These reviews may also result in the removal of a Signature Wealth Investment Provider from the Program. Education and Business Standards The investment advisory personnel employed by Advisory Service Providers participating in the Signature Wealth Program must meet certain educational, business and personnel requirements. The minimum educational requirement for an individual providing investment advice is a college degree and completion of further financial service industry certifications such as the CFA, FINRA Series 7, 63, 65 and 66 licenses, or comparable education or work experience. Ameriprise Financial Services’ research personnel seek to identify, and encourage participation by, Advisory Service Providers whose personnel have additional professional qualifications, including graduate degrees or a CFA designation. In addition, suitable work experience in the financial services industry is considered as part of an individual’s overall qualifications. Your financial advisor will discuss your financial objectives and other factors such as your risk tolerance, investment objectives, and important information regarding the Signature Wealth Program, the Signature Wealth Investment Manager and the available Signature Wealth Investment Providers. Based on the Client Information you provided, you and your financial advisor will work together to create a Signature Wealth proposal which will provide you with a target asset allocation for your Managed Account along with recommendations for model investment portfolios and as applicable, a client directed model of individual mutual funds and / or ETFs to round out your target asset allocation. Your financial advisor will recommend and you may select one or more Signature Wealth Investment Providers from the list of available model investment portfolios. Included in the available model investment portfolio list is Columbia Management Capital Advisers, an operating division of CMIA, an affiliate of Ameriprise Financial Services. When you select your investments and agree to establish a Signature Wealth Account, you will be giving discretion of your Signature Wealth Account to the Signature Wealth Investment Manager. To assist you in making your decision, you will be provided with a copy of the Signature Wealth Investment Manager’s disclosure brochure document (Part 2A of Form ADV) and you will be provided with access to the Signature Wealth Model Provider’s disclosure document (Part 2A 34 withdraw, disburse or transfer funds or securities from your Managed Account without your prior authorization. Limitations on Security Type of Form ADV), which includes important information regarding the Advisory Service Providers. Your financial advisor will also provide you with Signature Wealth Model Provider Fact Sheets for the model investment portfolios you selected for your Signature Wealth Account. Please note that past performance is not an indication of future results. Composite performance information included on the Signature Wealth Fact Sheet has been provided by the Signature Wealth Investment Provider. In general, these composites are created quarterly on an asset and time-weighted basis using month-end market values and returns. Your financial advisor can provide you with the Signature Wealth Fact Sheets for specific composite performance information regarding each model investment portfolio available. Except as may be provided in connection with the Sweep Program, in general, the Signature Wealth Investment Manager may not directly invest your assets in cash equivalent securities or instruments such as money market securities, certificates of deposit, time deposits, banker’s acceptances or repurchase agreements; or options, futures or other derivative instruments; however these types of securities may be included in the underlying holdings of the mutual funds and ETFs recommended by the Signature Wealth Investment Providers and utilized by the Signature Wealth Investment Manager. These types of assets are also generally not accepted for deposit in connection with establishing a new Account. Prospectus Delivery to Signature Wealth Investment Manager Ameriprise Financial Services requires each Signature Wealth Investment Provider to meet Ameriprise Financial Services’ performance validation standards, however Ameriprise Financial Services does not review the appropriateness of the methodologies used by the Signature Wealth Investment Providers to calculate the underlying historical performance information presented in the Signature Wealth Fact Sheet, nor does Ameriprise Financial Services audit the mathematical accuracy of the Signature Wealth Model Provider’s performance information. Ameriprise Financial Services does restate the performance after deducting the highest annual Asset-based Fee when presenting the performance on a net basis. Prospectuses contain detailed information about the fees and expenses charged by, and the past performance of, the investments held in your Managed Account(s). With your authorization and appointment as your agent for delivery, the Signature Wealth Investment Manager will receive prospectuses on your behalf for the mutual funds and ETFs purchased in your Signature Wealth Account investments within the model investment portfolios. Information regarding your Managed Account’s holdings of, and transactions in, mutual funds and ETFs will be available on the secure site at amerprise.com and in your Ameriprise Financial statements. Review the Signature Wealth Investment Manager and as applicable, the Signature Wealth Model Provider’s disclosure document (Part 2A of Form ADV), this Disclosure Brochure Supplement, the Disclosure Brochure and the applicable Signature Wealth Investment Providers Fact Sheet(s) prior to selecting a Signature Wealth Account. Each Signature Wealth Model Provider’s disclosure document is available to you at ameriprise.com/investmentproviders. Acceptance of Your Signature Wealth Account You retain the right to receive any prospectuses that are delivered to the Signature Wealth Investment Manager on request and at any time by requesting a copy from your financial advisor or by contacting us at 800.862.7919. You may also access the prospectuses for the mutual funds and ETFs held in your Signature Wealth Account(s) via the fund family’s website. If you prefer to receive the information that is contained in prospectuses, please contact your financial advisor or us at the number above and we will provide them to you. In this case, Ameriprise Financial Services will deliver prospectuses for the investments held in your Signature Wealth Account(s) directly to you in accordance with your document delivery preference. If you elect a client directed model, the prospectuses related to the mutual funds and/or ETFs held will be directed to you. You may not direct these prospectuses to the Signature Wealth Investment Manager. Ameriprise Financial Services will determine, on behalf of the Signature Wealth Investment Manager, whether to accept or reject a prospective client and related Account based upon the Client Information. Once your Managed Account is accepted, you will become an investment management client of the Signature Wealth Investment Manager. The Signature Wealth Investment Manager will have discretionary authority as described above to act on your behalf for purchases, sales and other transactions in your Signature Wealth Account, including sales with respect to securities transferred in-kind to the account, without seeking your approval. Such transactions generally result in tax consequences in non-qualified accounts. Your Signature Wealth Investment Manager will not have the ability to 35 Methods of Analysis changes to the selected investments within your Managed Account, as well as other relevant information to help them monitor these discretionary Account(s). Transferred Accounts The following information applies generally to the Investment Managers and Investment Providers available in Managed Accounts Programs. Investment Managers and Investment Providers may utilize different techniques for buying and selling securities, which are often unique to the investment strategies they manage. Fundamental analysis is the most common method used and typically involves the development of a thorough understanding of fundamental features of a business through analysis and interpretation of company and industry data, such as revenue, expenses, assets, liabilities, management, industry position and other factors, in order to evaluate a security. You may wish to transfer a model investment portfolio that you hold at another investment advisory firm to Ameriprise Financial Services. If this model investment portfolio is offered in the Ameriprise Signature Wealth Program, you may transfer the account to your Signature Wealth Account. Upon receipt, the investment will be rebalanced into your Managed Account in accordance with your Signature Wealth Account’s target asset allocation within your Signature Wealth proposal, which may result in different investment positions and/or allocation of such positions than the model investment portfolio you held at the prior advisory firm. If your current model investment portfolio is not available in the Ameriprise Signature Wealth Service, your financial advisor will assist you with identifying other appropriate alternatives. Active Portfolios® Certain Investment Managers and Investment Providers may also use quantitative methods of analysis, which is computer-based and uses mathematical and statistical modeling to value securities, markets or investment opportunities. Technical analysis may also be used, involving the analysis of market data. Investment Managers and Investment Providers may employ one or more methods of analysis, with varying degrees of focus on certain attributes and techniques. Review and Update of Client Information Active Portfolios® is a discretionary Program that enables you to invest in actively managed portfolios comprised of mutual funds and/or ETFs. Advisory Shares are the primary share class for mutual funds offered for purchase in Active Portfolios® Accounts. Your financial advisor will review your Client Information and Signature Wealth Account’s performance and compatibility with respect to your Managed Account’s target asset allocation, risk tolerance and time horizon with you. All discretionary investment management is provided by the Signature Wealth Investment Manager, a non-affiliated third-party Advisory Service Provider that serves as the Investment Manager for all Active Portfolios® Accounts. Investment Providers deliver asset allocation and investment selection recommendations for their specific portfolio(s) to the Investment Manager. If there are changes to your Client Information, your financial advisor will inform Ameriprise Financial Services of any changes to your Client Information. Your financial advisor may also provide research and analysis regarding the target asset allocation and select model investment portfolios to you and recommend changes based on any changes to your Client Information. If there have been changes to your Client Information, your financial advisor may recommend updates your Signature Wealth Account’s target asset allocation and/or model investment portfolios. Your financial advisor will review the updated proposal with you and based on your review and acceptance, your financial advisor will then submit your updated proposal to Ameriprise Financial Services. Ameriprise Financial Services will inform and provide the Signature Wealth Investment Manager with your updated information and requested changes. The Investment Manager has discretionary authority to purchase or sell securities or make other investments for your Managed Account; however, you directly own the underlying securities in the portfolio. The Investment Manager invests your Managed Account assets in the portfolio you select with your financial advisor and is responsible for the ongoing investment management and trading of your Active Portfolios® Account, subject to any Reasonable Restrictions or other instructions you provide. Your financial advisor provides recommendations regarding which portfolio to hold in your Active Portfolios® Account. The Investment Manager—not your financial advisor or the Investment Provider—provides discretionary investment management services for your Active Portfolios® Account in accordance with your Managed Account’s target asset allocation and the portfolio you select. Ameriprise provides the Signature Wealth Investment Manager with ongoing updates of Client Information and Account information, such as updates to your Managed Account’s target asset allocation and Ameriprise Financial Services offers a variety of Active Portfolios® investments that are designed to help meet 36 your investment growth and/or income needs. TSCA Accounts are only eligible to invest in Active Diversified Portfolios® investments. You retain the right to receive any prospectuses that are delivered to the Investment Manager on request and at any time by requesting a copy from your financial advisor or by contacting us at 800.862.7919. You may also access the prospectuses for the mutual funds and ETFs held in your Active Portfolios® Account(s) via the fund family’s website. CMIA, an affiliate of Ameriprise Financial Services, is the Investment Provider of the following Active Portfolios® investments Active Accumulation Portfolios® (only available for non-qualified Accounts) and Active Risk Portfolios®. Non-qualified Active Accumulation Portfolios®, and Active Risk Portfolios® are designed to primarily invest in, and therefore favor, Columbia mutual funds managed by CMIA. The Columbia Management Asset Allocation Team determines the asset allocation at the portfolio level and selects the investments to be included in the portfolios. If you prefer to receive the information that is contained in prospectuses, please contact your financial advisor or us at the number above and we will provide them to you. In this case, Ameriprise Financial Services will deliver prospectuses for the investments held in your Active Portfolios® Account(s) directly to you in accordance with your document delivery preference. Ameriprise Financial Services and our affiliates receive greater revenue when you select a portfolio managed by CMIA than if you select another Active Portfolios® investment. In the event our master investment advisory agreement with your Investment Manager does not provide for the receipt of certain or all prospectuses on behalf of clients, you will receive such prospectuses directly. Inclusion and Management of Active Portfolios® Investment Managers The following summarizes Ameriprise Financial Services’ research, due diligence and contractual efforts in connection with the inclusion of Advisory Service Providers in the Active Portfolios® Program. Investment Manager for Active Portfolios® investments may select mutual funds and/or ETFs. In general, the selected mutual funds are among the fund families that fully participate in the Ameriprise Financial Services mutual fund program. Program participants pay cost reimbursement payments to AEIS, as described in the “Cost Reimbursement Services and Third-Party Payments” section. Review of Advisory Service Providers You may request Reasonable Restrictions on your Active Portfolios® account(s) by completing and signing the appropriate document reflecting your request. Ameriprise Financial Services and the applicable Investment Manager(s) must accept any Reasonable Restrictions before they will be binding on the Account(s). Ameriprise Financial Services conducts initial and ongoing reviews of the Investment Providers and their applicable investment strategies and investment advisory services available or utilized in Active Portfolios® investments as further described in the “Advisory Service Providers” section. From time to time, the IRG personnel will conduct searches to identify new Advisory Service Providers for Active Portfolios®. These recommendations are presented to the Oversight Committee for inclusion in Active Portfolios®. The Investment Manager will determine whether to reinvest dividends, interest and distributions received on the investments held in your Active Portfolios® Account. Where reinvestment of dividends is not allowed, dividends, interest and distributions will be deposited into your Sweep Program. Prospectus Delivery to Investment Managers In addition, IRG conducts periodic reviews of the Advisory Service Providers. These reviews are based on applicable information gathered from various sources including disclosure documents, questionnaires, portfolio performance, assets under management, personnel changes, portfolio turnover and other factors as Ameriprise Financial Services deems appropriate. Ameriprise Financial Services periodically provides information from these reviews to financial advisors servicing Active Portfolios® investments. From time to time, these reviews may also result in Ameriprise Financial Services removing an Advisory Service Provider. Prospectuses contain detailed information about the fees and expenses charged by, and the past performance of, the investments held in your Managed Account(s). With your authorization and appointment as your agent for delivery, the Investment Manager for Active Portfolios® investments will receive prospectuses on your behalf for the mutual funds and ETFs purchased in your Active Portfolios® Account(s). Information regarding your Managed Account’s holdings of, and transactions in, mutual funds and ETFs will be available on the secure site at amerprise.com and in your Ameriprise Financial statements. 37 Education and Business Standards management client of the Investment Manager. Your Investment Manager will have full discretionary authority to act on your behalf for purchases, sales and other transactions in your Active Portfolios® Account, including sales with respect to securities transferred in-kind to the account, without seeking your approval. Such transactions generally result in tax consequences in non-qualified accounts. Your Investment Manager will not have the ability to withdraw, disburse or transfer funds or securities from your Managed Account without your prior authorization. For Active Portfolios® managed by CMIA or an unaffiliated Investment Providers, review the applicable Advisory Brochure (Part 2A of the Form ADV) for additional information about the Investment Manager’s advisory services and methods of analysis. The investment advisory personnel employed by the Investment Manager must meet certain educational, business and personnel requirements. The minimum educational requirement for an individual providing investment advice is a college degree and completion of further financial service industry certification such as CFA®, Financial Industry Regulatory Authority (“FINRA”) Series 7, 63, 65 and 66 licenses, or comparable education or work experience. Ameriprise Financial Services’ due diligence personnel seek to identify, and encourage participation by, Investment Managers whose personnel have additional professional qualifications, including graduate degrees or a CFA designation. In addition, suitable work experience in the financial services industry is considered as part of an individual’s overall qualifications. Investment Manager Review of Active Portfolios® Ameriprise Financial Services’ contractual relationship with Advisory Service Provider Ongoing updates of Active Portfolios® account information, including holdings and transaction information, as well as other relevant information are made available to the Investment Manager to help monitor the Active Portfolios® investments. Each Advisory Service Provider has entered into a master investment advisory agreement with Ameriprise Financial Services, which governs the relationship and responsibilities of the respective parties. Select Separate Account Your Active Portfolios® Selection Select Separate Account is a discretionary Program in which you may own a portfolio of individual securities, SMAs, ETFs, and/or mutual funds managed by a professional Advisory Service Provider in accordance with a single investment strategy or a combination of complementary strategies. Select Separate SMA strategies generally do not offer mutual funds. Where mutual funds are offered, Advisory Shares will be offered for purchase. TSCA Accounts are not eligible to invest in Select Separate Accounts. Your financial advisor will assist you in selecting one or more Active Portfolios® investments. Your financial advisor will discuss your financial objectives and other factors such as your risk tolerance, investment objectives, and important information regarding the Investment Manager. Your financial advisor will also provide you with the applicable Active Portfolios® investment fact sheet (“Active Portfolios® investment Fact Sheet”). The Active Portfolios® investment Fact Sheet includes biographical information about the Investment Manager and investment philosophy and style information, portfolio characteristics and composite performance. Past performance is not an indication of future results. The Oversight Committee, acting on behalf of Ameriprise Financial Services, is the Investment Manager of the Select ETF Portfolios that invest in a variety of non- proprietary ETF investments in partnership with Portfolio Strategists or Asset Allocation Strategists. Composite performance information included in the Active Portfolios® investment Fact Sheet is calculated by Ameriprise Financial Services. This composite performance information is shown both gross and net of the highest annual Asset-based Fees. These composites are created quarterly on an asset and time-weighted basis using month-end net asset values and returns. Ameriprise Financial Services also offers a series of portfolios consisting of SMAs, mutual funds and ETFs in a single account called Select Strategist UMA. These portfolios are managed by a non-affiliated Investment Manager with discretionary authority to purchase or sell securities or make other investments for your Managed Account. Acceptance of your Active Portfolios® Account Ameriprise Financial Services will determine, on behalf of the Investment Manager, whether to accept or reject a prospective client and related Account based upon the Client Information. Once your Managed Account is accepted, you will become an investment Each of the Portfolio Strategists and Asset Allocation Strategists for Select ETF Portfolios, as applicable, develops asset allocation models, conducts qualitative and/or quantitative research on mutual funds and ETFs, and constructs model portfolio recommendations, as applicable, to the Oversight Committee. The Oversight 38 through this transition, Ameriprise Financial Services will notify you. Committee reviews and approves these recommendations. The Oversight Committee may remove an Advisory Service Provider from the Select ETF Portfolios Service and/or adjust an asset allocation or model portfolio as appropriate. With the aid of your financial advisor, you select the appropriate Advisory Service Provider(s) in accordance with the Client Information you provide to your financial advisor. The Advisory Service Provider, not your financial advisor, will provide you with investment management services according to the investment strategy you select and the related investment objectives. Advisory Service Providers in the service will either serve as a discretionary Investment Manager over the assets in your Managed Account(s) or as a Model Provider. Model Provider will construct a model portfolio according to a specific investment strategy. The Model Provider will be independently responsible for the investment decisions it makes for the model portfolio strategy. The Oversight Committee will have discretionary trading authority over the assets in your Managed Account(s) to implement the Model Provider’s trading instructions for the model portfolio. You may request Reasonable Restrictions on your Managed Account(s) by working with your financial advisor to complete and sign appropriate documents to reflect your restriction request(s). Ameriprise Financial Services and the applicable Investment Manager(s) must accept any Reasonable Restrictions before they will be binding on the Account(s). This creates a conflict of interest as Ameriprise Financial Services receives a higher Platform Fee for Select Separate Accounts than we receive for Signature Wealth Accounts, including the transition period when the same SMA strategy is held in both Programs. Ameriprise Financial Services addresses this conflict through a combination of disclosures and by closing any duplicative SMA strategies through the transition process described above. Additionally, the transition process does not impact the Manager Fee that compensates the Advisory Service Provider and does not affect the portion of the Asset-based Fee received by your financial advisor. However, the transition process will result, for a limited period of time, in Sponsor receiving a higher Platform Fee from impacted SMA strategies held within Select Separate Accounts than it would from the same SMA strategy invested in Signature Wealth Accounts. Beginning in the second half of 2026, Ameriprise Financial Services plans to eliminate this conflict of interest by migrating any Select Separate Account with an impacted SMA strategy from the Select Separate Account Program to the Signature Wealth Program, in accordance with the Relationship Agreement. As noted above, if your Select Separate Account SMA strategy is a part of this transition, Ameriprise Financial Services will notify you so that you may work with your financial advisor to transition your Select Separate SMA Account to the Signature Wealth Program at a date of your choosing so that you can benefit sooner from the reduced Platform Fee rate the Signature Wealth Program provides. Inclusion and Management of Advisory Service Providers The following summarizes Ameriprise Financial Services’ research, due diligence and contractual efforts in connection with the inclusion of Advisory Service Providers in the Select Separate Program. Screening and Evaluation of Advisory Service Providers Concurrent with the addition of SMA model investment portfolios to the Signature Wealth Program in late 2025, certain SMA strategies that are currently available in the Select Separate Account Program will become available in our Signature Wealth Program as our initial step to transition such SMA strategies from the Select Separate Account Program into the Signature Wealth Program. The full transition process will include the following steps: Ameriprise Financial Services will (i) first close the SMA strategy in the Select Separate Account Program to new investments prior to offering the SMA strategy in the Signature Wealth Program; (ii) generally allow pending new accounts for the SMA strategy to continue to be processed in the Select Separate Account Program; and (iii) subsequently migrate existing accounts investing in the SMA strategy from the Select Separate Account Program into the Signature Wealth Program. During this transition, if you currently hold an impacted SMA strategy in an existing Select Separate Account, the Platform Fee rate you pay is higher for your Select Separate Account than it would be if you held the same SMA strategy in the Signature Wealth Program. If your Select Separate SMA strategy will go Ameriprise Financial Services seeks to identify a range of professional Advisory Service Providers to participate in the Select Separate Account Service in order to provide clients with a choice of investment styles and corresponding risk levels. The evaluation process consists of gathering information on the Advisory Service Provider candidates from published materials, questionnaires and interviews. Screening factors are both quantitative and qualitative and include (but are not limited to): (i) management style and total assets under management; (ii) assets managed in a particular investment style; (iii) number of years the firm has managed assets; and (iv) the number and qualifications of investment professionals 39 Provider receives the Manager Fee component of the Asset-based Fees paid by clients. employed. Each evaluation factor may have a different weighting in the decision-making process. Generally, no one factor determines the outcome of any selection. Firms, including affiliates of Ameriprise Financial Services, which pass the evaluation process are subject to a structured due diligence review by IRG. Review of Advisory Service Providers Certain Advisory Service Providers may employ one or more affiliates as sub-advisers for one or more investment strategies. In these situations, the sub- adviser is subject to the same duties and obligations as the Advisory Service Provider, including adherence to the master advisory agreement with Ameriprise Financial Services, and any reasonable restrictions imposed by clients. In delegating responsibilities to a sub-adviser, an Advisory Service Provider would not be relieved of any of its duties or obligations and remains responsible for the acts and omissions of the sub- adviser as if such acts and omissions were its own. From time to time, an Advisory Service Provider’s investment strategy that is currently available through Envestnet in the Vista Separate Account Program may become available in our Select Separate Account Program. In this instance, Ameriprise Financial Services will (i) close any duplicative investment strategies in the Vista Separate Account Program to new clients prior to offering such investment strategies in the Select Separate Account Program; (ii) generally allow pending Vista Separate Account Program Accounts for existing clients, and in certain instances new clients, to continue to be processed for transition purposes; and (iii) subsequently migrate such Vista Separate Account strategies into the same investment strategy in the Select Separate Account Program. Ameriprise Financial Services conducts initial and ongoing reviews of the Investment Managers, Investment Providers, Portfolio Strategists and Asset Allocation Strategists and their applicable investment strategies and investment advisory services available or utilized in the Select Separate Program as further described in the “Advisory Service Providers” section. This review is based on applicable information gathered from various sources, including disclosure documents, annual questionnaires and other data and reports received from Advisory Service Providers. The information provided to Ameriprise Financial Services includes composite performance, assets under management, personnel changes, portfolio turnover, trading practices and placement of client trade orders. Ameriprise Financial Services may identify actual or potential concerns regarding a particular Advisory Service Provider as a result of the review and may request that the Advisory Service Provider take corrective action to address such concerns. These reviews may also result in the removal of an Advisory Service Provider from the Service. Your Selection of an Advisory Service Provider Education and Business Standards The investment advisory personnel employed by Advisory Service Providers participating in the Select Separate Account Service must meet certain educational, business and personnel requirements. You may select one or more Advisory Service Providers from the list of participating professional asset managers. Included in the participating Advisory Service Providers is Columbia Management Capital Advisers, an operating division of CMIA, an affiliate of Ameriprise Financial Services. Ameriprise Financial Services may also act as an Investment Manager within the Select Separate Account Service. If you select CMIA as an Investment Manager, Ameriprise Financial Services may receive greater revenues than if you select an unaffiliated Advisory Service Provider. Contact your financial advisor for a current list of Advisory Service Providers participating in the Select Separate Account Service. The minimum educational requirement for an individual providing investment advice is a college degree and completion of further financial service industry certifications such as the CFA, FINRA Series 7, 63, 65 and 66 licenses, or comparable education or work experience. Ameriprise Financial Services’ research personnel seek to identify, and encourage participation by, Advisory Service Providers whose personnel have additional professional qualifications, including graduate degrees or a CFA designation. In addition, suitable work experience in the financial services industry is considered as part of an individual’s overall qualifications. Ameriprise Financial Services’ Contractual Relationship with Advisory Service Providers Each Advisory Service Provider has entered into a master investment advisory agreement with Ameriprise Financial Services through which the Advisory Service To assist you in making your decision regarding the selection of an Advisory Service Provider, you will be provided with a copy of the Advisory Service Provider’s disclosure document (Part 2A of Form ADV), which includes important information regarding the Advisory Service Provider. Your financial advisor will also provide you with the Strategy Fact Sheet for the Advisory Service Provider indicating whether it serves as Investment Manager or Model Provider, and which also includes biographical information, investment philosophy and style, portfolio characteristics, composite performance 40 an Investment Manager that does not invest in ETFs or mutual funds. Methods of Analysis and may include information, if applicable, about the Portfolio Strategist or Asset Allocation Strategist. Please note that past performance is not an indication of future results. Depending on the strategy, composite performance information included on the Strategy Fact Sheet may be calculated by the Ameriprise Financial Services or the Advisory Service Provider. In nearly all cases, these composites are created quarterly on an asset and time-weighted basis using month-end market values and returns. Your financial advisor can provide you with the Strategy Fact Sheet for specific composite performance information regarding each investment strategy available. The following information applies generally to Investment Managers participating in the Select Separate Account Service. For additional information on Investment Managers, please refer to Part 2A of the applicable Investment Manager’s Form ADV. Investment Managers utilize different techniques for buying and selling securities, which are often unique to the strategies they manage. Fundamental analysis is the most common method used and typically involves the development of a thorough understanding of fundamental features of a business through analysis and interpretation of company and industry data, such as revenue, expenses, assets, liabilities, management, industry position and other factors, in order to evaluate a security. Certain Investment Managers and third-party providers of model portfolios may also use quantitative methods of analysis, which is computer-based and uses mathematical and statistical modeling to value securities, markets or investment opportunities. Technical analysis may also be used, involving the analysis of market data. Ameriprise Financial Services requires each Advisory Service Provider to meet Ameriprise Financial Services’ performance validation standards, however Ameriprise Financial Services does not review the appropriateness of the methodologies used by Advisory Service Providers to calculate the underlying historical performance information presented in the Strategy Fact Sheet, nor does Ameriprise Financial Services audit the mathematical accuracy of the Advisory Service Provider’s performance information. Ameriprise Financial Services does restate the performance after deducting the highest annual Asset-based Fee when presenting the performance on a net basis. Investment Managers may employ one or more methods of analysis, with varying degrees of focus on certain attributes and techniques. Review and Update of Client Information Review the Advisory Service Provider’s disclosure document (Part 2A of Form ADV), this Disclosure Brochure and the Strategy Fact Sheet prior to selecting an Advisory Service Provider. Limitations on Security Type Your financial advisor reviews the Investment Manager’s performance and compatibility with respect to your Select Separate Account and may also provide research and analysis regarding the Investment Manager to you. Your financial advisor will then inform Ameriprise Financial Services if any information contained in the Client Information has changed or if you wish to make any other changes with respect to the Investment Manager(s) servicing. Except as may be provided in connection with the Sweep Program, in general, participating Investment Managers may not directly invest your assets in cash equivalent securities or instruments such as money market securities, certificates of deposit, time deposits, banker’s acceptances or repurchase agreements; or options, futures or other derivative instruments; however these types of securities may be included in the underlying holdings of the mutual funds and ETFs utilized by the Investment Manager. These types of assets are also generally not accepted for deposit in connection with establishing a new Account. Where Investment Manager has discretionary authority over the assets in your Managed Account, Ameriprise Financial Services provides Investment Managers ongoing updates of Account information, including holdings and transaction information, as well as other relevant information to help them monitor these discretionary Account(s). Transferred Accounts You may wish to transfer a separately managed account (“SMA”) that you hold at another investment advisory firm to Ameriprise Financial Services. This SMA strategy may not be available in the Ameriprise Select Separate Account Service. Contact your financial advisor to discuss other appropriate alternatives. Some participating Investment Managers may use ETFs and mutual funds as a part of their investment strategy that incur a separate and additional Investment Cost for its management fee which is assessed by the fund or ETF directly and is in addition to the Asset-based Fee charged by Ameriprise Financial Services. Due to Investment Costs, the use of ETFs and mutual funds by an Investment Manager may result in clients paying more than clients utilizing 41 Managed Accounts Offered with Envestnet Asset Management, Inc. Vista Separate Account The Vista Separate Account is a discretionary investment advisory Program offered on the Envestnet platform that gives you access to a selection of SMAs in a single or multi-account investment portfolio. Contact your financial advisor for a current list of available SMAs offered in a Vista Separate Account. Your financial advisor will help you customize a portfolio that includes multiple investment styles, such as domestic and international offerings. Separate Account Program to new clients prior to offering such investment strategies in the Select Separate Account Program; (ii) generally allow pending Vista Separate Account Program Accounts for existing clients, and in certain instances new clients, to continue to be processed for transition purposes; and (iii) subsequently migrate such Vista Separate Account strategies for all clients into the same investment strategy in the Select Separate Account Program. If you have a Vista multi-account portfolio, your Vista Statement of Investment Selection will be updated to remove the migrated strategy and reallocate its designated allocation among the remaining strategies on a pro rata basis. Investor Unified Account You will directly own individual securities when investing in an SMA. Envestnet and/or the Envestnet Manager will rebalance and reallocate the individual securities within each SMA. If you invest in multiple Vista Separate Accounts within your Vista Statement of Investment Selection, (a “Vista multi-account portfolio”) you will work with your financial advisor to designate a percentage allocation for each SMA included in your total Vista multi-account portfolio. Your Vista multi-account portfolio will be rebalanced to these designated allocations when you make deposits or withdrawals. You may also request a rebalance of your Vista multi-account portfolio at any time. Such transactions generally result in tax consequences in non-qualified accounts. The Investor Unified Account is a discretionary investment advisory Program that offers clients the ability to purchase SMAs, mutual funds and ETFs in an asset allocation within a single account managed by Envestnet. Advisory Shares are the primary share class for mutual funds offered for purchase in Investor Unified Accounts. Your financial advisor will help you to select from a broad range of SMAs, eligible mutual funds and ETFs in order to customize a portfolio for you. You must select at least one SMA in order to participate in this Program. In certain limited instances an SMA that is also available for new purchases and new contributions in the Access Account Program may also be available for selection in your Investor Unified Account. Envestnet and Ameriprise Financial Services have defined various risk-based asset allocation models available in the Investor Unified Account service. With the assistance of your financial advisor, you will determine your investment objective, risk tolerance, the appropriate asset allocation and then select the specific underlying investment vehicles for the asset allocation to meet your needs. You will receive an asset allocation and a personalized proposal based on your Client Information. Envestnet provides overlay management services for Investor Unified Accounts and you directly own the underlying securities in the portfolio. Your Managed Account will generally only rebalance when you make deposits into or withdrawals from the Account, on the Account’s anniversary date, or when requested. However, if you make a change to your investment vehicle selections or asset allocation model, your Managed Account will be rebalanced to align with the appropriate asset allocation model in effect for your investment objective and risk tolerance. From time to time, an Advisory Service Provider’s investment strategy that is currently available through Envestnet in the Vista Separate Account Program may become available in our Select Separate Account Program. For Select Separate Accounts each Advisory Service Provider enters into a master investment advisory agreement with Ameriprise Financial Services, and we pay the Advisory Service Provider the Manager Fee for its investment management services. For Vista Separate Accounts that are available through Envestnet, each Advisory Service Provider enters into a sub-management agreement with Envestnet, and Envestnet pays the Advisory Service Provider directly for their investment management services. As a result, the same Advisory Service Provider may earn more or less in investment management fees from Envestnet than from Ameriprise Financial Services for the same investment strategy available in the Select Separate Account Program. Ameriprise Financial Services manages this conflict by migrating all applicable existing client assets from the Vista Separate Account Program into the Select Separate Account Program and mitigates this potential conflict of interest by disallowing any duplicative investment strategies in the Vista Separate Account Program and the Select Separate Account Program. In this instance, Ameriprise Financial Services will (i) close any duplicative investment strategies in the Vista Such rebalancing transactions generally result in tax consequences in non-qualified accounts. Your annual rebalance date will reset each time your Managed Account rebalances. Envestnet will rebalance and 42 record keeping, custody, and all clearing functions for accounts introduced by Ameriprise Financial Services. reallocate your Managed Account and each SMA that you select within the Account. Under Envestnet’s Appendix 1 of Form ADV Part 2A, the Investor Unified Account is referred to as the Unified Managed Account. Access Account Generally, Ameriprise Financial Services, your financial advisor and AEIS act as an agent when executing transactions in your Managed Account. When permissible by applicable law, and after complying with regulatory requirements, we will execute some transactions on your behalf, and in your Managed Account(s) while acting as principal for our own account (“Principal Transactions”). Fractional Shares and Principal Transactions The Access Account program is a discretionary Program that accommodates a variety of actively managed portfolios containing mutual funds and/or ETFs transferred to Ameriprise from another firm. These portfolios are managed by Envestnet and Envestnet Managers and offered on the Envestnet platform. If you currently hold an Access Account portfolio, you may add new contributions to your existing account(s). Access Account is generally a hold and service Program. In certain limited instances you may make both new purchases and new contributions into Access Account portfolios that are not otherwise available for sale. Some or all of your portfolio may temporarily move to a cash position in certain circumstances such as if there is no selling agreement in place at the time of transition to Ameriprise Financial Services. Such transactions generally result in tax consequences in non-qualified accounts. Supplementary Managed Accounts Information Brokerage Practices A fractional share is defined as less that one full share of an equity, ETF, preferred security, CEF or UIT. Fractional shares are not eligible for purchase in your Managed Account(s) however when you direct Ameriprise Financial Services to reinvest dividends of securities that transact in fractional shares into your Managed Account(s), where allowed, you are also directing us to purchase additional shares on your behalf in an amount equal to the amount of the dividend proceeds. This will generally result in us purchasing a fractional share of the applicable securities on your behalf. Fractional shares may be held in your Managed Account(s), if appropriate, but due to their nature may not be purchased or sold on an agency basis through AEIS. The liquidation of fractional shares requires us to purchase a full share and divide the share while acting as principal for our inventory account in order to pay you the proceeds of the value of the fractional share you own. By entering into the Relationship Agreement, you authorize Ameriprise Financial Services to effect fractional share Principal Transactions. AEIS and Ameriprise Financial mitigate any potential conflicts of interest in effecting fractional share Principal Transactions by acting in the best interest of our clients and neither Ameriprise Financial nor AEIS will receive any selling concession or other compensation or benefits. You will not be charged a markup or markdown in connection with fractional share Principal Transactions. Aggregated Trade Orders Ameriprise Financial Services will act in the best interest of its clients, including, but not limited to, seeking best execution on all client transactions in Managed Accounts Programs. Both AEIS and Ameriprise Financial Services have implemented various policies and procedures to address any potential conflict of interest, including but not limited to procedures regarding the suitability, supervision and best execution of securities recommended to, or purchased to or from, Ameriprise Financial Services client accounts. Brokerage services are made available through Ameriprise Financial Services. Ameriprise Financial Services and AEIS have an agreement in which Ameriprise Financial Services introduces customer accounts to AEIS on a fully disclosed basis. AEIS serves as Ameriprise Financial Services’ clearing agent in providing clearing, custody and settlement services for transactions that are executed for customers of Ameriprise Financial Services. Under certain circumstances, when Ameriprise Financial Services or your financial advisor deems a transaction to be in the best interests of you and other clients, and to the extent permitted by applicable law and regulation, Ameriprise Financial Services will instruct AEIS to aggregate multiple client orders to obtain what Ameriprise Financial Services believes will be the most favorable price and/or lower execution costs at the time of execution, as further described below. SPS Advantage Program—Fixed Income Securities Ameriprise Financial Services approves and opens accounts and accepts securities order instructions with respect to the accounts. In exchange for a fee paid by Ameriprise Financial Services, AEIS provides For fixed income securities in SPS Advantage Accounts, when you provide your financial advisor with your 43 trade order, which includes transaction costs when AEIS executes transactions in your Managed Account. consent to take time and price discretion for a given trading session, your trade order will be combined with orders for multiple clients of that financial advisor in order to buy and sell the same securities in an aggregated trade order for best execution purposes. Ameriprise Financial Services will instruct AEIS to aggregate the trade orders for the applicable securities and to buy or sell the securities in one or more aggregated trade orders. Your financial advisor will then allocate the executed trades to each individual client Account in a manner that is fair and equitable through a trade rotation or random selection methodology, including for any partially filled trade orders. When fixed income securities are aggregated for execution in SPS Advantage Accounts, you receive the average price for the aggregated trade order, meaning you may receive a higher or lower price for the applicable fixed income securities than may otherwise have been obtained. Client trade orders submitted for Accounts enrolled in the optional automatic rebalancing feature do not include fixed income securities and are not aggregated for execution. In connection the Manager Directed Programs, you will grant discretionary trading authority to place trades for securities bought or sold for your Managed Account, or brokerage discretion, to an Investment Manager (including the Signature Wealth Investment Manager or an Envestnet Manager, for applicable Accounts) or to Ameriprise Financial Services under the terms of your Relationship Agreement. In such cases, the Investment Manager or Ameriprise Financial Services is subject to an obligation to seek best execution, which is a duty to place trades with the broker-dealer or stock exchange (collectively referred to herein as the “Executing Party”) that the manager reasonably believes is capable of providing the best qualitative execution of client trade orders under the circumstances considering all relevant factors, such as execution capabilities, efficiency and responsiveness of the Executing Party, transaction costs for the trade, familiarity with the type of security to be traded, the value of any research or other services provided by the Executing Party and other relevant factors. SPS Advisor Program—Aggregate Orders The Asset-based Fee associated with each Account covers transaction costs when trades are executed by the Ameriprise Financial Services on an agency basis through AEIS; therefore, it is common for participating Investment Managers to direct transactions for your Managed Account to Ameriprise Financial Services for execution in this manner. For SPS Advisor Accounts, financial advisors generally aggregate orders of the same security for multiple clients of that financial advisor in one aggregated trade order to seek best execution. When securities are aggregated for execution, each client will receive the average share price for the aggregated trade order. As a result, the average share price you receive may be higher or lower than the price you would have received had the transaction been executed independently from the aggregated transaction. For Signature Wealth, Active Portfolios® investments, Select Strategist UMAs and Investment Providers in the Select Separate Program and Envestnet Managers that have entered into a Model Provider sub- management agreement with Envestnet, Ameriprise Financial Services will execute brokerage transactions for your Managed Account on an agency basis through our clearing agent, AEIS. Your financial advisor will then allocate the executed trades to each individual client Account in a manner that is fair and equitable through a trade rotation or random selection methodology, including for any partially filled trade orders. Adjustments may also be made to avoid a nominal allocation to client accounts. However, for Select Separate Account, Vista Separate Account and Investor Unified Account the Investment Manager or Envestnet Manager, as applicable, that you select has discretionary trading authority, or brokerage discretion, and may allocate a purchase or sale transaction for the Account to an Executing Party other than AEIS, provided the allocation is consistent with the manager’s obligation to seek best execution on the particular transaction. Financial advisors may choose not to aggregate transactions in certain circumstances, for example, client directed trading activity such as contributions, withdrawals, asset allocation changes, or investment strategy changes. Adjustments to trade aggregation and allocations may also be made by your financial advisor to take into consideration account specific investment restrictions, undesirable position size, account portfolio weightings, client tax status, client cash positions and client preferences. Manager Directed Programs When an Investment Manager directs transactions for execution with or through Executing Parties other than AEIS, these trades are referred to as “step-out trades” and the practice is referred to as “trading away.” Any additional trading costs (“Third Party Execution Fees”) incurred will be passed along to you, are included in the purchase or sale price of the transacted security and are in addition to the Asset-based Fee. Any Third- Discretionary trading in Manager Directed Programs generally requires aggregation of client trade orders for the purchase or sale of securities within a Program and clients receive the average share price for the 44 Party Execution Fees incurred may impact and reduce the investment performance of your Managed Account. However, an Investment Manager’s election to place step-out trades may allow the Investment Manager to execute client trade orders at a better purchase or sale price for the transacted security than would otherwise be obtained through AEIS and any such price improvement may contribute to the investment performance of your Managed Account. The Investment Manager’s trade rotation practices may result in transactions placed on behalf of your Managed Account receiving a more or less favorable net price for the transaction as compared to the Investment Manager’s other client accounts. Before selecting an Investment Manager for your Managed Account, you should carefully review all material related to the Investment Manager and the SMA strategy you select, including information in the Investment Manager’s disclosure document (Part 2A of Form ADV) regarding the Investment Manager’s best execution, trade aggregation and trade allocation practices, if any, as well as whether the Investment Manager may select Executing Parties that provide the Investment Manager credit toward the acquisition of research or other transaction related products and services. When an Investment Manager places a step-out trade, the transaction is generally traded from broker to broker and may be executed without any Third-Party Execution Fees. However, for many step-out trades, the Executing Party will assess a commission or transaction cost. These costs may be in excess of what other Executing Parties may have charged, including AEIS. Investment Managers that specialize in certain SMA strategies, such as those investing in fixed income, preferred, convertible or small-cap securities, will be more likely to place step-out trades due to factors the Investment Manager considers relevant in meeting its best execution obligations. Ameriprise Financial Services does not restrict an Investment Manager’s ability to trade away in SMA strategies for your Managed Account, as the Investment Manager has brokerage discretion over its client trade orders and must meet its best execution obligations with respect to transactions placed on behalf of your Managed Account. This may cause certain Investment Managers to direct most, if not all, of their trades to an Executing Party other than AEIS. Ameriprise Financial Services is not a party to step-out trades, does not participate in Executing Party selection for step-out trades and is not in a position to negotiate the price or transaction related cost(s) with the Executing Party selected by the Investment Manager in these situations. Ameriprise Financial Services has procedures in place to monitor the services, including trading practices and placement of client trade orders, provided by Investment Managers. Ameriprise Financial Services requires that Investment Managers place client trade orders in accordance with the Investment Manager’s best execution and fair trading policies and procedures as well as any trade aggregation or trade allocation policies and procedures utilized by the Investment Manager with respect to your Managed Account. In determining whether to place client trade orders with AEIS or another Executing Party an Investment Manager may consider not only the factors listed above but also the fact that transaction costs related to trades effected by Ameriprise Financial Services through AEIS are included in the Asset-based Fee. The Investment Manager may manage institutional or other client accounts that are not a part of Ameriprise Financial Services’ program. In the event the Investment Manager purchases or sells a security for all of its client accounts using a particular strategy offered by the Investment Manager, the Investment Manager may determine that it will receive more favorable execution, including better pricing and enhanced investment opportunities, if it aggregates all such client transactions into a block trade that is executed through one Executing Party. Investment Managers for fixed income SMA strategies will generally step-out all of their client trades. For other types of SMA strategies, some Investment Managers step-out most, if not all, of their client trades. Additionally, due to operational and other considerations specific to the Envestnet platform, Envestnet Managers may be more likely to place step- out trades for Accounts than Investment Managers for Select Separate Accounts. SMA strategies of Investment Managers that elect to place step-out trades may, in certain circumstances, be more costly to clients than SMA strategies of Investment Managers that elect to trade exclusively or primarily through AEIS. As discussed above, the Investment Manager’s decision to place step-out trades may reduce or may contribute to the investment performance of your Managed Account. Please ask your financial advisor for more information about the trading practices of each Investment Manager, including the average Third Party Execution Fees for step-out trades placed by the Investment Manager, and consider the impact of those costs before selecting an Investment Strategy for your Select Separate Account or your Managed Account offered with Envestnet. Alternatively, the Investment Manager may utilize a trade rotation process where one group of its client accounts may have a transaction executed before or after another group of the Investment Manager’s client accounts. 45 • Credit Risk. Credit risk is the risk that the issuer, Ameriprise Financial Services does not receive research products or services in exchange for commissions generated by transactions in client Accounts, also known as “soft dollars” or client commission practices. guarantor or borrower becomes unable or unwilling, or is perceived to be unable or unwilling, to honor its financial obligations or otherwise defaults. • Reinvestment Risk. This is the risk of having to reinvest future proceeds from investments, whether scheduled or unscheduled, at potentially lower prevailing rates. • Liquidity Risk. Liquidity risk is the risk associated with any event, circumstance, or characteristic of an investment or market that negatively impacts the ability to sell, or realize the proceeds from the sale of, an investment at a desirable time or price. Ameriprise Financial Services receives and distributes research authored by its affiliate AEIS; however, this research is not provided in exchange for any type of compensation to AEIS. Nor do we or our affiliates receive client referrals from broker- dealers or third parties that are considered in selecting or recommending broker- dealers. See the “Broker- dealer” subsection in the “Other Financial Industry Activities and Affiliations” section of this Disclosure Brochure for more information about the brokerage business of Ameriprise Financial Services and its affiliates. • Investment and Market Risk You should understand that: • All investments involve risk of loss and you should be prepared to bear such a loss (the amount of which may vary significantly), • Foreign Investments and Currency Risk. Investments in or exposure to foreign investments involve certain risks not associated with US investments. Foreign investments are subject to the risks including, but not limited to, political, economic, market, regulatory and others within a particular country or region, as well as currency fluctuations and less stringent financial and accounting standards. Risks are enhanced for emerging market. Investment performance in any products referenced in this Disclosure Brochure can never be predicted or guaranteed, • • Tax Risk. This is the risk that the tax treatment of certain investments and of the income and gain therefrom is uncertain and can vary over time. The market value of a Managed Account will fluctuate due to market conditions and other factors such as liquidity and volatility, • • There is no guarantee that a mutual fund or Managed Account will meet its objective, Legal and Regulatory Risk. This is the risk that new or revised laws or regulations may adversely affect investments and programs. • Past performance does not predict future performance with respect to any Managed Account described in this Disclosure Brochure, • All trading in your Managed Account will be at your risk. • Operational Risk. Operational risks can include risks of loss arising from operational failures including but not limited to failures in internal processes, people, or systems, or from external events, including those resulting from the mistakes of third parties. • Business Disruption Risk. This is the risk of The Risks of Investing in the Programs Include, but are not Limited to the Following: • Market Risk. Market risk refers to the possibility that the market values of securities or other investments will fall, sometimes rapidly or unpredictably, or fail to rise, because of a variety of actual or perceived factors affecting issuer, industry or sector in which it operates or the market as a whole. • business disruption of varying severity and scope occurring. The types of disruption may include, but not be limited to, firm-only disruption, disruption that affects a single building, a disruption that affects the entire city or business district, and disruption that affects the entire region. Please read more in Ameriprise Financials’ Business Continuity Plan Disclosure and Ameriprise Financial Client Relationship Guide. Interest Rate Risk. The interest rate risk is the risk that investment value is sensitive to changes in interest rates. In general, a rise in interest rates may result in a price decline of fixed-income instruments. This risk may be heightened for longer maturity and duration instruments. • Cybersecurity Risk. With the use of technologies such as internet to conduct business, businesses are susceptible to cybersecurity breaches, please read more at https://www.ameriprise.com/ privacy-security-fraud. • • Technology Risk. Businesses must rely in part on digital and network technologies to conduct Inflation Risk. Inflation risk is the uncertainty over the future value of an investment due to inflation. Investments may not keep pace with inflation, which may result in losses. 46 business, provide services and maintain business operations. These technology systems may fail to operate properly or become disabled as a result of events or circumstances wholly or partly beyond control. Technology failures, whether deliberate or not, could have a material adverse effect and could result in, among other things, financial loss, reputational damage, regulatory penalties or the inability to conduct business. intended for all investors. Clients who choose to follow high-risk strategies should know that there is the possibility of significant losses up to and including the possibility of the loss of all assets placed in the strategies. Clients investing in high-risk strategies should be prepared to bear this loss. It is strongly recommended that you diversify your investments and do not place all of your investments in high-risk investment strategies. • Business Risk. This risk is associated with a particular industry or a particular company within an industry. • Management Risk. The risk refers to the risk of the situation in which the company and shareholders would have been better off without the choices made by management. • Concentration Risk. This risk refers to Any firm, whether Ameriprise Financial Services and its affiliates or a non-affiliated Advisory Service Provider, that has discretionary authority over client assets may be limited in its investment activities due to ownership restrictions imposed by an issuer (i.e., a legal entity that sells common stock shares to the general public) or a regulatory agency. These ownership restrictions are based upon the level of beneficial ownership in a security. For purposes of determining whether a particular ownership limit has been reached, a firm may be required to aggregate holdings across an entire group of affiliated companies, meaning that all shares held on a discretionary basis for the account of the firm and its affiliates or for the benefit of their respective clients are taken into account for purposes of determining the maximum amount that may be held under the ownership restrictions. undiversified or concentrated investments. When assets are invested in a small number of issuers, specific asset type or overly exposed to particular sectors, industries or geographic regions that may create more vulnerability to unfavorable developments in these issuers, asset type, sectors, industries or geographic regions and greater risk of loss than those that are invested more broadly. • Margin Risk. Margin borrowing has specific risks outlined in the Margin Risk Disclosure document, review that document for more information. • Pledging Assets Risk. Pledging assets to secure loan involves additional risks, please read more in the Pledging Assets Section of Disclosure Brochure. • Ameriprise Financial Services and its affiliates, including CMIA, are subject to the limitations referenced above. As a result, you may be limited or prevented from acquiring securities of an issuer that Ameriprise Financial Services, CMIA or your financial advisor may otherwise prefer to purchase in your Managed Account if Ameriprise Financial Services or your financial advisor has discretionary authority. These limitations apply to certain Active Portfolios® investments, Select ETF Portfolios and SPS Advisor Accounts. Leverage Risk. Leverage occurs when assets available for investment are increased by using borrowings, short sales, derivatives, or similar instruments or techniques. The use of leverage allows for investment exposure in excess of net assets, thereby magnifying volatility of returns and risk of loss. The risks described above should not be considered to be an exhaustive list of all the risks which clients should consider. For further information about various risks, please refer to the applicable prospectus or other investment product offering documents, as well as the Advisory Service Provider’s disclosure document (Part 2A of Form ADV) and the Strategy Fact Sheet, the Ameriprise Financial Client Relationship Guide, and any applicable risk acknowledgement forms. It is possible that these ownership limitations could cause performance dispersion among Accounts of clients who have chosen the same investment strategy. For example, if purchases in an issuer are restricted due to ownership limits, Ameriprise Financial Services or a financial advisor would not be able to purchase that security for client accounts even though an Advisory Service Provider may hold that security in its investment strategy or model portfolio, as applicable, and recommend it for purchase. Similarly, certain Accounts may hold fewer shares of a certain security than other Accounts following the same investment strategy depending on when purchases of that security were restricted. Some strategies may be high-risk strategies and usually have the potential for substantial returns; however, there are correspondingly significant risks involved in the strategies. Such strategies are not In addition, purchases of certain securities may be restricted from purchase by client Accounts of Ameriprise Financial Services and its affiliates for risk management reasons. 47 Sources of information Although the information and data provided by third party organizations is believed to be accurate, Ameriprise Financial Services and its financial advisors do not independently verify third party information. In general, Discretionary Managers conduct securities analysis using the services of research analysts. Among the various sources of information utilized by these research analysts and other investment management personnel may include: • information prepared by companies; Neither Ameriprise Financial Services nor its financial advisors guarantee the accuracy, completeness or timeliness of any such information nor do they imply any warranty of any kind regarding the information provided. • meetings with outside analysts; • informational interviews at corporations; Third Party Research Provider Materials Not Approved for Use with Clients • corporate rating services; • financial and industry trade publications; • • research materials prepared by a wide variety of financial services sources; and economic reports and government services. From time to time, financial advisors may access research, models, investment tools or other material from third party research providers that are not approved for use with clients rather are for the purposes of the financial advisor’s general education, staying current on industry trends or developing potential investment ideas. Financial advisors may provide clients with general market commentary or non- security information once the individual pieces have been approved for use by Ameriprise Financial Services. Death of a Managed Account Holder In the Signature Wealth Program, the Signature Wealth Investment Providers will utilize Sources of Information made available to them from Ameriprise Financial Services to assist them in the support of the Signature Wealth Program. The source of the information provided is Ameriprise Financial Services and is specific to the administration and operational support of the Signature Wealth Program. In addition, Ameriprise Financial Services will make available certain Signature Wealth Investment Provider information to all Signature Wealth Investment Providers. Except for the extent such information is ultimately provided by Ameriprise Financial Services, the information and data provided by the third-party organizations is believed to be accurate, Ameriprise Financial Services and its financial advisors do not independently verify third party information. In addition, for mutual funds, mutual fund analysts may also use the following sources of information: • conferences with mutual fund advisors; • mutual fund rating and performance services; • • For Signature Wealth Accounts, when Ameriprise Financial Services receives notice that the owner of an individual Account has died, Ameriprise Financial Services will freeze the Signature Wealth Account(s), prorate the Asset-based Fee based on the period of time during the billing period the Account was open and rebate any unused portion of the Asset- based Fee, and will then close the Signature Wealth Account and transfer the Account, and transfer the positions in-kind to a restricted SPS Advantage Account and await instructions from the executor or designated administrator of the deceased’s estate. If the beneficiary wants to establish a new Signature Wealth Account, Ameriprise Financial Services must receive the necessary Account opening documents, including a newly executed Relationship Agreement and related documentation including a new Signature Wealth Proposal. • • asset allocation tools; training and marketing materials; prospectuses and annual reports for the investment; product materials (some of which are created by Ameriprise Financial Services or affiliates); and • market commentary (some of which may be provided by Ameriprise Financial Services’ affiliates). For all other Programs, when the Ameriprise Financial Services receives notice that the account holder of an individual Account has died, Ameriprise Financial Services will freeze the Account(s), prorate the Asset- based Fee based on the period of time during the billing period the Account was open and rebate any unused portion of the Asset- based Fee, and will await instructions from the executor or designated administrator of the deceased’s estate. Ameriprise Financial Services is not responsible for taking any action with respect to such Accounts prior to its receipt of appropriate instructions, which means that Ameriprise Financial Services will not take action in response to market fluctuations or other factors that may adversely impact the market value of any Account. Your financial advisor may utilize research produced by Ameriprise Financial Services or its affiliates, such as material prepared by the IRG, or from third party research providers that have been approved by Ameriprise Financial Services when providing investment advice within a Managed Account. Our affiliates may have views and opinions, or may make research available, that differs from that of the IRG or your financial advisor. 48 Upon receipt of appropriate instructions, an Account will be created to hold each beneficiary’s portion. If the beneficiary wants to maintain an active Account, Ameriprise Financial Services must receive the necessary Account opening documents, including a newly executed Relationship Agreement and related documentation. the purchase is in a qualified Managed Account. Gain/loss information may be available on your Managed Account statements and/or by accessing your Managed Account through ameriprise.com. Wash sales may not always be reported as such in your Managed Account statement, as reporting is required only if the exchange is for the exact same security. You should work with your tax advisor to determine the appropriate tax treatment. In the event that Ameriprise Financial Services receives notice that an account holder of an Account held in some form of joint ownership has died, additional conditions will apply to continue the enrollment and any related management of the Account. Tax Consequences For certain non-covered securities, you are encouraged to provide your Ameriprise financial advisor with the correct cost basis information for any assets that are transferred into your Managed Account. Please contact your financial advisor to determine whether you hold any non-covered securities. You should discuss with your financial advisor whether you want to initiate any tax- related transactions, such as tax loss harvesting. Payment of an Asset-based Fee may produce accounting, bookkeeping and/or income tax results that are different from those resulting from the payment of securities transaction-based commissions or other charges on a transaction-by transaction basis. The tax treatment of the fee may differ if some, or all of the investment is in tax- exempt municipal bonds or bond funds. We will provide you with certain legally required tax documents in connection with your Managed Account. You may also receive other tax related information from time to time. You should understand that neither Ameriprise Financial Services, your financial advisor nor any Discretionary Manager provides tax advice. Clients seeking tax advice are urged to seek the advice of a professional tax advisor. You will be responsible for any tax liabilities associated with your Managed Account. We may be legally required to withhold US tax from certain payments, for example, if you fail to provide a certified taxpayer identification number. Certain investment income, such as dividends on foreign equities, may incur foreign withholding taxes that may or may not be recoverable. Special Considerations for Retirement Accounts There may be tax consequences associated with transactions, including rebalancing, in your non- qualified Managed Account, such as capital gains or losses. These transactions are generally reflected on your Managed Account statements and include activities such as you selling or redeeming securities for the purpose of establishing a Managed Account or your Discretionary Manager exercising investment discretion within your discretionary Managed Account to sell all or a portion of the securities. There may be other taxable income, for example, dividends or interest. Mutual funds and ETFs may make capital gain distributions of net long- term gains in the fund. Purchasing fund shares shortly before a dividend, also known as “buying a dividend,” may raise tax costs as you will effectively receive part of your dividend price back as the distribution, resulting in inefficient tax consequences. Unless you are a tax-exempt investor or holding fund shares through a tax-advantaged account (such as a 401(k) plan or IRA), you should consider avoiding buying fund shares shortly before the Fund makes a distribution. For IRAs and other tax- qualified retirement accounts, transactions that occur within the account generally do not generate taxable income although the purchase, sale or holding of certain investments such as master limited partnerships can. See “Your Guide to IRAs” (available on Ameriprise.com or from your financial advisor) for possible tax consequence of IRA distributions. Your financial advisor may discuss, present or offer ideas for you to consider related to the allocation of retirement assets among one or more Managed Accounts. Such communications are offered as education, marketing and examples of the potential uses of these Managed Accounts for purposes of discussion and for your independent consideration, and should not be viewed, construed or relied upon, as investment or fiduciary recommendations or advice under ERISA or Section 4975 of the Internal Revenue Code of 1986, as amended (the “Internal Revenue Code”). Additionally, if in connection with discussing, presenting or offering particular Managed Accounts to you, we provide you with a sample or proposed asset allocation, including one that identifies specific You should also be aware that you may need to make estimated tax payments periodically during the year due to income generated in the non-qualified account, including: interest, dividends, and net capital gains from securities sales. There is also the potential for losses to be disallowed under the “wash sale” rules. A wash sale typically occurs when you sell or trade a stock or security at a loss, and within 30 days before or after the sale, you: (i) buy substantially identical stock or securities, (ii) acquire substantially identical stock or securities in a fully taxable exchange, or (iii) acquire a contract or option to buy substantially identical stock or securities. The wash sale rules also apply to sales in a non-qualified Managed Account and 49 investments. Any fees you pay reduce the overall value of and net performance of your Managed Account. Fee Information for Each Advisory Solution Program The Asset-based Fee is comprised of the total of (1) a negotiable Advisory Fee of up to a maximum annual rate of 2.0%; (2) a Platform Fee rate that varies by Program; and (3) any applicable Manager Fee. The Advisory Fee and the Platform Fee applies to each Managed Account in a Program and the Manager Fee applies to the Select Separate Account Program, Vista Separate Account Program, Investor Unified Account Program, the Access Account Program, and SMA investment portfolios within the Signature Wealth Program. securities or other investments, such asset allocation is merely an example of, or proposal for, the fiduciary advice and recommendations that may potentially be made available through the Managed Account once you decide to enroll in the Managed Account and should not be relied upon as investment or fiduciary advice or a recommendation under ERISA or the Internal Revenue Code. We are not acting as a fiduciary under ERISA or the Internal Revenue Code when you decide to engage us for a new service, including with respect to your decision, or the decision of a plan participant, to roll over assets to an Ameriprise IRA. Similarly, we are not acting as a fiduciary under ERISA or the Internal Revenue Code when you decide to move assets from one type of account held at Ameriprise Financial Services to another type of account (e.g., moving assets from an Ameriprise brokerage account to a Managed Account). Ameriprise Financial Services and its financial advisors may be subject to limitations with respect to the revenue they receive in connection with Accounts of retirement or other tax-favored savings plans. In addition to your Asset-based Fee, for SPS Advisor Accounts, Ameriprise Financial Services assesses a quarterly asset-based Investments and Infrastructure Support Fee of 0.03% of the total advisory assets in your Managed Account. Our affiliate AEIS credits to clients all sub- transfer agency fees and networking fees AEIS receives for SPS Advisor Accounts from mutual fund firms. This Investments and Infrastructure Support Credit may be more or less than the Investments and Infrastructure Support Fee. Annual Fee Rate Fee Component Applicable Program(s) 2.0% Retirement account clients are not permitted to open or maintain a margin account with AEIS or any other broker or dealer for the purposes of effecting Managed Account transactions on margin. Retirement account clients are also precluded from pledging assets held in a Managed Account. For additional information regarding special considerations that may apply to retirement accounts, please refer to the Relationship Agreement. Maximum Advisory Fee All Managed Accounts Programs Platform Fee 0.17% Select Separate Account, Vista Separate Account, Investor Unified Account, and Access Account Programs Covered family members of Ameriprise financial advisors are able to purchase investment products in their Ameriprise brokerage retirement accounts at a lower commission rate and receive a rebate of the applicable 12b-1 fees, as well as a waiver of any transaction charges paid by your financial advisor. Ameriprise financial advisors who provide advisory services to covered family members will not receive any portion of the Advisory Fees paid on these Managed Account retirement accounts, unless the Asset-based Fee is paid from a nonqualified account via an alternative fee billing arrangement. Please contact your financial advisor if you have questions as to whether you’re a covered family member of an Ameriprise financial advisor. Fees and Compensation SPS Advisor, Signature Wealth and Active Portfolios Programs Ranges from 0.02% - 0.05% based on advisory household assets under management (“AUM”).* * Asset tier ranges and rates are set forth in Section 9 of the Relationship Agreement. 0.02% SPS Advantage Program The total cost to you of a Managed Account will include (1) the Asset-based Fee, which includes any investment management fees charged by Advisory Service Providers for SMA strategies; (2) for SPS Advisor Accounts, the Investments and Infrastructure Support Fee; (3) Investment Costs; and (4) Additional Fees and Expenses which are any additional transaction related fees that may be incurred in connection with your Managed Account based on the nature of your 50 Manager Fee Generally ranges from 0.10% to 0.80% Managed Account such as asset allocation, portfolio construction, creation of model portfolios, investment recommendations and selection including applicable investment product due diligence, execution of transactions through our affiliated clearing agent, AEIS, custody of securities, and tax and account reporting including trade confirmations and client statements and services provided by your financial advisor for your Managed Account. The Advisory Fee you pay is shared between Ameriprise Financial Services and your financial advisor and discussed in further detail in the Financial Advisor – Advisory Fee” sub- section under the “Financial Advisors Compensation & Benefits “ section. o Ameriprise Financial Planning Service Fee. Select Separate Account, Vista Separate Account, Investor Unified Account, Access Account Program, and SMA investment portfolios within the Signature Wealth Program. SPS Advisor Program If you choose to pay for your Ameriprise Financial Planning Service (“AFPS”) through the consolidated advisory fee service a portion of your Asset-based Fee is allocated to cover the financial planning services you receive (“AFPS Fee”). The AFPS Fee rate is negotiated with your financial advisor, however the sum of the Advisory Fee and the AFPS Fee cannot exceed 2%. The level of the Advisory Fee you negotiate with your financial advisor will depend upon a number of factors including: • • • total assets in your Managed Account the service level of your Managed Account type of strategy employed Investments and Infrastructure Support Fee and Investments and Infrastructure Support Credit 0.03% AEIS credits to clients all sub-transfer agency fees and networking fees it receives for SPS Advisor fund firms. fees and networking fees it receives for SPS Advisor Accounts from mutual fund firms. Because the Advisory Fee component of the Asset- based Fee is negotiable, client Asset-based Fees may vary. Accordingly, you may pay a higher or lower Asset based Fee than a similarly situated client due to factors such as account value, types of investment products, investment strategy, trading activity and the range of services received. For example, you may pay more or less than another client invested in the same particular investment strategy with a higher or lower account value than your Managed Account. This means you may pay more than a similarly- situated client with a lower account balance who is receiving the same services. Based on the Program you select, the components of your Asset-based Fee will vary. The fee components will be displayed to you when open a new Managed Account or make changes to an existing Managed Account that result in a change to one or more components of your Asset-based Fee. You may also request current fee rates from your financial advisor. Each possible component that may apply to you is further described below. • Advisory Fee. The Advisory Fee rate is an ongoing asset-based fee negotiated between you and your financial advisor. It is part of the overall Asset- based Fee calculated for you on a monthly basis. The Advisory Fee is based in part on the total value of the assets in your Managed Account(s) at Ameriprise Financial Services (“Advisory Tiers”). There are minimum Advisory fee rates that vary based on this total value. The Advisory Fee covers services provided by your financial advisor for your • Platform Fee. The Platform Fee rate is part of the overall Asset-based Fee calculated for you on a monthly basis. For Programs that charge a Platform Fee rate within a range, the effective Platform Fee is based on the advisory household AUM. o For discretionary programs, e.g., SPS Advisor, Signature Wealth, Active Portfolios, Select Separate Account, Vista Separate Account, Investor Unified Account, and Access Account Programs, the Platform Fee covers additional costs associated with these Programs for services provided by Ameriprise Financial 51 In calculating the Blended Fee Rate, assets without a Manager Fee (such as mutual funds, ETFs, uninvested cash, and securities) are assigned a 0% rate, while SMA assets use the applicable Manager Fee based on their respective allocations. Services such as advisory service provider due diligence and oversight, investment selection including initial and ongoing investment strategy due diligence (Manager Directed Programs only), investment product due diligence, overlay management, additional trading costs, enhanced proposal and trading tools (as applicable by Program), reporting (e.g. manager and portfolio reports), advisory training and expert support, platform management (e.g. ongoing product development and administration) and additional operational and support related functions. o For non-discretionary programs, e.g., SPS Advantage, the Platform Fee covers additional costs associated with non-discretionary program services provided by Ameriprise Financial Services such as advisory training and expert support, platform management (e.g. ongoing product development and administration) and additional operational and support-related functions. • Manager Fee. The Manager Fee represents For Select Strategist UMA Managed Accounts, the initial Blended Fee Rate will be calculated based on the percentage of the Managed Account targeted to each SMA on the date your Managed Account is accepted. Thereafter, the Blended Fee Rate will be calculated on the net asset value of the actual allocation within each SMA on the last business day of each month. Investor Unified Account Managed Accounts calculate the Blended Fee Rate using the net asset value of the allocation within each SMA. For Signature Wealth Managed Accounts the initial and first monthly Blended Fee Rate will be calculated based on the percentage of the Managed Account targeted to each model investment portfolio at the time your Account is accepted. This is to allow the Investment Manager adequate time to fully invest into the model investment portfolios. Thereafter, the Blended Fee Rate will be calculated based on the actual asset value of each model investment portfolio, on the last business day of each month. investment management fees charged by Advisory Service Providers for a specific SMA investment strategy. The Manager Fee rate is variable by Advisory Service Provider and specific investment strategy and is charged to you as a component of your Asset-based Fee. Manager Fee rates are subject to change. Because each SMA may be subject to different fees, your Blended Fee Rate will change depending on a variety of factors, including the value of the assets in each sub- account, market movements, your contributions and withdrawals, any changes to your allocation or the selection of a new SMA strategy. As a result, the Blended Fee Rate may be more or less than the Blended Fee Rate originally shown in the confirmation of your new Account. Investments and Infrastructure Fee for SPS Advisor Accounts. The Manager Fee also applies to SMA investment portfolios within Signature Wealth. Other Signature Wealth Investment Providers generally earn compensation through management fees, or Investment Costs, associated with proprietary mutual funds and ETFs used in the investment models recommended. The Asset-based Fees for Programs that offer SMA strategies range higher than Programs that do not offer SMA strategies in order to cover the fees paid to Advisory Service Provider(s) for services provided to your Managed Account. As of the date of this Disclosure Brochure, the fee rates for SMA strategies generally range from 0.10% to 0.80% per annum of the market value of the assets invested in each SMA strategy. More information regarding the investment management fees charged by a particular Advisory Service Provider for its SMA strategies is contained in its disclosure document (Part 2A of Form ADV). For SPS Advisor Accounts, Ameriprise Financial Services assesses an annual asset-based Investments and Infrastructure Support Fee of 0.03% of the total advisory assets in your Managed Account. The Investments and Infrastructure Support Fee is assessed quarterly and calculated based on the closing market value of your Managed Account as of the last business day of the calendar quarter. If you do not have an SPS Advisor Account balance as of the last business day of the calendar quarter, you will not be assessed the Investments and Infrastructure Support Fee. You will be charged an Investments and Infrastructure Support Fee for the entire calendar quarter if you have an SPS Advisor Account balance on the last business day of the calendar quarter (i.e., no proration). The Investments and Infrastructure Support Fee is in addition to your Asset-based Fee and helps support the cost of maintaining and servicing the SPS Advisor Program. For Select Strategist UMA, Investor Unified Account, and Signature Wealth Managed Accounts each underlying SMA investment strategy may be subject to a different Manager Fee rate. The Manager Fee rate for these Managed Accounts is assessed as a blended rate (the “Blended Fee Rate”), calculated using the full billable value of the Managed Account. 52 considered miscellaneous income for tax reporting purposes. For Accounts with alternative fee billing arrangements, the entire Investments and Infrastructure Support Credit will be considered miscellaneous income if the originating Account is a non-qualified Account. Account holders receiving aggregate miscellaneous income of $600 or more annually will receive an IRS Form 1099-MISC, Miscellaneous Income, from AEIS. Account holders receiving miscellaneous income amounts under $600 annually generally will not receive an IRS Form 1099- MISC from AEIS, but will be responsible for reporting the income to the IRS. Holders of IRAs and qualified retirement plan Accounts will not experience a taxable event as a result of a rebate and will instead be taxed only on amounts when they are distributed from the Account. Householding of Account Assets and Minimum Asset- based Fee. For SPS Advisor Accounts, Ameriprise Financial Services causes its affiliate, AEIS, to credit to clients all sub- transfer agency fees and networking fees AEIS receives from mutual funds firms. This Investments and Infrastructure Support Credit is calculated on a proportionate basis based on the revenues earned over the course of the applicable calendar quarter, divided by SPS Advisor Account assets as of the closing market value of each client’s SPS Advisor Account(s) as of the last business day of the calendar quarter. Clients who do not have an Account balance as of the last business day of the calendar quarter will not be eligible to receive the Investments and Infrastructure Support Credit. Clients who open an Account during the calendar quarter will receive a full credit (i.e., no proration) if they have an SPS Advisor Managed Account balance on the last business day of the calendar quarter. The Investments and Infrastructure Support Credit will be allocated without regard to the value of mutual fund positions held in any particular client’s SPS Advisor Account. Although Ameriprise Financial Services intends to credit these sub-transfer agency fees and networking fees back to clients, AEIS reserves the right, in its discretion, to cease to collect these sub-transfer agency fees and networking fees at any time and, accordingly, cease crediting client Accounts. The Asset-based Fee provides householding benefits across all Programs and Managed Accounts (“Advisory Fee Householding”). By default, a primary household will consist of a client, their spouse or domestic partner, unmarried children under the age of 21, and accounts owned by these people, which are displayed under one Group ID on your client statement. If you have more than one Group ID, you may be able to link the Group ID associated with your primary household group to the Group ID associated with an additional household group with which you have an eligible affiliation, such as the grantor of an irrevocable trust or owner of a corporation. Household minimums are assessed across all Managed Accounts within a household and the minimum Asset-based Fee for a household is $100. Households charged the minimum annual Asset-based Fee amount may exceed the maximum Asset-based Fee percentage otherwise applicable to your Managed Account(s). Households with less than a $3,333 balance will be charged an effective Asset-based Fee in excess of 3%. If your effective Asset- based Fee exceeds 3%, Managed Accounts may not be the most cost-effective investment vehicle for you; similar products and services may be available at a lower overall fee through another investment program. A pro- rata portion of this minimum fee is assessed each billing period. The Investments and Infrastructure Support Fee and Investments and Infrastructure Support Credit apply at the same rate for each SPS Advisor Managed Account regardless of how many mutual fund positions, if any, are held in the Managed Account. Ameriprise Financial Services intends to fund, in whole or in part, the Investments and Infrastructure Support Credit from sub- transfer agency fees and networking fees its affiliate collects from mutual fund companies for the mutual fund accounting, recordkeeping, tax reporting and other shareholder services related to the mutual funds held in all SPS Advisor Accounts. As a result, the Investments and Infrastructure Support Credit will generally offset the cost of the Investments and Infrastructure Support Fee. However, changing circumstances, such as a shift at the Program level away from investments in mutual funds into individual securities, ETFs or other investment products, could cause the credit to be less than the Investments and Infrastructure Support Fee and may impact the costs associated with your SPS Advisor Account. The Investments and Infrastructure Support Credit may also be more than the Investments and Infrastructure Support Fee. Each quarterly fee and credit is displayed on your statement for the following month. For example, December’s fee and credit will appear on your January statement. In circumstances where the Investments and Infrastructure Support Credit exceeds the Investments and Infrastructure Support Fees paid from your nonqualified account, the excess will be Where eligible, Advisory Fee Householding allows you to combine Managed Account assets across multiple household groups, which may help you qualify for a lower minimum Advisory Fee rate, or, if applicable, to qualify for the household minimum Asset-based Fee across all Managed Accounts in the linked households. Generally, pension and group retirement plans are not eligible to be linked for Advisory Fee Householding. Due to the timing of Account processing, when a new Account is created, funded and billed on the last 53 business day of the billing period, such new Account may not be included in your household assets for that billing period. In addition to your client statement, you can also find your Group ID online if you’re registered on the secure site at ameriprise.com. Contact your financial advisor to review whether your Group IDs are eligible to be linked for Advisory Fee Householding benefits. You may also call 800.862.7919 to review your Group IDs and householding eligibility. any such changes, with the exceptions of (i) changes to your Platform Fee rate for SPS Advisor, Signature Wealth and Active Portfolios Accounts which varies over time based on your household advisory AUM; and (ii) changes to your Blended Fee Rate for the Manager Fee charged to Select Strategist UMA Managed Accounts and Investor Unified Managed Accounts. You authorize Ameriprise Financial Services to apply future changes to the fee components by continuing to accept the Service. Billing Methodology Your Asset-based Fee is deducted directly from your Managed Account and paid from cash available in your Sweep Program unless your Asset-based Fee is paid via an alternate fee billing arrangement. The Advisory Fee that you negotiate with your financial advisor for a specific Account will increase if your total advisory assets fall below the minimum for your Advisory Tier and remain as such through any applicable grace period (a “Passive Advisory Fee Change”). If you have a Passive Advisory Fee Change, we will provide you with prior notice that your Advisory Fee rate will be increased unless you take some action. If you do not take any action, we will confirm the new Advisory Fee rate once it is effective. Passive Advisory Fee Changes do not require your signature. The maximum change is 0.25% and your Advisory Fee will not exceed 2%. If you are in a consolidated advisory fee service, and the Passive Advisory Fee Change causes the sum of the new Advisory Fee rate and the AFPS Fee rate to exceed 2%, your AFPS Fee rate will be reduced until the sum of the Advisory Fee rate and AFPS Fee rate totals 2%. The initial Asset-based Fee is based on the market value of the Account on the opening date, except for the Platform Fee portion of SPS Advisor, Signature Wealth and Active Portfolios Accounts which is based on advisory household AUM, adjusted proportionately to reflect the number of days remaining in the initial monthly billing period. Thereafter, billing will be calculated based on the market value of the assets in the Account or advisory household AUM, as applicable, as of the last business day of the preceding monthly billing period and deducted on the 14th of each month, or if the 14th is a weekend or holiday, the fee deducts the following business day. In the event a Managed Account is terminated, Ameriprise Financial Services will prorate the Asset- based Fee based on the period of time during the billing period the Account was open and rebate any unused portion of the Asset-based Fee. When you establish your Relationship, you negotiate the highest Advisory Fee that you agree could apply to an Account opened under the Relationship without obtaining an additional signature (the “Negotiated Advisory Fee”). If you are engaged in a consolidated advisory fee service, the Negotiated Advisory Fee includes your AFPS Fee. You may choose a Negotiated Advisory Fee rate for each specific Program offered by Ameriprise Financial Services or you may negotiate one rate that will apply at the Relationship level and consistently across all Programs offered. Your Negotiated Advisory Fee rate(s) may be lower than or up to 2% but may not exceed 2% for any individual Account at any time. Your signature is required for any increase to your Negotiated Advisory Fee rate(s). For SPS Advisor, Signature Wealth and Active Portfolios Accounts, the initial Platform Fee rate applied to your Managed Account at new Account set up will be determined by the anticipated advisory household AUM selected on your Managed Account opening paperwork. The ongoing Platform Fee rate will then be adjusted on a monthly basis based on your actual advisory household AUM. As a result, your total Asset-based Fee for each SPS Advisor, Signature Wealth and Active Portfolios Account will increase and decrease over time within the range specified in the chart above, based on the market value of your advisory AUM. Deposits into and withdrawals from your Managed Accounts will cause your advisory AUM to increase and decrease. Any such increase or decrease that changes your applicable advisory household asset tier will be effective immediately and charged as of the next applicable billing period. Changes to Fee Components The Negotiated Advisory Fee you’ve agreed to may not be the same as the (i) Advisory Fee, or (ii) sum of the Advisory Fee and AFPS Fee, if applicable, that you agree to be applied to and charged on a specific Managed Account (within the remainder of this section, the “Assessed Advisory Fee”). When establishing a Managed Account, you may agree to an Assessed Advisory Fee up to the applicable Negotiated Advisory Fee without a signature. Your signature will be required if you agree to an Assessed Advisory Fee that is higher than the applicable Negotiated Advisory Fee. Fee components are subject to change in the circumstances set forth below. Any change to an underlying fee component will change your total Asset- based Fee. We will provide you written confirmation of For an existing Managed Account, you may renegotiate the Assessed Advisory Fee with your financial advisor at 54 any time. Your financial advisor will complete the appropriate documents reflecting the new Assessed Advisory Fee. Your signature will be required if the Assessed Advisory Fee, including an APFS Fee if applicable, is higher than the applicable Negotiated Advisory Fee. Your financial advisor or Ameriprise Financial Services may, without obtaining your signature: (i) for Managed Accounts that are part of a negotiate the Advisory Fee rate with your financial advisor, move to another Program, add the consolidated advisory fee service to that Managed Account, or when processing certain ownership changes. Clients with a Grandfathered Advisory Fee will not be subject to a Passive Advisory Fee Change. Ask your financial advisor whether you have a Grandfathered Advisory Fee rate and consider this rate before re-negotiating your Advisory Fee rate or moving to another strategy. Relationship: reduce or increase your Assessed Advisory Fee up to the Negotiated Advisory Fee; or, Allocation of Asset-based Fees The Asset-based Fee paid in connection with each Managed Account you establish will be allocated to Ameriprise Financial Services, your financial advisor and if applicable, the Advisory Service Providers as follows. • (ii) for all Accounts where the Assessed Advisory Fee includes an AFPS Fee: reduce, increase, reallocate or remove the AFPS Fee associated with your Managed Account providing that the new sum of your Assessed Advisory Fee does not exceed the higher of your Managed Account’s current Assessed Advisory Fee or the applicable Negotiated Advisory Fee, if the Account is part of a Relationship. The Advisory Fee compensates Ameriprise Financial Services. A portion of the Advisory Fee and, if applicable, the AFPS Fee, is shared with your financial advisor. • The Platform Fee compensates Ameriprise Financial Services. The Platform Fee is not shared with your financial advisor. For Signature Wealth Accounts, a portion of the Platform Fee is shared with the Signature Wealth Investment Manager. The Assessed Advisory Fee change will become effective at the start of the next billing period, following the period in which the request is received and accepted by Sponsor. For each instance of a Negotiated Advisory Fee or Assessed Advisory Fee change, we will send you a confirmation, regardless of whether your signature was required. • The Manager Fee compensates the Advisory Service Provider and is not shared with Ameriprise Financial Services or your financial advisor. As of the date of this Disclosure Brochure, Manager Fee rates generally range from 0.10% to 0.80% per annum of the market value of the assets invested in each SMA strategy. More information regarding the investment management fees charged by a particular Advisory Service Provider for its SMA strategies is contained in its disclosure document (Part 2A of Form ADV). Manager Fee rates are subject to change. The Manager Fee may change if (i) your Managed Account changes Advisory Service Providers, (ii) you make changes to your investment strategy, (iii) one of your current Advisory Service Providers change their fee, or (iv) your investment strategy moves to another Program as a part of a Program reorganization. Any increase or decrease in the Manager Fee is passed along to you. For UMA accounts, the Blended Fee Rate will generally change as the allocation between the underlying SMAs changes. • Changes to the Manager Fee, including the Blended Fee Rate, do not require your signature. The SPS Advisor Investments and Infrastructure Support Fee compensates Ameriprise Financial Services and is not shared with your financial advisor. Ameriprise Financial Services. Ameriprise Financial Services retains the portion of the Advisory Fee not allocated to your financial advisor. Our portion of the Advisory Fee may be higher or lower than the portion of the Advisory Fee allocated to your financial advisor. Advisory Service Providers. Important considerations for the Manager Fee paid to Advisory Service Provider(s) you select include: Platform Fee rates are subject to change. Platform Fee rate changes do not require your signature. Platform Fee rates for SPS Advisor, Signature Wealth and Active Portfolios Accounts are subject to change within the current applicable ranges based on your advisory household AUM, as described above, and can vary over the course of your Relationship. The Platform Fee rate or the overall range(s) applicable to your Managed Account(s) may increase or decrease with notice to you. • Manager Fee rates are negotiated separately with each Advisory Service Provider. • Grandfathered Advisory Fee Rates. If you have received notice that you have a Grandfathered Advisory Fee rate, which is an Advisory Fee rate that is lower than the minimum fee rate allowed for the applicable Advisory Tier (the “Grandfathered Advisory Fee rate”), you will retain that fee rate until you re- Participating Advisory Service Providers may reimburse AEIS and AEIS may subsequently reimburse financial advisors for the costs arising from, or make payments to AEIS for participation in, client meetings or educational and training 55 meetings held with financial advisors and other personnel. pay additional fees and expenses associated with your specific Sweep Program. This section discusses each of these costs. Investment Costs of Mutual Funds. There are underlying mutual fund expenses charged to all mutual fund shareholders. Some mutual fund companies and their service providers pay AEIS a portion of the fees it receives for underlying mutual fund expenses in the form of Third-Party Payments. Any mutual fund fees or expenses you pay reduce the overall value of and net performance of your Managed Account. Important considerations: In addition to the fees described above, Ameriprise Financial Services and its affiliates retain the revenues each receives related to the investment products held in your Managed Account such as (i) Third Party Payments; and (ii) any management fees, distribution fees or compensation earned related to administrative or transfer agency fees related to affiliated mutual funds held in your Managed Account that are included in the Investment Costs paid indirectly by you and are received by our affiliates, such as CMIA. • Additional Costs Associated with a Managed Account The underlying fees related to investment products you purchase within your Managed Account are referred to as Investment Costs and are more fully described below. These costs are in addition to the Asset-based Fee that you pay directly from your Managed Account and may include Third Party Payments that are compensation to AEIS, as discussed above. They are paid by you indirectly as part of the cost of the investment and they reduce the value of your investment in the product. They are not a direct fee deducted from your Managed Account. These fees and expenses include management fees, distribution and other expenses. A mutual fund may also charge shareholder service (“12b- 1”) fees. These fees and expenses could increase the total cost of your investment in the mutual fund by 1.00% to 2.00% or more. For example, if the Asset-based Fee for your Managed Account is 1.00%, and the mutual funds in which you invest have average fees of 1.50%, the total fees will be 2.50%. As noted above, all Managed Accounts offer Advisory Shares that typically do not assess 12b-1 fees as the primary share class. To the extent that Ameriprise Financial Services receives 12b-1 fees from mutual fund companies for applicable mutual fund classes utilized in any Managed Accounts, it rebates these fees to clients. Rebates are generally deposited into the applicable client Accounts within a week after we receive the 12b-1 shareholder servicing fees. • Charges imposed by the underlying mutual funds held in your Managed Account may include short- term redemption fees and small position fees. Investment Costs apply whether the investment product is sponsored or managed by a third party or an affiliate of Ameriprise Financial Services, such as Columbia Management Investment Advisers, LLC (CMIA”), a wholly owned subsidiary of Ameriprise Financial, Inc., Ameriprise Financial Services’ parent company. When you invest in investment products managed by CMIA, CMIA or its affiliates will receive compensation for managing those investments and for other services they provide based on the amount you invest, just as they would if you invested in CMIA investment products through another service provider. • Ameriprise Financial Services and/or one or more of its affiliates may serve as the fund’s distributor, transfer agent, shareholder servicing agent, custodian and/or investment adviser. In these situations, Ameriprise Financial Services and/or its affiliates will receive payments for such services that may vary depending on the assets invested in such mutual fund. • Other mutual funds, such as fund-of-funds, also have additional management, advisory and other internal fees and expenses which are assessed by the fund directly and are in addition to the Asset- based Fee. Investment Costs received by CMIA are not compensation to Ameriprise Financial Services, however, Ameriprise Financial Services, CMIA and their affiliates receive more revenue, in aggregate, from the purchase of affiliated mutual funds or investment products offered by CMIA or their affiliates than from the purchase of investment products offered by firms that are not affiliated with Ameriprise Financial, Inc. It is your responsibility to understand all fees and charges prior to making investment decisions. Review each applicable mutual fund prospectus for details on all fund fees. In addition to your Asset-based Fee and Investment Costs, you may pay Third Party Execution Fees associated with “step-out trades” placed by an Investment Manager in an investment strategy you select in Select Separate Account or a Managed Account offered with Envestnet, as described in the “Brokerage Practices” section; and you may pay any additional fees and expenses to the extent incurred in connection with your Managed Account. You may also Third Party Payments. A portion of Investment Costs are paid to AEIS by third parties who manage, Ameriprise Financial Services or distribute investment products held in your Managed Account. This compensation helps fund the cost of providing service, 56 maintaining accounts and offering an investment platform for our clients. These payments are generally funded directly, or indirectly, from Investment Costs, as more fully discussed above. Cost reimbursement services and Third-Party Payments related to your Managed Account are further described in the “Cost Reimbursement Services and Third-Party Payments” section, including marketing and sales support payments are received from certain mutual fund firms that participate in the Full Participation Program Ameriprise Financial Services offers. AEIS will receive the following types of payments from product companies with respect to the investment model portfolios and other investment products we recommend, and you select for the investment of your Managed Account assets. For qualified SPS Advisor Accounts, inherited IRAs in qualified SPS Advantage Accounts where a trust has inherited the IRA and Ameriprise Bank acts as trustee of the trust and eligible trustee-directed retirement plans in Select Separate Accounts AEIS either does not collect Third Party Payments or credits them back to client Accounts. Third Party Payments do not include any management fees, distribution fees or compensation earned related to administrative, or transfer agency fees related to affiliated mutual funds held in your Managed Account and managed by one of our affiliates, such as CMIA. These fees are included in the Investment Costs paid indirectly by you and are received by our affiliates but are not compensation to Ameriprise Financial Services or AEIS, however they are an economic benefit to Ameriprise Financial Services and its affiliates as further discussed in the “Economic benefits of affiliates’ products and services” section. • Mutual funds – AEIS will receive cost- reimbursement payments (e.g., reimbursement for marketing support) from non-affiliated mutual fund firms for investments you make as a result of our recommendations. • Certain other investment products – AEIS will receive cost-reimbursement payments from third party investment firms whose products Ameriprise Financial Services recommends. Additional Fees and Sources of Compensation. Under certain circumstances, you may be assessed transaction related fees or charges depending on the nature of the investment products held in your Managed Account. You may also be charged fees for transactions initiated by you such as costs associated with pledge loans and interest charges when investing on margin. Any such fees and charges incurred in connection with your Managed Account are in addition to the Asset- based Fee charged to your Managed Account(s). Any additional fees you pay reduce the overall value of and net performance of your Managed Account. Examples of the types of additional fees and charges that you would pay, to the extent they are incurred in connection with your Managed Account, include: • Brokerage commissions resulting from • Other servicing and account maintenance fees – AEIS will also receive sub-transfer agency fees or networking fees with respect to investments you make in mutual funds except for inherited IRAs in qualified SPS Advantage Accounts where a trust has inherited the IRA and Ameriprise Bank acts as trustee of the trust and eligible trustee-directed retirement plans in Select Separate Accounts, as noted above. As further described above, for SPS Advisor Accounts, Ameriprise Financial Services will rebate to clients all sub- transfer agency fees or networking fees and other servicing and account maintenance fees its affiliate, AEIS, receives from mutual funds firms. transactions effected through or with a broker- dealer other than AEIS; • AEIS also receives revenues that exceed the costs • Transaction fees relating to any foreign securities other than American Depositary Receipts; • of the cost reimbursement services provided. These revenues include marketing support and distribution support payments, and such payments increase the gross revenues and net earnings of AEIS. • AEIS is responsible for delivering to clients or their The entire public offering price, including underwriting commissions or discounts, on securities purchased from an underwriter or dealer involved in a distribution of securities; • Fees related to the sale of Initial Public Offerings; and • Other costs or charges imposed by third parties, including American Depositary Receipts issuance fees and annual depository fees, voluntary reorganization fees, odd-lot differentials, transfer fees exchange fees, and other fees or taxes required by law. agent all shareholder materials (e.g. annual reports and proxies) received from the issuers of securities. It does this through a vendor. The vendor charges each issuer based on rates determined by the New York Stock Exchange. AEIS earns rebates from its vendor based on the difference between the rate charged to the issuer and the cost to the vendor to deliver the shareholder materials. The rebates are generally higher for customers who consent to utilizing electronic delivery. Review the Relationship Agreement and Ameriprise brokerage materials for a summary of the service fees 57 ameriprise.com/disclosures or call our service line at 800.862.7919. Sweep Programs Offered in Managed Accounts: • Ameriprise Insured Money Market Account (“AIMMA”) is the Sweep Program offered for SPS Advantage Accounts, except for trustee-directed 401(a) Accounts; and for non-qualified Accounts in the following Advisory Programs: SPS Advisor Accounts, Signature Wealth Accounts, Active Portfolios® Accounts, Select Separate Accounts, Vista Separate Accounts, Investor Unified Accounts, and Access Accounts. that may be charged in connection with your Managed Account(s). You should also refer to the disclosure document(s) for a description of the fees and expenses associated with any product or service that is made available in connection with the Managed Account. It is your responsibility to understand all fees, expenses and other charges prior to investing or participating in any product or service. All Investment Costs and additional fees are subject to change. Contact your financial advisor if you have any questions about the types of additional fees and expenses that may be associated with your Managed Account. • Sweep Program and Expenses Your Managed Account(s) will from time to time receive and disburse cash. Cash received can be in the form of deposits you make to your Managed Account, the proceeds from investments you sell, and the receipt of dividend and interest payments from investments you own. Ameriprise Bank Insured Sweep Account (“ABISA”) is the Sweep Program offered for SPS Advantage trustee-directed 401(a) Accounts and qualified Accounts in the following Advisory Programs: SPS Advisor Accounts, Signature Wealth, Active Portfolios® Accounts, Select Separate Accounts, Vista Separate Accounts, Investor Unified Accounts, and Access Accounts. • Either Dreyfus Government Cash Management – Institutional Shares or the Dreyfus Government Cash Management – Wealth Shares are the Sweep Program offered for TSCA/403(b) Managed Accounts and personal trust services Managed Accounts opened by Ameriprise Bank as trustee and certain other non-qualified Managed Accounts that are ineligible for an insured deposit Sweep Program. An investment in a money market fund is not a bank deposit and is not insured or guaranteed by the FDIC or any other government agency. Cash is disbursed from your Managed Account to pay for new investment products you buy, to cover check writing, debit card, ACH or bill pay activity, and to pay the Asset-based Fee and other fees you may incur. Any portion of your Managed Account balance that is held in cash will be included in the Asset-based Fee calculation. On a daily basis, Ameriprise Financial Services will move all uninvested cash into the Sweep Program applied to your Managed Account(s). The Sweep Programs may pay interest or dividends. By authorizing Ameriprise Financial Services to open a Managed Account, you expressly authorize Ameriprise Financial Services to move such cash balances. Rates and yields vary across the different Sweep Programs and maybe be higher or lower depending on the particular money market fund or interest-bearing bank deposit product, and on the cash balance you maintain in your Managed Account. Regardless of the Sweep Program made available to you, you can also buy and sell positional money market mutual funds, brokered certificates of deposit, treasury bills, and other similar cash-equivalent products to manage cash in your non-discretionary Managed Accounts and Ameriprise brokerage accounts, and such investment products may be available for you to buy and sell in certain discretionary Managed Accounts. These options for the investment of cash balances are generally expected to offer higher returns than the Sweep Program we make available for your Managed Account. Some types of investment products may not be available to you under the terms of your specific Account. If you decline the Sweep Program offered for your Managed Account(s), or if you subsequently revoke your acceptance, you may at any time direct Ameriprise Financial Services to (i) hold your Sweep Program balance as a free credit balance in your Managed Account(s); (ii) return the proceeds to your Managed Account(s) for investment in a cash equivalent investment product; or (iii) have us remit the cash to you. Cash held as a free credit balance is eligible for coverage by SIPC, up to $250,000 per capacity as determined by SIPC. Cash held as a free credit balance is not eligible for FDIC coverage. For Managed Accounts, we may earn interest or other revenue on the balance but are not obligated to pay interest on cash held as a credit balance in your Managed Account(s). More detail regarding Sweep Programs offered by Ameriprise Financial Services is available in the Other Important Brokerage Disclosures document and the Money Settlement Options section of the Ameriprise Brokerage Client Agreement. For a copy of the Other Important Brokerage Disclosures or the Ameriprise Brokerage Client Agreement, visit our website at 58 AIMMA Program Banks pay on the deposits held through AIMMA. This difference is known as “spread.” Like the unaffiliated Program Banks participating in AIMMA, Ameriprise Bank earns spread revenue when it participates in AIMMA as a Program Bank. AEIS receives and retains compensation from Program Banks for its services related to AIMMA for Advisory Solutions, based on the cash deposits held at each Program Bank. This compensation is either negotiated between each Program Bank and AEIS, or between the Program Bank and our vendor, IntraFi, and is either a fixed rate or is based on a benchmark interest rate, such as the Federal Funds Rate, plus or minus a spread. You can find up-to-date information on the revenue AEIS receives from unaffiliated Program Banks participating in AIMMA at ameriprise.com/products/ investments/brokerage-sweep-options. AIMMA is an interest-bearing multi-bank deposit product made available by Ameriprise Financial and held in an omnibus account(s) at one or more FDIC member banks (collectively, the “Program Banks”). Our affiliate, Ameriprise Bank, FSB (“Ameriprise Bank”) is a Program Bank and participates in AIMMA. The Program Banks may serve individually as custodians for all or a portion of the cash balance held within your Managed Account that are swept to AIMMA, as described in the Other Important Brokerage Disclosures document. Multibank deposit products are FDIC insured up to $250,000 per depositor ($500,000 for joint ownerships) per Program Bank, including deposits held at Ameriprise Bank. AEIS will use reasonable efforts to place deposits across multiple Program Banks to enable clients to receive up to $2.5 million per depositor ($5 million for joint ownerships) across all Program Banks combined. Ameriprise Bank does not compensate AEIS for its sweep services provided or for the cash deposits held at Ameriprise Bank, but reimburses AEIS for its direct out of pocket expenses related to AIMMA. Your financial advisor does not receive any of (i) the compensation paid by the Program Banks; or (ii) the reimbursements paid by Ameriprise Bank to AEIS. ABISA For any amount above the applicable limit that is deposited in a single Program Bank, including any other FDIC insured product you may own through that Program Bank, the amount above the limit will not be eligible for FDIC deposit insurance. Ameriprise Bank may restrict AIMMA deposits based on certain account ownership types. Deposit products are not covered by the SIPC. If your Managed Account uses AIMMA as its Sweep Program, you agree to accept the proprietary algorithm applied by IntraFi LLC (“IntraFi”), which determines the Program Banks into which your deposits are placed. You also understand and agree that IntraFi will periodically change the order of the Program Banks to optimize the amount of FDIC insurance available in the AIMMA Sweep Program. Under ordinary business conditions, changes to the Program Bank List will be published at least five business days prior to the effective date, and current interest rates for each interest rate tier will be published three to five business days prior to their effective date. The Program Banks are identified on the Program Bank List and interest rate information is available at Ameriprise.com/cashrates. ABISA is an interest-bearing single bank deposit product made available by Ameriprise Financial Services. Deposits into ABISA are held in an omnibus account(s) at Ameriprise Bank, Member FDIC, an affiliate of Ameriprise Financial. Ameriprise Bank serves as custodian for the cash balances held within Managed Accounts that are swept to ABISA, as described in the Other Important Brokerage Disclosures. Single bank deposit products are FDIC insured up to $250,000 per depositor ($500,000 for joint accounts), per FDIC rules. For any amount above the applicable limit, the amount above the limit will not be eligible for FDIC deposit insurance. Deposit products are not covered by SIPC. If your Managed Account uses ABISA as its Sweep Program, Ameriprise Bank earns spread revenue, the difference between what it pays in interest and what it earns on its investments. Ameriprise Bank does not compensate AEIS for its sweep services provided or for the cash deposits held at Ameriprise Bank, but reimburses AEIS for its direct out of pocket expenses related to ABISA. Your financial advisor does not receive any of (i) the compensation earned by Ameriprise Bank; or (ii) the reimbursements paid by Ameriprise Bank to AEIS. Money Market Fund Any cash in your Managed Account(s) that is swept to AIMMA is aggregated with cash held by other Ameriprise clients that utilize AIMMA and is held in an omnibus account at one or more Program Banks. Omnibus accounts, by virtue of their ability to raise significant balances for the Program Banks, are generally able to earn higher interest rates than those you would be able to earn if you deposited cash individually at a bank. The Program Banks participating in AIMMA earn income by lending or investing the deposits they receive and charging a higher interest rate to borrowers, or earning a higher yield, than the If your Managed Account’s Sweep Program uses a money market mutual fund, our affiliate AEIS may receive marketing support payments of up to 0.37% of the amount held in that money market mutual fund Sweep Program. Please refer to the applicable 59 prospectus or the “Cost Reimbursement Services and Third-Party Payments” sub-section for further specific details regarding mutual fund marketing and sales support payments received by AEIS. An investment in a money market fund is not a bank deposit and is not insured or guaranteed by the FDIC or any other government agency. Affiliate Compensation reserves the right to, or may instruct the custodian to, sell securities held in your Managed Account Sweep Program to cover these fees. Ameriprise Financial Services reserves the right to determine which mutual funds or other securities will be sold. Because of mutual fund redemption minimums and other applicable minimums, Ameriprise Financial Services may be required to sell more shares than is necessary to cover this amount. The proceeds of such sales will be held in your applicable Sweep Program pending deduction of the applicable fee(s). As noted above, our affiliate AEIS is compensated based on the balance held in your Sweep Program. Brokerage Accounts Sweep Programs made available in Managed Accounts are offered by Ameriprise Financial Services in its capacity as a broker-dealer, and services are provided by our affiliate AEIS as part of the overall brokerage services provided to your Managed Account(s) pursuant to the “Money Settlement Options” section of the Ameriprise Brokerage Client Agreement. Your financial advisor does not recommend the Sweep Program offered to you for any particular Account(s) and revenues received by our affiliates related to the Sweep Programs are not shared with financial advisors. Generally, the combined revenue earned by our affiliates AEIS and Ameriprise Bank is expected to be (i) the highest when your Managed Account sweeps cash into ABISA or AIMMA where Ameriprise Bank is utilized as a Program Bank; (ii) the second highest when your Managed Account sweeps cash into AIMMA where unaffiliated Program Banks are utilized; and (iii) the lowest when your Managed Account sweeps cash into an eligible money market mutual fund. Retail brokerage services are also available through Ameriprise Financial Services. If you choose to open an Ameriprise brokerage account separate from your Managed Account to purchase and sell securities, you will incur a sales commission or pay a mark-up or mark- down in connection with each transaction in that account. These transaction charges are paid to compensate Ameriprise Financial Services and your financial advisor for the assistance they provide in helping to execute those transactions. You may also incur a variety of other fees in connection with maintaining an Ameriprise brokerage account, including fees and margin loan interest. Review the account opening documents provided in connection with establishing a brokerage account for additional information. Our affiliates AEIS and Ameriprise Bank use this revenue to defray the cost of operating our Sweep Programs and the expense of providing other services to our clients, as well as for general operating expenses and to provide net earnings to AEIS and Ameriprise Bank. In the absence of this revenue Ameriprise Financial Services would likely charge higher fees or other charges to clients for the services AEIS and Ameriprise Bank provide to clients. Ameriprise Financial Services does not receive research or other products or services other than execution from any unaffiliated broker-dealer or other third party for client securities transactions. Ameriprise Financial Services receives and distributes research authored by its affiliate AEIS however this research is not provided for client securities transactions or for any other compensation. Nor do we or our affiliates receive client referrals from broker-dealers or third parties that are considered in selecting or recommending broker-dealers. Other Investment Advisory Services Ameriprise Financial Services addresses this conflict of interest through a combination of disclosures and policies and procedures regarding Sweep Program availability and the free-credit balance, as well as supervision and surveillance of cash balances held in Managed Accounts. Sweep Program Balance Requirements Your financial advisor may offer ongoing financial planning or other services that are not included in a Managed Account for additional fees. A Managed Account is not a financial planning service and clients investing solely in a Managed Account will not receive all material elements of the financial planning process. Managed Account clients are required to maintain sufficient cash balances in the Sweep Program or as a free credit balance in your Managed Account(s) to meet the applicable Asset-based Fee and, if applicable, SPS Advisor Investments and Infrastructure Support Fee deductions. If there is not sufficient cash in your Managed Account(s) Sweep Program to cover these and other applicable fees, Ameriprise Financial Services In addition to the Advisory Solutions Programs described in this Disclosure Brochure Ameriprise Financial Services offers the following advisory services for retail investors: • Ameriprise Financial Planning Service • Ameriprise Premier Retirement Income Service 60 but also provides the ability to borrow money to purchase securities. Both pledge loans and margin are available on non-qualified SPS Advantage Accounts and non-qualified Ameriprise brokerage accounts; however, you may not utilize both margin lending features and a pledge line of credit on the same Account. You also have the option to engage in the consolidated advisory fee service. The consolidated advisory fee service is a combined investment advisory service for which you will receive AFPS and at least one Managed Account Service. The fee is based on the assets in the Managed Account(s) with a portion of the fee calculated for AFPS, as described in the “Fees and Compensation” section. Any Managed Account fees are separate from and in addition to any advisory fees you pay for these additional services. Margin is available in non-qualified SPS Advantage Accounts and non-qualified Ameriprise brokerage accounts and involves the extension of credit to you and your financial exposure could exceed the value of your securities. Ameriprise Financial Services, in its sole discretion, may approve your Managed Account for margin trading. Margin lending has specific risks outlined in the Margin Risk Disclosure document which you should review before opening a margin account. A description of the advisory services listed above and the fees, compensation and other policies associated with each may be viewed online by visiting www.ameriprise.com/disclosures and expanding the sub- heading “General Disclosures” for Ameriprise Financial Planning Service and Ameriprise Premier Retirement Income Service and “Managed Account Client Disclosure Brochures” for consolidated advisory fee service. You should consider the aggregate costs and expenses of investment advisory services and products as a whole. Your financial advisor may not offer all investment advisory services or accounts. Ameriprise Financial Services also offers Ameriprise® Retirement Plan Consulting Services to employers and trustees and is designed to assist in their role as a plan fiduciary. Other Products, Services and Features Ameriprise Financial Services may allow you to pledge certain non-qualified Managed Account(s) and non- qualified Ameriprise brokerage account assets as collateral for an Ameriprise Preferred Line of Credit offered jointly and separately by Ameriprise Bank and Goldman Sachs Bank USA (collectively, “Lender”), or a pledge line of credit program from a third-party financial institution. To the extent that you pledge non- qualified assets held at Ameriprise Financial Services as collateral for a pledge loan to a third-party financial institution, you will be required to execute, and arrange for the completion and execution of, certain required documentation. Among other things, this will result in the financial institution being required to complete Ameriprise Financial Services’ form of collateralization agreement. The interest rate you may secure from a third-party financial institution may be higher or lower than the interest rate offered for an Ameriprise Preferred Line of Credit. Certain pre-existing non-qualified SPS Advantage Accounts have access to check writing, bill pay and debit card features of the Ameriprise ONE® Financial Account. Other products, services and features may be included or made available in connection with a Managed Account. When you apply for a pledge loan for your Brokerage Account(s) or Managed Account(s) you agree that such assets will be pledged to the lender as security for that line of credit. Once your Managed Account(s) are pledged, the securities and cash will serve as collateral for the line of credit. If the market value of the securities in your pledged Account(s) drops below certain levels, you may be required by the lender to pay down the loan, sell securities in the Account(s), and/or pledge additional securities. These products, services and features may have their own terms, conditions, disclosure documents, fees and expenses. Review applicable materials, and consider fees related to a particular product, service or feature prior to deciding to participate or invest in, or as you consider remaining in, that product, service or feature. Talk to your financial advisor about the applicability of any product, service or feature of a Managed Account. Securities-based Lending Solutions It is important that you understand the actions the Lender has the right to take against any account(s) that you pledge as security for an Ameriprise Preferred Line of Credit, as well as risks and restrictions associated with pledging your Managed Accounts. If the Lender feels that the security for its line of credit to you is at risk, it may take actions regarding your pledged assets Account(s) that may be disruptive to your investment objectives for your Managed Account(s) or to the existing target asset allocation such as restricting trading or reinvestment in the Account while instructions from the Lender are Each of the Ameriprise Preferred Line of Credit, Ameriprise Preferred Loan and margin loans are securities-based lending solutions made available to clients of Ameriprise Financial Services. While a pledge line of credit or loan, such as the Ameriprise Preferred Line of Credit or Ameriprise Preferred Loan, is credit extended by a financial institution such lines of credit or loans are principally used for liquidity purposes only. Margin lending is credit extended directly by AEIS and may be used for liquidity purposes 61 processed; and the Lender may impose conditions that prevent you from maintaining your existing Managed Account(s). You may need to work with your financial advisor to take other steps to maintain your Ameriprise Preferred Line of Credit. Ameriprise Financial Services reserves the right to decline your request to pledge your assets. Compensation Received by Ameriprise Financial Services and Its Affiliates When Ameriprise Bank as co-lenders receive revenue related to your Ameriprise Preferred Line of Credit and Ameriprise Preferred Loan, each of Ameriprise Bank and Goldman Sachs Bank USA receives a pro-rata portion of the revenue generated. As a result, on a comparable amount of credit extended, Ameriprise Financial Services and its affiliates generally earn higher revenues for the use of margin, and it is therefore more profitable when clients utilize margin than when using an Ameriprise Preferred Line of Credit or and Ameriprise Preferred Loan. Ameriprise Financial manages this conflict of interest by keeping the cost to you for either a negotiated rate margin loan or an Ameriprise Preferred Line of Credit and Ameriprise Preferred Loan in line with each other as described below. A margin loan is the only securities-based lending solution offered by Ameriprise Financial Services that allows you to borrow money to purchase securities. Either of the Ameriprise Preferred Line of Credit or a margin loan allows you to borrow money for liquidity purposes. Non-qualified Brokerage Accounts and non- qualified SPS Advantage Managed Accounts offer both of these securities-based lending solutions. Conflicts of Interest Related to Financial Advisors’ Recommendations Margin When used to purchase securities, any margin account balance in your non-qualified SPS Advantage Account will be included in the calculation of your Asset-based Fee for that period and is shared with your financial advisor. Our affiliate AEIS earns interest on your margin balance whether you use the money to purchase securities or for liquidity purposes. Ameriprise Preferred Line of Credit Your financial advisor does not receive compensation on your margin account balance when you borrow money for liquidity purposes but does receive ongoing compensation based on the outstanding balance of the credit line extended to you for an Ameriprise Preferred Line of Credit or Ameriprise Preferred Loan. This compensation creates a financial incentive for your financial advisor to recommend the use of the Ameriprise Preferred Line of Credit or Ameriprise Preferred Loan over margin. Ameriprise Financial manages this conflict of interest through a combination of disclosures, compensating financial advisors for the Ameriprise Preferred Line of Credit and Ameriprise Preferred Loan within a reasonable range that is non-negotiable and capped, keeping client costs for either negotiated rate margin loans, an Ameriprise Preferred Line of Credit or an Ameriprise Preferred Loan comparable and in line with each other by monitoring interest rates, and policies, procedures, training and additional resources designed to delineate the features of each product to assist financial advisors in providing recommendations that are in a client’s best interest and consider reasonably available alternatives. Account Requirements and Types of Clients Establishing and Maintaining Accounts Ameriprise Bank earns revenue based on the outstanding balance amount of the Ameriprise Preferred Line of Credit and the interest rate on the loan. Ameriprise Financial Services receives compensation from Ameriprise Bank, FSB of 0.25% of the outstanding balance on the credit line on an annualized basis. This amount is shared with your financial advisor based on how your advisor is affiliated with us and on the payout rate for which your financial advisor qualifies. This compensation is separate from the compensation your financial advisor receives for servicing your Managed Account. These affiliations and compensation structures are described in the “Financial Advisors Compensation & Benefits” section below. Ameriprise Financial and your financial advisors will continue to receive the Asset- based Fee on any pledged assets held in your Managed Account(s). Ameriprise Bank does not compensate AEIS, but reimburses AEIS for its direct out of pocket expenses related to its Ameriprise Preferred Line of Credit support. To establish an Account in one or more of the services, you will be asked to: Conflicts of Interest Related to Securities-Based Lending Solutions • Review this Disclosure Brochure; and other applicable Advisory Service Provider Form ADV Part 2A; • Provide accurate and complete information to your Conflicts of Interest Related to our Affiliated Products and Services When AEIS charges you interest on your margin balance it retains the full amount of such revenue. financial advisor to complete the Client Information and the applicable Managed Accounts application; 62 • Read and sign the application which includes the Relationship Agreement; • Read and sign the Brokerage Agreement to establish and maintain a brokerage account as part of a Managed Account; and • Select a Sweep Program as described in the Brokerage Agreement. Coverdell Savings Accounts and 529 plan accounts are not available in a Managed Account. In the event a Managed Account is terminated, Ameriprise Financial Services will prorate the Asset- based Fee and rebate any unused portion. You have the right to request that your assets be distributed in the form of cash or securities. This transaction may have tax implications. Because you will be responsible for any associated tax liabilities, you should discuss the potential implications with your tax advisor. Additional fees may apply to distributions in the form of securities as outlined in the “Sweep Program and Expenses” section. In these situations, the anticipated timing of distributions would be the same as outlined for each Managed Account Service description in the “Services, Fees and Compensation” section. Termination of Advisory Service Providers Ameriprise Financial Services may, in its sole discretion and at any time, terminate an Advisory Service Provider’s (including an Envestnet Manager’s) participation in a Managed Account, or discontinue the Advisory Service Provider’s services with respect to a particular investment strategy in accordance with the Relationship Agreement and with thirty (30) days prior written notice to you. As a result, Ameriprise Financial Services may transfer the Account assets to an Ameriprise brokerage account, and the Brokerage Agreement will govern any assets transferred including fees charged in connection with maintaining an Ameriprise brokerage account and transaction fees. Managed Accounts are available for individual investors, corporate entities, certain nonprofit organizations and tax-qualified accounts. The types of tax-qualified accounts that may be available include traditional IRAs, Roth IRAs, Simplified Employee Pension (“SEP”) IRAs, Savings Incentive Match Plan for Employees (“SIMPLE”) and defined contribution plans as defined in Section 401(a) of the Internal Revenue Code (e.g., Profit Sharing, Money Purchase). Ameriprise Financial Services, in its own discretion, may offer certain account types to certain clients. Tax-Sheltered Custodial Account (“TSCA”) may be available for TSCA participants to invest in SPS Advantage, SPS Advisor, Active Diversified Portfolios® investments and Access Separate Accounts, but may not invest in other Managed Accounts. Trustee-directed retirement plans may not invest in the Active Portfolios®, SPS Advisor, certain Select Separate Account investment strategies, Vista Separate Account, Investor Unified Account or Access Account Programs. Nonprofit organizations operating as a donor advised fund are eligible to invest in certain investment strategies in most Manager Directed Programs. Programs and Managed Accounts are made available based on the ownership type associated with your Relationship, and not all Programs may be available to you. Nonresidents of the United States for U.S. tax purposes are not eligible to open Managed Accounts in all Programs. Terminating a Relationship Agreement If you terminate your Advisory Service Provider, or if Ameriprise Financial Services or Advisory Service Provider terminates or discontinues the service provided to you, you may reinvest with another Advisory Service Provider. Reinvesting with another Advisory Service Provider may result in portfolio turnover and tax implications (for non-qualified accounts) based on the holdings of the successor Advisory Service Provider’s portfolio. Because you will be responsible for any associated tax liabilities, you should discuss the potential implications for non-qualified accounts with your tax professional. Client Information Provided to Advisory Service Providers A description of the Client Information shared with an Advisory Service Provider for your Managed Account is included in the following sub-sections in this Disclosure Brochure: • “Acceptance of your Signature Wealth Account” subsection in the Signature Wealth section. • • The Relationship Agreement may be terminated by you or Ameriprise Financial Services by providing appropriate notice. If Ameriprise Financial Services decides to terminate your Managed Account(s), the Ameriprise Financial Services will provide you no less than 30 days prior notice. This notice will advise you of options, if any, that may be available to you. If Ameriprise Financial Services decides to terminate your Managed Account(s), Ameriprise Financial Services may transfer the Account assets to an Ameriprise brokerage account, and the Brokerage Agreement will govern your relationship with Ameriprise Financial Services. If Ameriprise Financial Services terminates your SPS Advisor Account, Ameriprise Financial Services may transfer the Account assets to an Ameriprise brokerage account as outlined above or to an SPS Advantage Account as set forth in the Relationship Agreement. “Investment Manager Review of Active Portfolios®” subsection in the Active Portfolios® section. "Review and Update of Client Information” subsection in the Select Separate Account section 63 • “Acceptance and Authority of Envestnet” in the Advisory Service Providers section. requires that Ameriprise Financial Services and your financial advisor make investment recommendations that are in your best interest and place your interest ahead of our own and those of your financial advisor. This is accomplished by: • Explaining and providing to you written disclosures that outline key, relevant factors about the investment advice and recommendations you receive; and • Providing you with written disclosures that describe material conflicts of interest that your financial advisor and/or Ameriprise Financial Services have as part of AFPS. (You will find these written disclosures throughout this Brochure, and in the “Other Financial Industry Activities and Affiliations” section.) Ameriprise Financial Planning Service Ameriprise® Financial Planning Service (“AFPS”) is designed as a long-term, collaborative, ongoing financial planning relationship to help you achieve at least one financial goal or need. You and your financial advisor will work together to define your goal or need, develop a plan to help you get there and track your progress along the way, making changes when needed. AFPS is a six-step financial planning process. As participants in this process, you and your financial advisor will: • Identify/Prioritize Objectives. Discuss your goals and needs to develop a clear vision of your financial future. • Gather Information. Review important documents such as your bank and brokerage statements, tax returns, insurance policies and retirement plans. • Analyze Information. Understand the big picture of your financial situation, based on information you provide, and analyze how the different elements of financial planning may impact each other. • Propose Recommendations. Develop written financial planning recommendations that align with your goals. • Your financial advisor can provide you with guidance to help you meet a wide variety of your financial needs, including asset allocation services. Your financial advisor may discuss, present or offer ideas for you to consider related to the allocation of retirement assets among one or more Managed Accounts. Such communications are offered solely as education, marketing and examples of the potential uses of these Managed Accounts for purposes of discussion and for your independent consideration, and should not be viewed, construed or relied upon, as investment or fiduciary recommendations or advice under the Employee Retirement Income Security Act of 1974 ("ERISA") or Section 4975 of the Internal Revenue Code of 1986, as amended (the “Internal Revenue Code”). Such communications should not be (and are not intended to be) relied upon as a primary basis for your investment decisions with respect to your retirement assets. Take Action. Act on your recommendations after developing proposed financial solutions to help reach your goals. • Track Your Progress. Your needs and goals evolve over time. Tracking your progress will enable you to adjust your plan in light of personal, legislative or regulatory and economic changes. If you are a client of the Ameriprise Personal Wealth Group, you may receive advice and support in the financial planning process from a dedicated team of financial advisors and professionals whose members may use titles such as Client Support Associate, Client Relationship Manager, or Financial Consultant. The advice you receive from your financial advisor is intended for your use only. If you choose to share your analysis and recommendations with a third party, neither your financial advisor nor Ameriprise Financial Services (nor any of its affiliates) is responsible for the outcome. Additionally, if in connection with discussing, presenting, or offering particular Managed Accounts to you, we provide you with a sample or proposed asset allocation, including one that identifies specific securities or other investments, such asset allocation is merely an example of, or proposal for, the fiduciary advice and recommendations that may potentially be made available through the Managed Account once you decide to establish a Managed Account, and should not be relied upon as investment or fiduciary advice or a recommendation under ERISA or the Internal Revenue Code. We are not acting as a fiduciary under ERISA or the Internal Revenue Code when you decide to engage us in a new service, including with respect to your decision, or the decision of a plan participant, to roll over assets into an Ameriprise IRA. Similarly, we are not acting as a fiduciary under ERISA or the Internal Revenue Code when you decide to move assets from one type of account held at Ameriprise Financial Services to another type of account (e.g., moving assets from an Ameriprise brokerage account to a Managed Account). Ameriprise Financial Services and our financial advisors owe you a fiduciary duty, as applied under the Investment Advisers Act of 1940, as amended, when you enter a financial planning service with Ameriprise Financial Services. This duty generally 64 To the extent that you receive recommendations related to assets held in your brokerage account or with respect to commission-based securities, such recommendations are made as part of your brokerage relationship and are made in your best interest but are not fiduciary recommendations under ERISA or the Internal Revenue Code. Ameriprise Financial Services provides Managed Accounts where you can receive individual securities level fiduciary recommendations. incapacity. It may also include a review of asset and policy ownership and beneficiary designations, as well as action steps or comments on how to work with legal advisors to improve your basic estate situation. Your financial advisor will review the financial fundamentals in the first year of your financial planning relationship and thereafter as needed, for example, if your personal financial circumstances or financial goals change. The review of fundamentals is not provided in advisory relationships with entity clients, such as trusts or businesses. The review of fundamentals is not provided as part of estate settlement or educational seminars and workshops. Additional Financial Planning Areas Your analysis and written recommendations may address one or more of the following goals: Also, to the extent an asset allocation service identifies any specific investment alternative in a retirement plan, please note that other investment alternatives with similar risk and return characteristics may be available to you. Such investment alternatives may be more or less costly than those available at or recommended by Ameriprise Financial Services. Your Plan sponsor (for government plans or those that fall under ERISA) or your financial advisor can assist you in obtaining information about other potential investment alternatives. Financial Position Planning — applying cash flow management strategies to help you optimize resources available to help you reach your goals. This may include debt management techniques, major purchase financing options, cash reserve strategies and family budgeting. AFPS tailors advisory services to the individual needs of clients as discussed in the next several sections. AFPS Planning Goals Future Purchase Planning — applying strategies to help you plan to fund a future purchase or accumulate funds for a particular goal. Your financial advisor will review your data and other information to make recommendations that can help you meet your goals. Education Planning — applying strategies to help you fund the education of children, grandchildren or others. This may also include financial aid analysis. Financial Fundamentals Retirement Planning — applying strategies to help you fund retirement, transition to retirement or ensure adequate retirement income. Basic Financial Position. At a minimum, this will include a high-level compilation of your net worth, income (inflows) and expenses (outflows). It may also include action step(s) and/or an acknowledgement by your financial advisor that figures are based on estimates if you are not able to provide precise data. Investment Planning — applying strategies to help optimize portfolio performance to reach future financial goals. AFPS does not include current market analysis or other ongoing investment-related advice. Income Tax Related Planning — addressing general tax considerations for financial services products, transactions and registrations (ownerships) and helping you understand how individual income, estate and gift tax planning techniques apply to your situation. Employee Benefits Planning — helping you make decisions related to your employer-sponsored benefit plans. Estate, Legacy or Multigenerational Planning — helping you prepare to pass wealth to your beneficiaries in an efficient manner. Protection Needs. At a minimum, this will include an inventory of your insurance policies, including life, disability (if you are not retired) and long-term care (if you have reached a certain age). You may also receive an analysis of your needs and your family’s needs in the event of death, disability and long-term care, as applicable. This may include an overview of other protection needs (e.g., property and casualty). Your financial advisor may also provide action steps in the form of recommendations; observations about the adequacy of your coverage; and/or other statements acknowledging your insurance situation, protection planning preferences, and/or whether any of the data or analysis is based on estimates if you are not able to provide precise data. Estate Settlement — applying strategies to help an estate or testamentary trust meet its obligations, such as distribution of assets and payment of income and estate taxes. Basic Estate Needs. This will include an inventory of basic estate documents that are essential for the proper disposition of your assets upon your death and to provide for appropriate care in the event of your Business Financial Planning — addressing your financial planning needs as a business owner, which 65 may include an analysis of business cash flow, business valuation, business tax planning, business benefits planning and business transition. financial circumstances or need for financial planning services change, you and your financial advisor should discuss whether your fee needs to change. Ongoing Relationship As your financial planning relationship continues, you will work with your financial advisor following the financial planning process described above. For example, you and your financial advisor will: Educational Seminars and Workshops — providing seminars and workshops on financial planning or investment- related topics to businesses or organizations. This service does not include the financial planning process or provision of written advice recommendations to individuals. • Confirm your working relationship and the associated fee, annually • Track progress over time toward identified goals • Identify key changes to your situation and revisit your financial goals Other types of financial planning services may be offered such as divorce financial analysis, or limited scope analysis. Your financial advisor may not be certified to offer certain types of financial planning. Talk with your financial advisor for more information about these services. • Propose new financial planning recommendations as appropriate Financial advisors are required to complete specialized training to provide divorce financial analysis, as well as some forms of income tax planning and planning for some types of trusts. If your financial advisor has not met these requirements, another qualified financial advisor may provide these services. Ameriprise Financial Services and Your Financial Advisor Do Not Provide Legal or Tax Advice. Your AFPS Agreement is effective the day that Ameriprise Financial Services processes the AFPS Agreement (“Effective Date”), which may be different than the date(s) signed by you and your financial advisor. Your initial engagement begins on the Effective Date and ends the day prior to the anniversary date of your Effective Date. Each twelve-month period thereafter will be a new engagement period (“Engagement Period”). Initial Recommendations Your AFPS Agreement will automatically renew each year. If you do not receive your written financial planning recommendation(s) within the Engagement Period, you are entitled to a refund of your AFPS fee. Changing Your Planning Goals In the first year following the effective date (described below) of your AFPS Agreement, your financial advisor will make best efforts to perform an analysis and deliver within 180 days initial written recommendation(s). This timeframe does not apply to estate settlement planning. You may change the financial planning goals on which you are requesting financial advice by discussing any desired changes with your financial advisor. In addition, after looking at all your financial data, your financial advisor may decide to recommend further assessment in a specific area that has not already been identified. The analysis and written recommendations will address the fundamentals of your financial situation as well as the priority goal(s) you have discussed with your financial advisor. The remainder of the first year may focus on tracking your progress to goals, addressing other financial planning goals and/or beginning to take action on written recommendations as appropriate. Changes to your financial planning goals are confirmed to you by the delivery of recommendations consistent with your new goals. Shortly after you sign the AFPS Agreement, you will receive a confirmation of services that reflects: • the total quoted AFPS fee; • the date your initial engagement began; and Read and understand those recommendations to determine if you received advice on the goals you specified. If you did not, please contact your financial advisor or call 800.862.7919. • the latest date on which you can expect to receive your initial written recommendations. You and your financial advisor should also discuss whether your AFPS fee needs to change in light of the changes to your planning goals. Implementation of Your Financial Planning Recommendations Any recommendations provided in your financial plan are provided relative to the goals you establish with You will also receive a confirmation of services annually, in the form of a notice on your consolidated statement or other written notice to you, each time your AFPS Agreement renews. Please contact Ameriprise Financial Services at 800.862.7919 if you do not receive a confirmation of services within 120 days of your renewal date. If your personal 66 your financial advisor and do not include ongoing monitoring of your investments or your accounts, nor do they include the implementation of the recommendations provided in the plan by your financial advisor. You may decide to implement the recommendations you receive through Ameriprise Financial Services, its affiliates or unaffiliated financial services providers. Before implementing any recommendations, consider carefully the consequences of purchasing products or services. You may want to seek further advice from your lawyer and/or accountant, particularly for estate planning, taxes, or business financial planning issues. When you choose to purchase products and services through Ameriprise Financial Services, you have the option of investing through a commission-based brokerage account, a fee-based Managed Account, or both. Brokerage Account. You pay commissions and other charges (such as sales loads on mutual funds) at the time of each individual securities transaction. As a result, this type of account may be more suitable than a Managed Account if you do not expect to trade on a regular basis and do not want ongoing investment advice on assets held in your Managed Account. None of the mutual funds currently offered in Ameriprise Managed Accounts Programs impose a front-end sales charge. For most mutual funds, a share class that does not have a sales load and does not assess 12b-1 fees (collectively “Advisory Shares”) is offered in all Ameriprise Managed Account Programs as the only mutual fund share class, where available to us through a selling agreement. If not available to us through a selling agreement or if the mutual fund does not offer an Advisory Share class, we offer Class A shares that may pay a 12b-1 fee or a no-load share class that does not have a sales-load but that may pay a 12b-1 fee. 12b-1 fees are paid by a mutual fund out of fund assets to cover distribution expenses and sometimes shareholder service expenses. The share class offered by Ameriprise Financial Services for a particular mutual fund is the only share class we allow for additional purchase within your Account. Any 12b-1 fees received by Ameriprise Financial Services will be promptly rebated to your Managed Account. The share class offered by Ameriprise Financial Services for each applicable fund is listed in our Mutual Fund Screener Tool. Access the tool by logging into your Ameriprise Secure Site account and navigating to “Trade & Research” and then, “Screeners” followed by “Mutual Fund”. From there, apply the Product Type filter and choose either SPS Advantage or SPS Advisor to view the funds and share classes available for purchase. Managed Account. You pay an ongoing Asset-based Fee (rather than a commission on each individual transaction) for investment advisory services such as investment selection, asset allocation, execution of transactions, custody of securities and account reporting services. The Asset-based Fee is assessed monthly. As a result, a Managed Account may be more suitable than a brokerage account if you want ongoing investment advice and expect to trade frequently. The Advisory Share or other share class we offer in Ameriprise Managed Accounts is less expensive than share classes made available through an Ameriprise brokerage account that charge investors a 12b-1 fee or assess a sales charge. This presents a conflict of interest because Ameriprise Financial Services and its financial advisors typically earn higher fees from share classes that charge such fees. It is therefore generally more profitable to Ameriprise Financial Services, its affiliates and its financial advisors, and more costly to clients, if clients invest in mutual fund share classes made available through an Ameriprise brokerage account. Ameriprise Financial Services is the sponsor and introducing broker for a variety of Advisory Solutions. Within its Advisory Solutions, Ameriprise Financial Services offers a number of Programs that have a wide array of investment strategies. When you decide upon a Program, you may open a Managed Account. See the Ameriprise® Managed Accounts Client Disclosure Brochure or, if you have elected to pay a consolidated advisory fee, the Ameriprise® Managed Accounts and Financial Planning Service Disclosure Brochure for additional important information, including applicable fees and other charges. Your financial advisor may not offer all Programs or accounts available from Ameriprise Financial Services. A financial advisor’s recommendation that the client invest in mutual fund share classes through an Ameriprise brokerage account service will cause the client to pay higher internal expenses for certain mutual funds than the client might otherwise pay if participating in an Ameriprise Managed Account Program or by buying the mutual funds directly from the distributor outside of a brokerage account service, if possible. The client’s participation in a brokerage account service that does not offer the Advisory Share or other share class we offer in Ameriprise Managed Accounts may still be an appropriate choice depending on the facts and circumstances of the client’s individual situation and in light of the features and benefits of the particular brokerage account service. Please refer to the mutual fund’s prospectus(es) or Depending on how long you choose to be a financial planning client and the number and types of products you purchase from Ameriprise Financial Services, you may pay more or less to purchase products and services through Ameriprise Financial Services and its affiliates than if you were to purchase products and services from other financial services providers. 67 website to determine whether your investment would qualify for a less expensive share class outside a brokerage account service, with corresponding lower expenses and fees. How to Make The Most of Your Financial Planning Relationship At Ameriprise Financial Services, we believe that financial planning is the best way to help you achieve your goals. The financial planning relationship begins with you. As an AFPS client, you will need to: Your financial advisor may provide asset allocation strategies that include advice on allocations into certain classes of investments. Except where we are providing you guidance related to your Outside Workplace Retirement Plan or Health Savings Account (“HSA”) as described below, your financial advisor cannot provide specific buy, sell or hold recommendations or initiate transactions concerning individual securities in your investment accounts held in custody elsewhere, unless held by one of our broker-dealer affiliates. See the “Other Financial Industry Activities and Affiliations” section of this brochure for more information about these affiliates. Establish Clear and Measurable Financial Goals. Talk with your financial advisor about your goals so he or she may be part of the financial planning process. For example, if your goal is a “comfortable” retirement, talk with your financial advisor about what that means to you. The more specific you are about the lifestyle you envision, the better equipped your financial advisor will be to make recommendations to help you get there. Provide Complete and Timely Information to Your Financial Advisor. Your financial advisor will base your financial planning analysis and written recommendations on the information you provide. You must provide the requested information in a timely manner to receive your recommendations in a timely manner. When you become an AFPS client, you represent that all financial and other data that you and/or your representatives or agents furnish to your financial advisor relating to your assets, liabilities, policies, present and future income, and obligations are true and correct and may be relied upon by your financial advisor and Ameriprise Financial Services for the purposes of providing AFPS. Your financial advisor will be better able to make recommendations to help you achieve your goals if you provide complete and thoughtful information to your financial advisor about your current financial and economic situation, the financial goals on which you want advice, your investment objectives, and any investment restrictions you may have. Promptly inform your financial advisor if you experience significant life events, or material changes in your financial situation, risk tolerance or financial objectives. Where requested and as part of your AFPS, your financial advisor may provide guidance on your retirement plan or HSA assets that are held outside of Ameriprise Financial Services in a participant-directed defined contribution plan (e.g., 401(k) plan) (“Outside Workplace Retirement Plan”) or HSA. Any guidance provided to you is based on information provided by you about your Outside Workplace Retirement Plan or HSA and is limited to investments offered through the core lineup of funds established by your plan sponsor. Your Outside Workplace Retirement Plan or HSA may include investment options not available at Ameriprise Financial Services or for which your financial advisor may not have access to detailed information. Neither Ameriprise Financial Services nor your financial advisor is responsible for the selection of the available investment options in your Outside Workplace Retirement Plan or HSA. Your financial advisor may not make buy recommendations related to employer stock that may be available within your Outside Workplace Retirement Plan or HSA. Your financial advisor cannot make recommendations with respect to any current portfolio holdings or investment options available through a self-directed brokerage account associated with your Outside Workplace Retirement Plan or HSA. You are responsible for placing any transactions recommended by your financial advisor. If you desire ongoing guidance on your Outside Workplace Retirement Plan or HSA you must provide your financial advisor with updated information, including statements and a list of funds available in your Outside Workplace Retirement Plan or HSA, on a regular basis. Your investment objectives and risk tolerance for your Outside Workplace Retirement Plan or HSA may differ from those of your Ameriprise account(s), if any. However, any guidance provided for your Outside Workplace Retirement Plan or HSA is provided in consideration of the investment objectives and risk tolerance of any Ameriprise account(s) you hold. Review The Written Recommendations You Receive. Based on the information you provided, your financial advisor will perform financial planning analysis and give you written recommendations on the financial goals you have identified. Your financial advisor is obligated to provide recommendation(s) within a particular timeframe, which is discussed in detail in the “Ameriprise® Financial Planning Service” section of this Brochure. If your financial advisor’s assumptions, methods, conclusions or recommendations do not meet your expectations, contact your financial advisor right away to resolve your concerns. Form Reasonable Expectations. Understand the benefits of and limits to the financial planning process and be reasonable in your expectations of the results you can achieve with your financial plan and 68 Other Advisory Services investments, given your risk tolerance and objectives. Financial planning is an ongoing process; it will not change your situation overnight. Furthermore, events beyond your financial advisor’s control, such as changes in economic conditions, will affect your financial planning results. Share with your financial advisor your expectations about the financial planning process and what you want to achieve. If your expectations are not met, let your financial advisor know so he or she can make adjustments to meet your needs. Ameriprise Financial Services offers a suite of Advisory Solutions that features several types of Programs, including Strategic Portfolio Service (“SPS”) Advantage, SPS Advisor, Signature Wealth, Active Portfolios® investments, Select Separate Account, Vista Separate Account, Investor Unified Account, and Access Account. Not all Managed Account Programs are available to all clients; contact your financial advisor for more information. Please review the Ameriprise Managed Accounts Client Disclosure Brochure, or if you have elected to pay a consolidated advisory fee, the Ameriprise Managed Accounts and Financial Planning Service Disclosure Brochure for a full description of these Programs. Take Action. After reviewing your financial planning recommendations with your financial advisor, the next step is to act on the advice you have received. You decide whether or not to implement any of the recommendations. You are not obligated to purchase products or services through Ameriprise Financial Services. As of December 31, 2025, Ameriprise Financial Services managed $304,183,842,664 in nondiscretionary assets and $356,290,579,112 in discretionary assets. If you would like to work with a different financial advisor, please call us at 800.862.7919 and we will help you find another financial advisor. If for some reason your financial advisor is unable to fulfill the terms of the service agreement, another Ameriprise financial advisor may be assigned to you to provide the written financial planning recommendations and complete the terms of your Agreement. Fees and Compensation Ameriprise financial advisors receive compensation for financial advice in the form of commissions and fees. Ameriprise Personal Wealth Group financial advisors can receive compensation for financial advice in the form of bonuses. AFPS fees are negotiable and there is no assurance that similarly situated clients will be assessed comparable fees. Your financial advisor will explain the AFPS fee and the factors considered in calculating the AFPS fee before asking you to sign the AFPS Agreement. A state may impose a sales tax on your AFPS fee, which we will collect and remit to the applicable state. Understand That Your Financial Planning Service Will Continue Until You Terminate It. You will receive written recommendation(s) and pay an AFPS fee during each Engagement Period. The service will automatically renew on an annual basis until you decide to terminate the AFPS Agreement or stop paying the fee. In addition, Ameriprise Financial Services will notify you when there are material changes to this Brochure and offer you the opportunity to receive a copy of the revised Brochure. You should carefully consider accepting this offer, as that revised Brochure replaces any previous version you have received. AFPS fees vary based on (1) your financial advisor’s fee schedule, which is based on your financial advisor’s years of financial planning experience, professional credentials, and other factors, such as local market considerations; and (2) the overall complexity of your advice needs. You may request and receive copies of a current Brochure at any time by writing to Ameriprise Financial Services at the following address or by contacting us at 800.862.7919 between 7 a.m. and 6 p.m. Central time. Ameriprise Financial Services, LLC 476 Ameriprise Financial Center Minneapolis, MN 55474 Your financial advisor will assign an overall complexity factor of “low,” “medium” or “high” to your advice needs based on your personal financial circumstances, your financial planning needs, and the frequency with which your financial advisor meets with you and/or other professionals or family members. Ask questions about the AFPS fee so that you understand the factors considered in arriving at your AFPS fee and what you can expect for this fee. Take an Active Role in The Process. Understand the process, your role and your financial advisor’s role. Provide information. Ask questions about the recommendations you receive. If at any time there are additional goals you would like to cover, let your financial advisor know. Take an active role in making decisions about your financial future, and you will position yourself to get the most out of your financial planning relationship. As of the date of this Brochure, the minimum annual AFPS fee for new AFPS Agreements is $500. Effective June 2026, the minimum annual AFPS fee for new and existing AFPS Agreements will increase to $750. Your 69 financial advisor’s minimum AFPS fee may be higher. The AFPS fee to enter a new financial planning relationship with financial advisors from the Ameriprise Personal Wealth Group is $50.00/month. Depending on the overall complexity of your advice needs, you may pay a higher fee. If you have an existing AFPS Engagement with financial advisors from the Ameriprise Personal Wealth Group, you may pay a lower fee. through Ameriprise. These sources include arrangements we have in place with product companies, and investment and interest income. See the “Cost Reimbursement Services and Third-Party Payments” subsection of the “How we get paid” section later in this brochure for more information on conflicts of interest regarding revenue sources for Ameriprise Financial Services and its affiliates, as well as the subsection “Revenue sources for RiverSource” for more information about the fees and commissions you pay when you implement your financial advisor’s recommendations through Ameriprise Financial Services and its affiliates. The revenue generated or received supports the development of new products, maintenance of our infrastructure, and retention of employees and financial advisors. Your financial advisor may recommend mutual funds and other investment products offered by firms that make Third Party Payments to our affiliate, AEIS, as described in the “Payments from product companies” subsection later in this Disclosure Brochure. Within its investment advisory business, compensation for the sale of investment products recommended by financial advisors is not Ameriprise Financial Services’ primary source of revenue from its advisory clients. The AFPS fee that you pay in the first year of service may differ from the AFPS fee you pay for services in ongoing years, as described in the “Ongoing relationship” subsection of the “Ameriprise® Financial Planning Service” section of this Brochure. A portion of the AFPS fee will be allocated to your financial advisor for introducing you to the service, gathering the information necessary to prepare your service, helping you establish needs and goals, preparing and presenting your service, and/or providing financial advice on behalf of Ameriprise Financial Services. The portion of the AFPS fee allocated to your financial advisor is impacted by factors including the level of affiliation that the financial advisor has with Ameriprise Financial Services and whether the financial advisor was assisted by another person (who may be a financial advisor or other individual who makes a referral) in providing services to you. Your AFPS fee does not include markups or brokerage commissions by Ameriprise Financial Services or your financial advisor. If you implement your financial plan in whole or in part through Ameriprise Financial Services or its affiliates, wrap fees, product fees, markups or markdowns and brokerage commissions will apply as applicable. Both time of sale and ongoing fees, if applicable, will apply for products and services purchased in a transaction- based brokerage account. Client Programs and Promotions The remaining portion of the fee goes to Ameriprise Financial Services for the supervisory, technical, administrative and other support provided to all financial advisors. If you establish an Ameriprise Managed Account, the Asset- based fee you pay for the Managed Account is separate from your AFPS fee. Please refer to the Ameriprise Managed Accounts Client Disclosure Brochure, or if you have elected to pay a consolidated advisory fee, the Ameriprise Managed Accounts and Financial Planning Service Disclosure Brochure for more detail about the allocation of Asset- based Fees. Some financial advisors require clients to pay AFPS fees either at the beginning of an Engagement Period or before providing AFPS. See the “Termination of AFPS” and “Termination procedure” sections below for information regarding refunds if you or Ameriprise Financial Services terminates the AFPS Agreement before the end of an Engagement Period. Ameriprise Financial Services may provide a fee reduction to corporate, institutional or membership organizations and their employees, partners, independent contractors or members. Ameriprise Financial Services may, from time to time, offer reduced fees on AFPS to individuals in a particular market segment or geographic area. Your financial advisor can tell you whether there is a promotion available to you. Ameriprise Financial Services, in its sole discretion, determines when to offer, modify and/or discontinue these promotions and programs. These promotions and programs are not available to financial advisors from the Ameriprise Personal Wealth Group. Ameriprise Financial Services is dedicated to providing quality client service. We work hard to ensure your satisfaction with the AFPS services that you receive and seek to meet or exceed your expectations. We will work with you to address any of your concerns, including helping you work with a different financial advisor or terminating the AFPS Agreement. Pro Bono Financial Planning Ameriprise Financial advisors may seek approval from Ameriprise Financial Services to offer, on a limited Our affiliate American Enterprise Investment Services Inc. (“AEIS”) receives revenue from several different sources on the products and services you purchase 70 basis, pro bono financial planning to persons who otherwise cannot afford to pay for financial planning services. These promotions and programs are not available to financial advisors from the Ameriprise Personal Wealth Group. Institutional Services Types of Clients AFPS is generally appropriate for individuals who seek an ongoing fee-based financial planning relationship and who have financial goals and sufficient assets and income to begin addressing those goals. AFPS is intended for individuals; couples; and entities with financial planning needs, such as trusts, estates, nonprofit organizations and businesses. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Financial Analysis Ameriprise Financial Services may enter into written agreements with corporate, institutional or membership organizations to provide AFPS to their employees, partners, independent contractors or members. The fees for institutional services vary by agreement. These agreements may include other services and fees that are lower than the AFPS fees paid by other AFPS clients. These promotions and programs are not available to financial advisors from the Ameriprise Advisor Center. Termination of AFPS AFPS will remain in effect until one of the following occurs: termination by you; termination of an existing AFPS Agreement by replacing it with a new one, as described in the preceding paragraph; termination by Ameriprise Financial Services, which would require sending you written notice reasonably in advance of the termination date (except as noted in this paragraph) to your address as shown on our records; termination by Ameriprise Financial Services, with no advance notice, for non-delivery of services to you by your financial advisor; or termination by you through nonpayment of the AFPS fee. When developing recommendations for you, your financial advisor compares your stated financial goals with your financial situation, investment risk tolerance, investment horizon and the risk and potential investment solutions. Your financial advisor may use asset value, current and projected rates of return, and other assumptions you provide, as well as historical return analysis prepared by Ameriprise Financial Services or an affiliate. Your financial plan may be prepared through the use of one or more software packages that take a needs-based approach to analyze your goals using one or more methods of analysis, including deterministic and probability modeling. The analysis and projections generated by the tools or other analysis described in this section of the Brochure include information regarding the likelihood of various potential investment outcomes. They are hypothetical in nature, vary depending on which tool of analysis is used and with each use and over time, do not reflect actual investment results, and are not guarantees of future results. Investing in securities involves the risk of loss and you should be prepared to bear this loss. The probability of success also varies based on differing assumptions, on different tools and from one Engagement Period to the next based on changing circumstances and market information. Results may reflect one point in time only and are only one factor you should consider as you determine how best to plan for your future. If you choose to terminate the Agreement during the first year before receiving your initial recommendations, you will receive a full refund of AFPS Fees paid. However, if you terminate at any time after Ameriprise Financial Services has performed under this Agreement, or if you terminate the services and have not provided your financial advisor with complete and accurate information concerning your financial situation, Ameriprise Financial Services reserves the right in its sole discretion to limit the amount of the refund you receive, if any. To terminate or cancel the Agreement and request a refund, if eligible, complete an AFPS Cancellation and Refund Request form available from ameriprise.com. You may also request the form from your financial advisor or by calling Ameriprise Financial Services directly at 800.862.7919 between the hours of 7 a.m. and 6 p.m. Central time, Monday through Friday. Your financial plan also may include an asset allocation analysis designed to assist you in positioning your investment assets. If your financial plan includes such analysis, the recommended portfolio allocation will be determined based on a variety of factors, including your personal financial information and the historical and anticipated performance of different asset classes. Performance-Based Fees and Side-by- Side Management Neither Ameriprise Financial Services nor any of its supervised persons accepts performance-based fees for its investment advisory services. The analysis is meant only to illustrate the relative experience among asset classes and portfolios. Periodic rebalancing of your portfolio and reallocation among the asset classes is recommended in most circumstances, and rebalancing and reallocation may not be part of AFPS. Rebalancing your non-qualified 71 analysis or written recommendations you receive does not correspond with the date and market value of your official Ameriprise Financial consolidated statement, the market values shown on the material you receive will differ from your consolidated statement. The information provided to you in your analysis and written recommendations is not intended to be a substitute for the valuation and other information contained in your official Ameriprise Financial consolidated statement. portfolio to meet asset allocation objectives may result in taxable gains or losses. Unless included in a particular Ameriprise Managed Account Program, Ameriprise Financial Services does not rebalance your portfolio or reallocate your target asset allocations on a continuous basis. If you have a substantial percentage of your net worth concentrated in a given asset or asset class, the illustrations may prompt your financial advisor to recommend that you sell or exchange a significant portion of such position to reduce risk by reducing the concentrated positions within your portfolio. Special tax rules apply to net unrealized appreciation of employer securities held in a retirement plan. This is particularly true if the asset in question is stock of your employer, given that both your income and investment could be tied to the profitability of your employer. Before you actually sell any such assets, consult with your legal and tax professionals regarding the tax and other implications of any such sales. The asset allocation analysis does not provide a comprehensive financial analysis of your ability to reach your other financial planning goals, and it does not identify the impact of your investment strategy on your tax and estate planning situations. Asset allocation does not guarantee a profit or protect against a loss. For your accounts and assets not held at Ameriprise Financial (“Non-Held Assets”) all asset and net worth information used in connection with your AFPS was provided by you or your designated agents and is shown as of the date it was provided to Ameriprise Financial Services. Ameriprise Financial services does not have knowledge of changes in your Non-Held Assets, including your accounts and portfolio holdings, and the materials provided in connection with your AFPS will not reflect changes to your Non-Held Assets. This means that if you view your AFPS materials without updating your Non-Held Assets, the information and assumptions provided to you will be based on data about Non-Held Assets that is not current. Ameriprise Financial and your financial advisor take reasonable steps to reproduce information obtained from you or your designated agents regarding Non-Held Assets. Sources of information Neither Ameriprise Financial nor your financial advisor has undertaken to review or verify the accuracy of Non- Held Assets and the inclusion of information and assumptions about Non-Held Assets in your AFPS written recommendations, or any other analysis, review, or guidance offered by Ameriprise Financial Services and your financial advisor creates no duty or other responsibility to advise you to take any action or inaction regarding such Non-Held Assets. Third-Party Research Provider Materials Not Approved for Use with Clients From time to time, financial advisors may access research, models, investment tools or other material from third- party research providers that are not approved for use with clients for the purposes of the financial advisor’s general education, staying current on industry trends or developing potential investment ideas. Financial advisors may provide clients with general market commentary or non-security information once the individual pieces have been approved for use by Ameriprise Financial Services. The principal source of information used by your financial advisor is the data provided by you, such as your personal data, assets and liabilities, income expectations, assumed overall rates of interest and inflation, short-term and long-term financial goals, tax information, risk tolerance associated with goals, and other relevant information. When developing product recommendations, your financial advisor may also use training and marketing materials and prospectuses and annual reports for a particular investment product. In addition, your financial advisor may also utilize research produced by Ameriprise Financial Services or its affiliates, such as material prepared by the Ameriprise Investment Research Group ("IRG") or from third-party research providers that have been approved by Ameriprise Financial Services when providing investment advice. Although the information and data are believed to be accurate, Ameriprise Financial Services and its financial advisors do not independently verify third-party information. Neither Ameriprise Financial Services nor its financial advisors guarantee the accuracy, completeness or timeliness of any such information nor do they imply any warranty of any kind regarding the information provided. Investment strategies Your financial advisor may recommend long-term strategies for your financial plan, such as dollar-cost averaging, reinvestment of dividends or other proceeds For your accounts held at Ameriprise Financial, if any, market value (i.e., account value) is provided from the source of record and is generally captured at a point in time. If the date and market value displayed in 72 on investments, and asset allocation. Recommendations may also be made to help you realize capital gains or losses on securities or investment products that you own. Such transactions may have tax consequences for non-qualified accounts. See the “Implementation of your financial planning recommendations” subsection of the "Advisory Business" section and the “Broker-dealer” subsection of the “Other Financial Industry Activities and Affiliations” section for further information on investment products and services offered by Ameriprise Financial Services. in-fact purchases the financial advisor is not obligated to make recommendations or give financial advice that, in the sole judgment of the financial advisor, would be impracticable, unsuitable, unattainable or undesirable for the client. We strongly recommend you seek advice from legal and tax counsel before implementing suggested planning strategies that involve disposition of assets. We reserve the right to decline business. When servicing the client’s account, the financial advisor cannot put your interests as attorney-in- fact ahead of his or her obligations to act in the best interest of the client. Disclosure of Interest and Capacity About Advisor Compensation — Your financial advisor may recommend that you purchase or sell investments, recommend that you enter into other financial transactions, or provide financial advice regarding financial decisions. You have no obligation to follow any such recommendations or advice. If you implement any such recommendations through Ameriprise Financial Services, then in addition to the AFPS fee described above, your financial advisor will receive fees, commissions or other financial compensation as a result of the transaction and/or advice, as described in the “How our financial advisors get paid” section elsewhere in this Brochure. Such transactions may result in tax consequences for non- qualified accounts. We cannot guarantee future financial results or the achievement of your financial goals through implementation of your financial plan and any advice or recommendations provided to you. Ameriprise Financial Services does not monitor the day-to-day performance of your specific investments. Before implementing your financial plan, you should consider carefully the ramifications of purchasing products or services, and you may want to seek further advice from your lawyer and/or accountant, particularly in connection with estate planning, taxes or small business owner planning issues. The benefits and advantages of cash value life insurance generally increase as the policy matures and are most fully realized with the death of the insured. A client with immediate liquidity needs may consider whether to sell the policy to a third party at a discounted value (commonly referred to as a life settlement). About Your Agreement — No assignment of the Agreement by Ameriprise Financial Services will be effective without your consent. Supplemental Terms and Conditions of Your Consolidated Advisory Fee Service By signing to establish a consolidated advisory fee service, you agree that the following terms and conditions supplement and apply to your service. About Your Initial Proposal and Ongoing Service — Your financial advisor’s initial recommendations may address only the areas that you have identified as your most immediate needs and priorities. About Estate or Trust Beneficiaries as AFPS Clients — If you are an AFPS client and a beneficiary of an estate or trust that is also an AFPS client serviced by your financial advisor, you understand, acknowledge and agree that (1) there may be a conflict when your financial advisor is providing advice to you as the beneficiary of an estate or trust, as the estate’s or trust’s interest may not be the same as your interest as beneficiary; and (2) when servicing the estate or trust, your financial advisor cannot put your interest as beneficiary ahead of his or her obligation to act in the best interests of the estate or trust. Your financial advisor is not obligated to make any recommendations or give any financial advice to you that, in the sole judgment of the financial advisor, would be impracticable, unsuitable, unattainable or undesirable. Your financial advisor provides financial services of the type contemplated in the Agreement, as well as other financial services for a number of clients. Your financial advisor will review the fundamentals of your financial situation; this may include an analysis of your insurance protection coverages. Ameriprise Financial Services does not provide insurance consulting, tax advice, legal advice or document preparation as part of AFPS. Ameriprise Financial Services does not monitor the day-to-day performance of your specific investments. Neither your financial advisor nor Ameriprise Financial Services shall have any liability for your failure to promptly inform your financial advisor of material changes in your financial and economic situation, your investment objectives or results, and any restrictions you wish to propose that may affect the development of your financial plan. About Power of Attorney Appointments — If you are an Attorney-in-Fact pursuant to a Power of Attorney for the client, you understand, acknowledge and agree that: (1) the financial planning services will be based on the information provided to us by the client and/or you as attorney-in-fact regarding the client’s financial situation; (2) you will provide us with complete and accurate information, to the best of your knowledge; and (3) with the service the client or you as attorney- 73 About Sweep Programs — If you decide to implement the recommendations you receive through Ameriprise Financial Services, you understand and agree that cash balances in your Managed Account(s) or Ameriprise brokerage account(s), as applicable, will be held in the money settlement option made available to you by Ameriprise Financial and that you agreed to in your Relationship Application for Managed Accounts or the Brokerage Application for Ameriprise brokerage accounts, as applicable. These money settlement options are further described in the Disclosure Brochure and include a free credit balance (Ameriprise Cash) held in your account or a program that provides for the automatic deposit or “sweep” of uninvested cash balances in your account (each, a “Sweep Program”). You understand we offer a Sweep Program as a short-term feature that is intended to hold cash for the purposes described in the Disclosure Brochure. You agree that you will not maintain a cash balance in your Ameriprise account(s) solely for the purpose of receiving interest or obtaining FDIC insurance or SIPC coverage. You understand that Ameriprise Financial offers other investments products that offer capital preservation with a higher rate of return than a Sweep Program and are a more appropriate place to invest cash than maintaining a significant cash balance in your account for an extended period. You understand and acknowledge that if your Sweep Program consists of money market mutual funds then your Sweep Program will have its own expenses. You further understand and acknowledge that the banks that participate in the FDIC insured interest-bearing bank deposit Sweep Programs offered by our affiliated clearing firm, AEIS, compensate AEIS for deposits placed at the bank(s) or reimburse AEIS for expenses it incurs in providing the Sweep Program, and that our affiliate, Ameriprise Bank, FSB, is a participant in these programs. AEIS receives marketing support payments from the underlying money market mutual funds, if eligible, used as the Sweep Program for your account. The availability of each Sweep Program depends on your account type and ownership. You acknowledge that you have received and have had the opportunity to review the (i) Sweep Program and Expenses section of the Disclosure Brochure; (ii) Money Settlement Options section of the Ameriprise Brokerage Client Agreement, and (iii) Other Important Brokerage Disclosures document, which fully describe our insured bank deposit programs. You can always obtain the current version of the Disclosure Brochure, Brokerage Client Agreement and the Other Important Brokerage Disclosures by visiting our website at ameriprise.com/disclosures or by calling our service line at 800.862.7919. About Insurance and Annuity Products — You understand and acknowledge that with the sale of life, disability income and long-term care insurance and annuity products, Ameriprise Financial Services and the financial advisor from whom you purchase the product are the appointed agents of the insurer and receive compensation from the insurer for the sale and servicing of that product. This compensation is separate from and in addition to the AFPS fee you pay for AFPS and may vary depending on the type or size of the insurance or annuity product that you purchase, the insurer that issues the product, the total number of life, disability income and long-term care insurance and annuity products sold by Ameriprise Financial Services and/or your financial advisor for that insurer, and other factors. This compensation typically will increase based on the size of the product that you purchase, or as the total payments that you make on that product increase. Generally speaking, the compensation that Ameriprise Financial Services and your financial advisor will receive depends on a relative compensation formula. That is, compensation received from the sale of life, disability income and long-term care insurance and annuity products is often greater than from the sale of other financial products such as mutual funds. As a result, Ameriprise Financial Services and your financial advisor typically will have a financial incentive to recommend that you purchase a life, disability income or long-term care insurance product or annuity product instead of another financial product such as a mutual fund. You are not obligated to purchase an insurance product from Ameriprise Financial Services or your financial advisor. About Retirement Accounts — You agree that your financial advisor may discuss, present or offer ideas for you to consider related to the allocation of your retirement assets and that such communications are offered solely as education, marketing and examples for the purposes of discussion and for your independent consideration, and should not be viewed, construed or relied upon, as investment or fiduciary recommendations or advice under the Employee Retirement Income Security Act of 1974 ("ERISA") or Section 4975 of the Internal Revenue Code of 1986, as amended (the “Internal Revenue Code”). You understand that such communications should not be (and are not intended to be) relied upon as a primary basis for your investment decisions with respect to your retirement assets. Also, if we provide you with a sample or proposed asset allocation, including one that identifies specific securities or other investments, such asset allocation is merely an example of, or a proposal for, the fiduciary advice and recommendations that may potentially be available and should not be relied upon as investment or fiduciary advice or a recommendation under ERISA or the Internal Revenue Code. Also, to the extent an asset allocation service identifies any specific investment alternative for your retirement assets, please note that other investment alternatives with similar risk and return characteristics may be available to you. 74 Privacy Notices Protecting your privacy is a top priority. Visit our Privacy, Security & Fraud Center at Ameriprise.com to understand our notices for how we collect, use, share and protect your personal information as well as to get answers to privacy-related questions. million. The firm further reimbursed all impacted clients for the losses they incurred due to the misconduct. The firm also took steps to enhance policies, procedures and controls related to the safeguarding of client assets against theft or misappropriation by its associated persons and voluntarily retained a compliance consultant to assess and confirm the reasonableness of these policies, procedures and controls. Married Person as AFPS Individual Client: If you are married and participating in an AFPS engagement as an individual, your spouse is not a party to the Agreement. Your analysis and recommendations will be based on information that you provide regarding your financial goals, needs, and priorities. Additional Information Disciplinary Information Below is notice of certain regulatory and legal settlements entered into by Ameriprise Financial Services during the last ten years: Regulatory Proceedings In December 2017, Ameriprise Financial Services reached a settlement with the SEC regarding allegations that from December 2010 through October 2013, the firm negligently relied on misrepresentations made by F- Squared Investments, Inc. regarding certain of its ETF portfolios and, as a result, the firm made false statements about the portfolios in certain advertisements. The SEC also alleged that the firm had failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the alleged violations. The firm agreed to pay a disgorgement amount of $6.3 million plus prejudgment interest of $700,000 and a civil penalty amount of $1.75 million. Ameriprise Financial Services entered into each of the regulatory settlements listed below without admitting or denying the allegations. Securities and Exchange Commission (“SEC”) and FINRA Actions In September 2016, Ameriprise Financial Services reached a settlement with FINRA regarding allegations that between October 2011 and September 2013 the firm failed to detect and prevent the conversion, via wire transfers, of more than $370,000 from five of its customers by one of its registered representatives. The customers were family members of the registered representative. FINRA also alleged this went undetected because the firm failed to establish, maintain, and enforce a supervisory system that was reasonably designed to review and monitor the transmittal of funds from accounts of customers to third parties, including those controlled by registered representatives of the firm. The firm paid restitution and a fine of $850,000. Other Financial Industry Activities and Affiliations In August 2024, Ameriprise Financial Services reached a settlement with the SEC in connection with its industry- wide review of firms’ recordkeeping practices regarding business-related electronic communications sent or received by firm personnel using non-approved channels or methods (“off-channel communications”). The settlement resolved allegations that, from at least June 2019, the firm did not maintain or preserve a substantial majority of off- channel communications that were records required to be maintained under federal securities laws and therefore failed to “reasonably supervise” its personnel. The firm agreed to pay a civil penalty amount of $50 million. Prior to the settlement, the firm retained a compliance consultant to address certain undertakings outlined in the settlement and took steps to enhance its policies and procedures and increase training concerning the use of approved communications methods. Ameriprise Financial Services is a subsidiary of Ameriprise Financial, Inc. and conducts its activities directly and through its affiliates. These activities may be material to its investment advisory business or its investment advisory clients. These affiliates include companies under common control with Ameriprise Financial Services by virtue of their status as direct or indirect subsidiaries of Ameriprise Financial, Inc. The information below provides you an overview of the Ameriprise Financial, Inc. companies. These companies work together to offer you financial products and services designed to help you reach your financial goals. In August 2018, Ameriprise Financial Services reached a settlement with the SEC regarding allegations that from 2011 through 2014 the firm failed to adopt and implement policies and procedures reasonably designed to safeguard retail investor assets against misappropriation and failed to reasonably supervise five representatives with a view to preventing and detecting violations of certain federal securities laws by these representatives. The firm agreed to pay a civil penalty amount of $4.5 75 Broker-Dealer the prevailing market conditions. See the Working in Your Best Interest – Regulation Best Interest Disclosure for more information about potential conflicts of interest relating to brokerage transactions. Ameriprise Financial Services, LLC is a registered investment adviser and broker-dealer with the SEC and is authorized to engage in the securities business in all 50 states as well as the District of Columbia, Puerto Rico, and the U.S. Virgin Islands. Ameriprise Financial Services is also a member of FINRA and the Securities Investor Protection Corporation (“SIPC”). For purposes of Form ADV Part 2, certain Ameriprise Financial Services management persons are registered representatives of Ameriprise Financial Services in its capacity as a broker-dealer, registered representatives of American Enterprise Investment Services Inc., and are associated persons of Ameriprise Financial Services in its capacity as a commodity trading advisor. Ameriprise Financial Services is registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor (“CTA”) and has obtained membership with the National Futures Association (“NFA”) in connection with such CFTC registration. Ameriprise Financial Services approves and opens accounts and accepts securities order instructions with respect to the accounts. AEIS serves as Ameriprise Financial Services’ clearing agent providing clearing and settlement services for transactions that are executed for customers of Ameriprise Financial Services. In exchange for a fee paid by Ameriprise Financial Services, AEIS provides clearing, custody, record keeping and all clearing functions for certain advice-based accounts. In addition, AEIS may act as an agent in effecting securities transactions for certain Ameriprise Bank trust accounts. In its capacity as a broker-dealer, Ameriprise Financial Services distributes or receives compensation from selling various products including but not limited to equities and fixed income products. Offerings include corporate bonds and municipal securities, mutual fund shares, ETFs, 529 plans, face-amount certificates, closed-end funds, preferred securities, UITs, non- traded REITs, non-traded BDCs, non-traded closed- end funds, hedge fund offerings, structured products, real estate private placements, exchange funds, private equity offerings, 1031 exchange offerings, fixed and variable annuities, and fixed and variable insurance. Ameriprise Financial Services also sells managed futures funds that engage in trading commodity interests, including futures. AMPF Holding Corporation, an indirect wholly owned subsidiary of Ameriprise Financial, Inc., is a holding company for Ameriprise Financial Services and AEIS. In addition, Ameriprise Financial Services is the distributor of the publicly offered face-amount certificates issued by Ameriprise Certificate Company. Ameriprise Financial Services also may serve as an underwriter or member of a selling group for securities offerings, including those issued by affiliates. Columbia Management Investment Distributors, Inc. (“Columbia Management Investment Distributors”), an indirect wholly-owned subsidiary of Ameriprise Financial, Inc., is a registered broker-dealer serving as principal underwriter and distributor of registered mutual funds and other funds advised by affiliated companies, CMIA and Columbia Wanger Asset Management, LLC (“Columbia Wanger Asset Management”) (collectively, “Columbia Management” or “Columbia”). These funds are collectively referred to as the “Columbia Funds.” Investment Company Ameriprise Financial Services has arrangements with Ameriprise Certificate Company to distribute and sell its face-amount certificates and selling arrangements with Columbia Management Investment Distributors to distribute the Columbia Funds. Investment Advisory Firm Columbia Management Investment Advisers, LLC (“CMIA”), is registered as an investment adviser with the SEC. CMIA provides investment management services to: • Columbia Funds, as well as the Columbia ETFs, closed-end funds and private funds Retail brokerage services are made available through Ameriprise Financial Services, which has an agreement with American Enterprise Investment Services Inc. (“AEIS”), a registered broker-dealer and an affiliate of Ameriprise Financial Services. Ameriprise Financial Services requires clients to agree in their Relationship Agreement that their account(s) are introduced by Ameriprise Financial Services to AEIS on a fully- disclosed basis, and that securities purchase and sale transactions in their account(s) shall be directed through AEIS, except when an Investment Manager places “step-out trades” as described in the “Brokerage Practices” sub-section. You should consider that not all investment advisory firms require clients to direct execution of transactions through a specific broker- dealer. Brokerage accounts are carried by, and brokerage transactions are cleared and settled through, AEIS, subject to AEIS policies to assure that the resultant price to the client is as favorable as possible under 76 • Ameriprise Certificate Company • RiverSource, as well as the Columbia Funds underlying certain variable contracts issued by RiverSource • Various wrap program sponsors including Ameriprise Financial Services associated rewards program, savings, certificates of deposits (“CDs”) and checking accounts and pledged asset loans. Ameriprise Bank provides personal trust services to clients, including trustee and investment management services for asset trust, and investment management and custodial agency services for individual, individual trustee, association and non- profit organization accounts. • Other affiliated and unaffiliated clients. Ameriprise Financial Services establishes custodial accounts and accepts securities order instructions for trust accounts at Ameriprise Bank. In addition, Ameriprise Financial Services may provide investment advice and research support to Ameriprise Bank and its clients for these trust accounts. Trust Company Ameriprise Financial, Inc. has other subsidiaries that are registered as investment advisers with the SEC, including, Threadneedle International Limited and Lionstone Partners, LLC. These subsidiaries are registered as investment advisers and may provide advice to domestic and foreign institutional clients, the Columbia Funds, Columbia ETFs, Columbia closed- end funds, private funds and other fiduciary clients. These entities provide services independent from Ameriprise Financial Services. Columbia Management and its affiliates Threadneedle Asset Management Ltd. (U.K. based), Threadneedle Investments Singapore (Pte.) Limited (Singapore based), and Columbia Threadneedle Investments (ME) Limited (Dubai based) operate under a combined global asset management brand, Columbia Threadneedle Investments. Ameriprise Trust Company (“ATC”), a Minnesota- chartered trust company, provides custodial, investment management and collective trust fund services for employer-sponsored retirement plans, including pension, profit sharing, 401(k) and other qualified and nonqualified employee retirement plans. ATC also serves as custodian for IRAs, 403(b)s and some retirement plans qualified under section 401(a) of the Internal Revenue Code of 1986 as well as the Ameriprise Certificate Company. ATC is not a deposit bank or a member of FDIC. Insurance Company CMIA has entered into sub-advisory agreements, delegation agreements, intercompany agreements and “participating affiliate” arrangements with certain of our Non-U.S. Advisory Affiliates, including Threadneedle International Ltd. (“TINTL”), Threadneedle Asset Management Ltd. (“TAML”), Threadneedle Management Luxembourg S.A. (“TMLSA”), Threadneedle Investments Singapore (Pte.) Limited (“TIS”), Threadneedle Investments Services Limited (“TISL”), Columbia Threadneedle Management Limited (“CTML”), Columbia Threadneedle Fund Management Limited (“CTFML”), Columbia Threadneedle Investment Business Limited (“CTIBL”), Columbia Threadneedle Netherlands B.V. (“CTNL”), Pyrford International Ltd (“Pyrford.”) and Thames River Capital LLP (“Thames”), each of which, like us, is a direct or indirect wholly-owned investment advisory subsidiary of Ameriprise Financial. Each of TINTL, TAML, TMLSA, TIS, TISL, CTML, CTFML, CTIBL, CTNL, Pyrford and Thames is registered with the appropriate respective regulators in their home jurisdictions. In addition, Pyrford is also currently registered with the SEC as an investment adviser. Affiliated insurance products sold by Ameriprise Financial Services and its financial advisors are issued by RiverSource Life Insurance Company (“RiverSource Life”), a stock life insurance company that is qualified to do business as an insurance company in the District of Columbia, American Samoa and all states except New York; and in New York only, issued by RiverSource Life Insurance Co. of New York (“RiverSource Life of NY”), a stock life insurance company that is qualified to do business as an insurance company in New York. The products of RiverSource Life and RiverSource Life of NY (together, “RiverSource”) include fixed and variable annuities, structured annuities (RiverSource Life only) and fixed and variable life insurance, disability income insurance and life insurance with long-term care benefits. Insurance products are also offered by other third parties through an arrangement with Ameriprise Financial Services and through Diversified Brokerage Services, Inc., LTCI Partners and Disability Resource Group, which act as co-general agents. Banking Institution RiverSource Distributors, Inc. (“RiverSource Distributors”), a wholly owned subsidiary of Ameriprise Financial, Inc., is a registered broker-dealer, serving as principal underwriter and distributor of RiverSource variable life insurance and annuities on behalf of RiverSource. Ameriprise Financial Services has selling arrangements with RiverSource and RiverSource Distributors to distribute these products. Ameriprise Bank, FSB, a wholly owned subsidiary of Ameriprise Financial, Inc. and an affiliate of Ameriprise Financial Services, is a federal savings bank. In addition to its participation in the AIMMA and ABISA Sweep Programs, Ameriprise Bank currently makes available a core set of banking products, including mortgage financing, co-branded credit cards with an 77 providers, including our affiliate, Ameriprise Bank. Ameriprise Financial Services and the AFIG financial advisor may serve as a finder relating to trust services and may receive a referral fee for business referred to unaffiliated trust providers. Ameriprise Financial Institutions Group (“AFIG”) is a business channel within Ameriprise Financial Services that specializes in delivering investment products and services to clients of financial institutions, such as banks and credit unions. Ameriprise Financial Services enters into networking arrangement with each financial institution whereby AFIG financial advisors provide one or more of our investment advisory services, brokerage services and insurance products to clients of the financial institution and other persons or entities that may be introduced or referred to us by the financial institution. Ameriprise Financial Services is not a bank or credit union. Any services or products you purchase through an AFIG financial advisor are not guaranteed or insured by Ameriprise Financial Services or the financial institution. The financial institution is not a party to your Relationship Agreement with us. Ameriprise Financial Services and each financial institution have entered into a networking agreement under which we have agreed to share fees and commissions with the financial institution, including Asset-based Fees charged for investment advisory services. Non- registered employees of the financial institution may also receive compensation for referring you to Ameriprise Financial Services. How We Get Paid This section should be read in connection with the “Services, Fees and Compensation” and/or the “Client Referrals and Other Compensation” sections in this Disclosure Brochure. The financial institution provides AFIG financial advisors joint marketing access to a distinct client segment and may provide office space in the building where it conducts its business. As a part of the contractual arrangement with the financial institution, Ameriprise Financial Services shares with the financial institution a portion of up to 94% of fees and commissions, including Asset-based Fees charged for investment advisory services, generated by AFIG financial advisors that are attributable to our operations under the joint marketing agreement with the financial institution. A portion of these fees may be paid to financial advisors who are employees of the financial institution, as described below. Ameriprise Financial Services and its affiliates receive revenue from several different sources on the products and services you purchase. These sources include the fees and charges you pay, other arrangements we have in place with product companies, and investment and interest income. The revenue generated or received supports, in part, the development of new products, maintenance of our infrastructure, and retention of employees and financial advisors. Further in this Disclosure Brochure you will find information on how our financial advisors are paid. Cost Reimbursement Services and Third-Party Payments Payments from Product Companies All AFIG financial advisors are licensed and registered through Ameriprise Financial Services. Ameriprise Financial Services has exclusive control over the activities conducted on our behalf under the agreement with the financial institution and is responsible for the supervision of certain activities of AFIG financial advisors. AFIG financial advisors are affiliated with Ameriprise Financial Services in one of three ways: independent contractors and their personnel, Ameriprise employee financial advisors and financial institution employee financial advisors. Financial advisors employed by the financial institution are compensated by the financial institution from the portion of fees and commissions it receives from Ameriprise Financial Services. In such cases the financial institution serves as paying agent on our behalf in accordance with applicable law. The level of compensation received by financial advisors employed by the financial institution is based on their employment agreement with the financial institution. Ameriprise Financial Services does not pay any compensation to any non-registered employee or agent of the financial institution for referrals. Any referral fee paid by the financial institution to an employee or agent is a one- time, per-customer fee of a nominal, fixed dollar amount and is unrelated to the products and services you purchase. AEIS will receive the following types of payments with respect to the investment products we recommend, and you select for the investment of your applicable Managed Account assets. This compensation is used in part to fund the cost of providing the services, maintaining Managed Accounts and offering an investment platform for our clients as well as providing revenue and net earnings to AEIS. For qualified SPS Advisor Accounts, inherited IRAs in qualified SPS Advantage Accounts where a trust has inherited the IRA and Ameriprise Bank acts as trustee of the trust and eligible trustee-directed retirement plans in Select Separate Accounts, AEIS either does not collect Third Party Payments or credits them back to client Accounts as described in the “Fees and Compensation” section. AFIG financial advisors who provide services at a financial institution that does not have a Trust Department can offer trust services through other 78 Ameriprise Financial Services receives cost reimbursement payments on our affiliated and unaffiliated annuity and insurance products which are not eligible investments for Managed Accounts. These payments are discussed in the remaining paragraphs of this section. AEIS performs certain services for the benefit of Ameriprise Financial Services, its financial advisors and clients, including but not limited to record keeping, administration and shareholder servicing support, applicable platform level eligibility and investment product due diligence, investment research, training and education, client telephonic and other servicing, and other support related functions such as trading systems, technology updates, asset allocation and performance reporting tools, websites and mobile applications (collectively “cost reimbursement services”). Any cost reimbursement payments received by AEIS that are paid by product sponsors out of assets of the investment, such as a mutual fund or unit investment trust, reduce the investor return on their investment. If AEIS and its affiliates did not receive this compensation, Ameriprise Financial Services would likely charge higher fees or other charges to clients for the services provided. When evaluating the reasonableness of the fees and expenses incurred in a Managed Account, you should consider not just the Asset-based Fee, but also the fund-level fees and other compensation that Ameriprise Financial Services and its affiliates receive including payments for cost reimbursement services described in this section and other cost reimbursement and marketing support payments received by us and our other affiliates, as described in the “How we get paid” and the “Revenue Sources for other Ameriprise Financial, Inc. companies” sections of this Disclosure Brochure as applicable. AEIS also receives revenues that exceed the costs of the cost reimbursement services provided. These revenues include cost reimbursement and marketing support payments (as described below under the heading “Education, Training, Seminar Reimbursement and noncash compensation”) and such payments increase the gross revenues and net earnings of AEIS. Mutual Fund and 529 Plan Marketing and Sales Support Payments. Mutual fund and 529 plan marketing and sales support payments are received from certain mutual fund firms. These payments form a structure referred to here as the Ameriprise Financial Mutual Fund Program (“Mutual Fund Program”) with approximately 140 mutual fund families offered by Ameriprise Financial Services. The goal at Ameriprise Financial Services is to offer a wide range of mutual funds using the following criteria: • Product breadth and strong-performing funds • Financial strength of the firm Ameriprise Financial Services has a financial incentive for its affiliate to continue to maintain these cost reimbursement arrangements, including arrangements with Full Participation Firms, and for AEIS to continue to receive revenue. Because not all investments provide for cost reimbursement payments, Ameriprise Financial Services has an incentive to recommend or select investment products that make such payments within the Managed Accounts Programs. Ameriprise Financial Services addresses this conflict of interest by applying objective due diligence standards and requiring all mutual funds, ETFs, ETNs, CEFs, UITs and alternative investments offered in the Programs to meet these standards. • Marketing and sales support payments paid to our affiliate AEIS to support cost reimbursement services • Ability to provide product support and training to our financial advisors • Tax benefits offered by individual states • Overall quality of the 529 plan (specific to 529 plans) Ameriprise financial advisors may offer, and clients are free to choose mutual funds from the approximately 140 fund families available. However, certain aspects of the Mutual Fund Program create a conflict of interest or incentive if Ameriprise Financial Services promotes, or Ameriprise financial advisors recommend, the mutual funds offered by a firm participating in the Mutual AEIS receives a variety of payments for cost reimbursement services from affiliated products sponsored or managed by affiliated investment advisers (e.g., Columbia Management) and by non- affiliated investment product companies which reimburse the costs of beneficial client services provided by Ameriprise Financial Services and AEIS. The most significant of these payments are reimbursement for marketing support received from the product companies. AEIS receives cost reimbursement payments from product companies for the following products: mutual funds, 529 plans, actively managed ETFs, UITs, non-traded REITs, real estate private placements, tax-deferred real estate exchanges, non-traded BDCs, fixed annuities, variable annuities, structured annuities, fixed insurance, variable insurance, structured products, managed futures funds, private equity offerings, non-traded closed end funds and hedge fund offerings. Fund Program versus mutual funds offered by nonparticipating firms. As further described below, these conflicts and incentives arise from the cost 79 affiliates receive in connection with client investments in mutual funds and other investment products. Additionally, Ameriprise Financial Services does not share with our financial advisors the cost reimbursement payments we or our affiliates receive. reimbursement related to Education, Training, Seminar Reimbursement and noncash compensation, provided to our financial advisors by, as well as the payments AEIS receives from, firms participating in the Mutual Fund Program and with other relationships with firms, including Columbia Management; see the section titled “Columbia Funds” below. If your Managed Account’s Sweep Program uses a money market mutual fund, AEIS receives cost reimbursement payments of up to 0.37% of the amount held in that money market fund Sweep Program. The amount that AEIS receives may be reduced based on fee waivers that are imposed by the money market fund firm. These arrangements vary between firms and may be subject to change or renegotiation at any time. If a firm ceases to make cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the mutual fund firm. To be included in the Mutual Fund Program, firms have agreed to pay AEIS a portion of the revenue generated from the sale and/or management of mutual fund shares. Full Participation Firms make cost reimbursement payments at a higher level than do firms that have arrangements discussed in the “Other Financial Relationships” section. For each year a client holds shares of a particular mutual fund, the mutual fund’s advisor or distributor may pay AEIS an amount based on the value of the collective mutual fund shares held in clients’ accounts (asset- based payment). AEIS receives an asset-based payment (up to 0.20% per year for mutual funds and 0.18% per year for 529 plans) on some or all of Ameriprise Financial Services clients’ assets managed by the participating firms. In instances where a new Full Participation Firm relationship is established, in certain instances, to offset AEIS expenses for providing cost reimbursement services, the cost reimbursement payments will initially be structured in the form of an annual flat fee in addition to 0.20% of assets invested, with the total dollar amount of such payment not to exceed $1,250,000. Full Participation. Thirty firms fully participate in the Mutual Fund Program. These fund firms include Columbia Threadneedle Investments, Allspring Funds , American Century Investments, Amundi, BlackRock Funds, BNY Mellon, Delaware Investments, DWS Investments, Eaton Vance, Eventide Funds, Federated Hermes, Fidelity, First Eagle Funds, Franklin Templeton, Goldman Sachs Asset Management, Hartford Mutual Funds, Invesco, Janus Henderson Investors, John Hancock Investments, JP Morgan Asset Management, Lord Abbett, MainStay Funds, MFS, Natixis Funds, Neuberger Berman, Nuveen, Principal, PGIM Investments, Virtus and Voya Funds. These firms are referred to as “Full Participation Firms.” We offer 529 plans from nineteen firms. Of those firms, fifteen are Full Participation Firms. These fund firms include American Century, BlackRock, Columbia Threadneedle Investments, Fidelity, Franklin Templeton, Goldman Sachs, Hartford, Invesco, John Hancock, J.P. Morgan, MFS, Nuveen, Principal, Virtus and Voya. Each of these firms is referred to as a “Full Participation Firm.” The most current Mutual Fund Program information, as well as the previous calendar year’s totals of cost reimbursement payments received from Full Participation firms, in addition to distribution support amounts, may be viewed online by visiting www.ameriprise.com/funds and clicking on “An Investor’s Guide to Purchasing Mutual Funds and 529 Plans at Ameriprise Financial”. Certain Full Participation Firms pay our affiliate AEIS more marketing support for certain types of mutual funds. In general, Full Participation Firms offer actively managed mutual funds that permit cost reimbursement payments to be included in the Investment Costs charged by the mutual fund. The Investment Costs of actively managed mutual funds are generally higher than those of (i) passively managed ETFs which do not make cost reimbursement payments; and (ii) actively managed ETFs which do make such payments. Ameriprise Financia Services has a financial incentive to offer actively managed mutual funds and ETFs that make cost reimbursement payments to our affiliate. As a result, Ameriprise financial advisors may have an indirect incentive to sell such mutual funds and ETFs. We address this incentive by offering a full range of investment product options, including actively managed mutual funds and both actively and passively managed ETFs. In addition, we do not offer actively managed ETFs that are clones of an actively managed mutual fund from the same firm. A similar actively managed ETF may have a lower or comparable management fee as an actively managed mutual fund. Ameriprise further addresses this conflict of interest by calculating the compensation paid to our financial advisors for all assets without regard to the amount of cost reimbursement payments we or our Education, Training, Seminar Reimbursement and Noncash Compensation. Full Participation Firms provide to Ameriprise financial advisors and, in some cases, to their clients, education, training, and support services relating to the investment products they offer. These firms may reimburse Ameriprise Financial Services, and Ameriprise Financial Services may subsequently reimburse Ameriprise financial advisors, 80 cost reimbursement services provided for the mutual fund shares purchased during a given period (sales- based payment). These mutual fund firms do not provide marketing and sales support such as those provided by Full Participation Firms to Ameriprise financial advisors, thus they do not have the same access to financial advisors as Full Participation Firms. for client/prospect education events and financial advisor sales meetings, seminars and training events, consistent with Ameriprise Financial Services policies. Ameriprise Financial Services and its financial advisors may also receive nominal noncash benefits from time to time. As a result, Ameriprise financial advisors may have greater familiarity with and an incentive to sell investment products of Full Participation Firms. Firms sponsoring alternative investments may also provide Ameriprise financial advisors (and, in some cases, their clients), education, training, and support services relating to the investment products they offer. Ameriprise Financial Services sells 529 plans from seven firms that do not make cost reimbursement payments to AEIS. Moreover, 529 plans offered by these firms are available for sale to in-state residents only. Those firms are: American Funds, Ascensus, Invesco, MFS, Orion, Union Bank & Trust and Virtus. Certain 529 plans may pay AEIS a fee of up to 1% of assets for NAV rollovers. Payments for Product Implementation and Trading Technology Expenses. The mutual fund’s distributor or affiliate may also make payments to AEIS for networking and/or omnibus support and other client services and account maintenance activities. AEIS will also receive sub- transfer agency fees with respect to investments you make in affiliated and non-affiliated mutual funds. For most investment products, AEIS will receive payments of up to $25,000 per investment product per expense from third-party firms to reimburse expenses associated with each of (i) conducting due diligence on the investment product; and (ii) the implementation of certain technology platforms or capabilities related to the distribution of the investment product. For most model investment portfolios in Signature Wealth and certain SMA strategies in Select Separate Account, AFS will receive payments of (i) up to $25,000 per investment product per expense; or (ii) reimbursement of actual costs incurred to reimburse expenses associated with the implementation of certain technology platforms or capabilities related to the distribution of the investment product. These fees vary depending on the mutual fund family and on whether the mutual fund keeps a separate record for each account (i.e., networked accounts) or relies on AEIS’s recordkeeping (i.e., omnibus accounts). Compensation for sub-transfer agency services range up to $12 per position annually for networked accounts, and up to $19 per position annually for omnibus accounts or, if paid on an asset basis, from 0.10% to 0.15% annually of any amounts you have invested in such mutual funds. In the case of certain no-load fund families for which AEIS has a direct relationship, the compensation for sub- accounting, administrative and distribution support services may be bundled into one asset-based fee of up to 0.35% (which may include a service fee up to a 0.25%) annually of the value of such shares held in an Account. Payments from Investment Providers Offering SMA Investment Portfolios Within the Signature Wealth Program. AEIS receives cost reimbursement payments for the sale of SMA investment portfolios offered within the Signature Wealth Program. AEIS receives an asset-based payment of up to 0.04% per year on Ameriprise Financial Services clients’ assets invested in the SMA investment portfolios. If an Investment Provider ceases to make such cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the firm. Other Financial Relationships AEIS and its affiliates may have other relationships with firms whose mutual funds Ameriprise Financial Services offers. These relationships may include affiliates of firms acting as a sub-adviser to CMIA, CMIA acting as a sub-adviser to a third-party firm, or affiliates of a firm managing an investment portfolio within another Ameriprise Financial Services or affiliated product, such as a RiverSource variable annuity. Firms may use CMIA to manage an underlying investment option in products offered through the Mutual Fund Program. Distribution Support Relationships. AEIS also has cost reimbursement arrangements with firms for distribution support services. These “Available for Sale Firms” make payments to AEIS for distribution support but do not provide marketing and sales support, such as those provided by Full Participation Firms, and make payments at a lower percentage rate than Full Participation Firms. These firms make cost reimbursement payments to AEIS of up to 0.10% on assets for these services, which support the distribution of the fund’s shares and 529 plans by making them available on one or more of Ameriprise Financial Services platforms. In addition, certain mutual funds’ distributors pay a fee to AEIS of up to 0.10% for AEIS has a cost reimbursement agreement with BlackRock Advisors, LLC with respect to mutual fund positions held by Ameriprise Financial Services customers. BlackRock, Inc. owns more than 5% of the outstanding shares of Ameriprise Financial, Inc. stock. Our affiliate CMIA has a sub-transfer agent agreement with Vanguard Group, Inc. with respect to the distribution of its investment products. Vanguard Group, Inc. owns more than 5% of the outstanding shares of Ameriprise Financial, Inc. stock. 81 Columbia Funds. AEIS and other affiliates of Ameriprise Financial Services provide certain administrative and transfer agent services to the Columbia Funds whose shares are owned by Ameriprise Financial Services clients. Ameriprise Financial Services and its affiliates generally receive more revenue from sales of affiliated mutual funds than from sales of other mutual funds. Employee compensation and operating goals at all levels of the company are tied to the company’s success. Certain employees may receive higher compensation and other benefits based, in part, on assets invested in affiliated mutual funds. payments form a structure referred to as the Ameriprise Financial ETF Program (“ETF Program”) and compensate AEIS for the costs of maintaining the ETF Program. Firms participating in the ETF Program are granted full access to Ameriprise Financial Services and our financial advisors to provide direct financial advisor education or sales support to promote their products. Passively managed ETFs and actively managed ETFs that are classified as Eligible to Hold Investments or Ineligible Investments do not participate in the ETF Program, do not have access to financial advisors for education or sales support and do not make cost reimbursement payments, as summarized below. As a result, Ameriprise financial advisors may have greater familiarity with and an indirect incentive to sell ETFs participating in the ETF Program. Ameriprise Financial Services addresses this incentive as described above in the “Mutual Fund and 529 Plan Marketing and Sales Support Payments” sub-section. Participate in ETF Program Yes Access to Ameriprise financial advisors Yes Make cost reimburse- ment payments Yes Actively managed ETFs offered for purchase No No No American Funds. For both affiliated an unaffiliated mutual funds we offer, AEIS receives cost reimbursement payments from mutual fund firms of up to 0.20% of assets invested in those funds. With most mutual fund firms, these payments are paid on an ongoing basis and determined solely based on total assets invested in the funds of a particular fund family held in clients’ accounts. Rather than determining the amount of the payment solely on an asset-based basis, American Funds pays AEIS an annual negotiated platform fee based on a number of factors, including prior year assets, in accordance with their prospectus governing each mutual fund. This platform fee will not exceed 0.20% of assets and will also not exceed the limits set forth in the prospectus governing each fund. You can find the total dollar amounts we receive annually from American Funds, as of the previous calendar year, by visiting www.ameriprise.com/funds and clicking on “An Investor’s Guide to Purchasing Mutual Funds and 529 Plans at Ameriprise Financial.” Actively managed ETFs that are classified as Eligible to Hold Investments or Ineligible Investments No No No American Funds are generally no longer available for new purchases in Ameriprise brokerage accounts (other than add-on purchases into existing positions, which may continue), and thus new investments of American Funds can generally only be executed in Advisory Solution Programs. Passively managed ETFs Ameriprise Preferred Line of Credit and Loan AEIS receives compensation from Ameriprise Bank, FSB for its Ameriprise Preferred Line of Credit and Loan support services. Payments from Alternative Investments Sponsors. AEIS, in consideration for its cost reimbursement services, may receive ongoing investor service and support fee payments from product sponsors of alternative investments available in Ameriprise Managed Accounts. Depending on the product sponsor, AEIS will receive payments of up to 0.25% of the assets invested in these products. Payments from UIT Sponsors. Certain UIT sponsors with which AEIS has agreements may pay AEIS cost reimbursement payments to help promote and support the offer, sale and servicing of UITs. These UIT sponsors are granted full access to Ameriprise Financial Services and our financial advisors to provide direct financial advisor education or sales support to Payments from Other Non-Affiliated Product Companies Payments from Actively Managed ETF Sponsors. For certain actively managed ETFs offered for purchase in Ameriprise Managed Accounts, AEIS receives from the ETF manager or distributor both (i) ongoing asset- based cost reimbursement payments of up to 0.18% of the assets invested in these products; and (ii) an annual flat program fee of up to $400,000 per manager or distributor. AEIS receives these payments to help promote and support the offer, sale and servicing of actively managed ETFs. These 82 Payments from Structured Products Sponsors. AEIS receives cost reimbursement for the sale of structured products. Depending on the structured product, AEIS will receive payments between 0.25% and 0.60% of the amount you invest, multiplied by the product’s term up to a maximum of 1.6%. For example, a structured note with a three-year term and a 0.40% payout could have an upfront payment of 1.2% (three years x 0.40%). Payments for Financial Advisor Support. Separately, for alternative investment products, AEIS will receive marketing and sales support payments in the form of an optional subscription for financial advisor support for a fixed annual fee of up to $250,000, which when combined with the payments described above for these types of investment products may exceed the ranges noted. promote their products. UIT sponsors without such agreements do not provide direct financial advisor education or sales support, thus they do not have the same access to financial advisors as full access firms. Such marketing and sales support may create a conflict of interest if Ameriprise Financial Services promotes, or Ameriprise financial advisors recommend, the UITs from UIT sponsors that have been granted full access versus UITs offered by nonparticipating firms. These conflicts may arise from the marketing and sales support provided to our financial advisors by, as well as the payments AEIS receives from, firms that have entered into such agreements. AEIS will receive both a fixed dollar amount of cost reimbursement payments, based in part on projected UIT sales, as well as sales-based volume concessions. The total amount of these payments will not exceed 0.20% of total UIT sales. Payments from Insurance Companies. Cost reimbursement payments are received by Ameriprise Financial Services and/or its affiliate, AEIS, from affiliated and unaffiliated insurance companies. Ameriprise Financial Services sells annuity and insurance products to its clients manufactured by its affiliate, RiverSource, as well as from select unaffiliated insurance companies. RiverSource and potentially other unaffiliated insurance companies may be permitted to reimburse Ameriprise Financial Services or AEIS, and these entities may subsequently reimburse Ameriprise financial advisors, for client/ prospect educational events and financial advisor sales meetings, seminars, and training events consistent with Ameriprise Financial Services and AEIS policies, as applicable. These companies may also provide support to the Ameriprise Financial Services internal sales desk, which in turn provides support to financial advisors. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource insurance and annuity products and the unaffiliated insurance companies who provide added educational support. Generally, unaffiliated insurance companies that issue annuities and life and disability income insurance policies do not provide direct client or financial advisor education or sales support, other than product training materials, product sales literature and addressing client service issues. However, in some instances direct financial advisor product education may occur. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource products. From unaffiliated long-term care insurance product manufacturers, AEIS receives payments up to 27.5% of the commissionable premium. AEIS receives varying payments from unaffiliated life, disability and other insurance product manufacturers. Mutual Funds & ETFs Available to Investment Managers. Investment Managers that construct investment strategies utilizing mutual funds and ETFs may utilize any mutual fund or ETF available for sale in our Programs provided the fund selected meets operational and other requirements designed to facilitate transaction execution and ensure timely order processing. Ameriprise Financial Services does not require Investment Managers to limit the mutual funds and ETFs utilized to only those that a financial advisor may recommend to a client in an SPS Advantage or SPS Advisor account or for a nondiscretionary mutual fund or ETF transaction in an Investor Unified Account or Vista Separate Account. Mutual funds and ETFs available for financial advisor recommendations are subject to initial and ongoing due diligence by the IRG based on a quantitative and qualitative process. Investment Managers are responsible for conducting their own independent due diligence and research on the mutual funds and ETFs utilized in constructing an SMA investment strategy or model portfolio available through the Programs. This may result in an Investment Manager reaching a different opinion for a particular mutual fund or ETF than the opinion of the IRG on that same investment. The IRG conducts initial and ongoing due diligence on Investment Managers available through the Programs and provides recommendations to the Oversight Committee on matters including due diligence findings that could result in a recommendation for termination. Mutual funds meeting the operational and other requirements noted above primarily consist of mutual funds from “Full Participation Firms.” AEIS receives cost reimbursement payments from the fund family when Investment Managers select mutual funds from “Full Participation Firms” for an investment strategy. The amount of any cost reimbursement payments AEIS receives from mutual fund firms is not considered in determining which funds are available to Investment Managers. Investment Managers do not have access 83 to specific information on which mutual funds are offered by “Full Participation Firms” or the rate of reimbursement a “Full Participation Firm” pays AEIS for cost reimbursement services. List. Similarly, Ameriprise brokerage account clients may be unable to purchase a mutual fund on the Starting Point List if that fund does not offer a share class available in Ameriprise brokerage accounts. In addition, some mutual funds included on the Starting Point List may offer lower-cost share classes than the Advisory Share class or other share class available in Advisory Solutions. You should consider whether you may be eligible to purchase these lower- cost share classes outside the Programs. These eligibility criteria are designed by Ameriprise Financial Services to primarily include, and therefore favor, mutual funds from Full Participation Firms. To be included in the Mutual Fund Program and be eligible for inclusion on the Starting Point List, each Full Participation Firm must meet a number of criteria that consider product breadth and strong-performing funds, financial strength of the firm and the ability to provide education and training to Ameriprise financial advisors, including marketing and sales support services relating to the funds they offer. Full Participation Firms have also agreed to pay our affiliate, AEIS, a portion of the revenue generated from the sale and/or management of fund shares as further described above. Mutual Fund & ETF Recommended List (“Starting Point List”) Ameriprise financial advisors may make mutual fund recommendations based on a group of funds that appear on the Starting Point List. Financial advisors are not required to use the Starting Point List as their source for mutual fund and ETF recommendations, and mutual funds contained on the Starting Point List may not be equally available across both Managed Accounts and Ameriprise brokerage accounts. All ETFs and mutual funds offered by Full Participation Firms or Available for Sale Firms, as further discussed below, must meet Ameriprise Financial Services’ due diligence standards to be eligible for inclusion on the Starting Point List. In developing the Starting Point List, the IRG applies a quantitative and qualitative evaluation process that includes an analysis of a fund’s returns, risk and expenses; the tenure and quality of the investment team; the soundness of the process and consistent implementation; and the overarching health of the organization. Certain mutual funds and ETFs that would have otherwise been included on Starting Point were excluded due to their high investment minimums. Client suitability must be considered when trading mutual funds and ETFs, including breakpoint discount eligibility and NAV transfer ability. The funds on the Starting Point List are subject to change periodically, however changes to the Starting Point List should not be the sole reason to prompt trading. The universe of mutual funds eligible for purchase in Signature Wealth generally represents a sub-set of the funds that appear on the Starting Point List or are otherwise sponsored or managed by Full Participation Firms that make cost reimbursement payments to AEIS. The list of eligible funds for Signature Wealth is therefore designed to primarily include, and therefore favor, mutual funds from Full Participation Firms. The Starting Point List is developed by the IRG based on eligibility criteria established by Ameriprise Financial Services. The universe of ETFs includes funds sponsored or managed by firms in the ETF Program and ETFs available for sale at Ameriprise. Approximately 2,100 mutual funds are eligible for inclusion on the Starting Point List. The primary universe of mutual funds includes only mutual funds sponsored or managed by Full Participation Firms in the Mutual Fund Program. If a suitable mutual fund recommendation for a particular asset class cannot be found within the Full Participation Firms’ offerings, the IRG will proceed to look for mutual fund options sponsored or managed by Available for Sale Firms. While the Starting Point List is developed by evaluating the performance characteristics of each fund’s Class A shares, the analysis is ultimately intended to apply at the mutual fund level. Mutual funds included on the Starting Point List may or may not offer an Advisory Share class or other share class that is available in our Managed Accounts Programs. As a result, Managed Account clients may be unable to purchase a fund on the Starting Point Available for Sale Firms make payments at a lower percentage rate than Full Participation Firms. They do not have the same wholesaling access to financial advisors as Full Participation Firms. As a result, Ameriprise financial advisors may have a greater familiarity with and an incentive to sell funds of Full Participation Firms. The payments made to AEIS by Full Participation Firms and Available for Sale Firms reimburse the costs of client beneficial services provided by Ameriprise Financial Services and AEIS to financial advisors and clients, including but not limited to distribution, marketing, administration and shareholder servicing support, due diligence, training and education, and other support related functions (e.g., cost reimbursement services) and increase the revenues and profitability of AEIS. The most significant of these payments are reimbursement for marketing support received from Full Participation Firms and other product companies. Full Participation Firms make cost reimbursement payments at a higher percentage rate than do Available for Sale Firms. This presents a conflict of interest as Full Participation Firms pay AEIS more revenue than Available for Sale Firms, and thus 84 investment options for 529 plan assets) and distribution fees paid from Ameriprise Certificate Company assets. 12b-1 shareholder servicing fees assessed in Ameriprise brokerage accounts may be used to pay for marketing, distribution and shareholder service expenses. Any 12b-1 shareholder servicing fees received for the share class utilized in Managed Accounts will be rebated to clients. AEIS earns more revenue from the purchase of mutual funds offered by Full Participation Firms than from the purchase of mutual funds offered by Available for Sale Firms. Clients may choose to follow the recommendations provided by their Ameriprise financial advisor or they may select from any of the other funds offered through Ameriprise Financial Services regardless of whether that fund appears on the Starting Point List. More information on the Full Participation Firms that participate in the Program, specific arrangements we have with them, and conflicts of interest or incentives that exist for Ameriprise Financial Services to promote (and for Ameriprise financial advisors to recommend) one fund over another fund is provided on our website at ameriprise.com/funds and click “Purchasing Mutual Funds Through Ameriprise.” Ameriprise Preferred Line of Credit and Ameriprise Preferred Loan. Ameriprise Financial Services receives compensation from Ameriprise Bank of 0.25% of the outstanding balance on the credit line or loan on an annualized basis. This amount is shared with your Ameriprise financial advisor based on how your advisor is affiliated with us and on the payout rate for which your financial advisor qualifies. These affiliations and compensation structures are described in the “Financial Advisors Compensation & Benefits” section of this Disclosure Brochure. Revenue Sources for Ameriprise Financial Services, LLC Financial Planning and Advisory Service Fees These are fees you pay for financial planning and fee- based investment advisory account services, respectively. Ameriprise Bank Savings Account and CDs. Ameriprise Financial Services receives compensation from Ameriprise Bank of 0.05% of the average monthly balance, on an annualized basis. This amount is shared with your Ameriprise financial advisor based on how your advisor is affiliated with us and on the payout rate for which your financial advisor qualifies. These affiliations and compensation structures are described in the “Financial Advisors Compensation & Benefits” section of this Disclosure Brochure. Ameriprise Brokerage Account Sales Charges. Sales charges, commissions and/or selling concessions are paid when you buy or sell equities or fixed income products including corporate bonds and municipal securities, mutual funds, ETFs, 529 plans, closed- end funds, preferred securities, UITs, non- traded REITs, non-traded BDCs, non-traded closed-end funds, hedge fund offerings, exchange funds, private equity offerings, managed futures funds, real estate private placement offerings and structured products. In addition, you may pay a markup or markdown in bond transactions executed in a principal capacity with AEIS. These charges vary by product and product type. Payments for Referrals to Structured Settlements Annuity Brokers. Ameriprise Financial Services receives a fee, shared with financial advisors, for referrals to non- affiliated structured settlement professionals for both client and non-client referrals. The amount and basis for the referral fee varies by relationship multiplied by the notional sales amount of the product. Underwriters’ Compensation. Ameriprise Financial Services receives a fee comprised of a selling concession, management fee, underwriting fee, and in some cases, a structuring fee for the sale of initial public offerings (“IPOs”) such as closed-end funds and preferred securities. The specific amounts vary by individual offering, and are disclosed in the prospectus of each offering. For example, with respect to mutual funds, the sales charge for a stock mutual fund is typically greater than that for a bond mutual fund. For other product types such as non-traded REITs, the sales charge you pay may also include a portion of the distribution, organization and offering fees and expenses. See the Working in Your Best Interest – Regulation Best Interest Disclosure for more information about costs, compensation and potential conflicts of interest relating to brokerage products and services. Periodic Fees. Periodic fees include IRA custodial fees, brokerage fees (i.e., account maintenance and order handling fees), and a portion of the fees associated with certain banking products and services (i.e., personal trust services). Periodic Expenses. Periodic expenses are paid from product assets, such as 12b-1 shareholder servicing fees paid from mutual fund assets (including 12b-1 fees paid on certain funds that serve as underlying Transaction Charges. Ameriprise Financial Services does not assess online transactions charges in Managed Accounts to financial advisors. Franchisee financial advisors are assessed a transaction charge if entering an order by phone for SPS Advantage or SPS Advisor accounts. For employee financial advisors, this transaction charge is assessed to the employee’s branch, and not paid by the advisor. Direct payment by the financial advisor of phone-in transaction charges may be a disincentive for a franchisee financial advisor to recommend an SPS Advantage or SPS Advisor account or to recommend trades in the account(s). 85 financial advisor receive more compensation on fund or share classes that pay higher fees. For Managed Accounts, Ameriprise financial advisors pay the same mutual fund transaction rate for orders entered by phone for all mutual fund firms. Not all mutual fund families are available for purchase in a Managed Account. For more information about payments and potential conflicts of interest, please see the applicable prospectus, term sheet, application or other client disclosure forms. Ameriprise Financial Services and the financial advisor generally receive less compensation when the sales charge and/or 12b-1 fee is reduced, waived completely, or where there is no sales charge or 12b-1 fee. Therefore, for brokerage accounts there is an incentive for our financial advisors to sell a fund that pays a load or a fund that pays a 12b-1 fee over funds that do not. Distribution Access Fees As described above, Ameriprise Financial Services directs securities purchase and sale transactions through our affiliate, AEIS, on a fully disclosed basis. In exchange, Ameriprise Financial Services receives reimbursements from AEIS for our non-distribution related expenses. Financial Interest in Products Ameriprise Financial Services and Ameriprise financial advisors are paid in different ways for helping you choose mutual funds, depending on the type of fund, amount invested, and share class purchased. Financial advisors receive compensation only from 12b-1 fees for mutual funds held in brokerage accounts. Ameriprise Financial Services and financial advisors receive more compensation for sales of certain types of products, such as insurance, rather than others. Economic Benefits of Affiliates’ Products and Services Ameriprise Financial Services has a financial interest in the sales of proprietary products that are manufactured by its affiliates. Ameriprise Financial Services and its affiliates receive more revenue from the sale of some financial products and services, particularly those products and services sold under the Ameriprise, Columbia Threadneedle Investments and RiverSource brands, than for the sale of other products and services. As with all financial services firms, a portion of our revenue and compensation can generate a profit for the firm. The revenue and compensation we receive helps us cover our expenses in providing and servicing these products and services. Employee and financial advisor compensation and operating goals at all levels of Ameriprise Financial, Inc. are tied to the success of its businesses. As a result, certain incentives and conflicts of interest may exist for Ameriprise Financial Services, our affiliates and our financial advisors if you purchase certain products or services recommended by your financial advisor. Generally, among other things, Ameriprise Financial Services and our affiliates will receive: Generally, Ameriprise Financial Services receives more revenue for securities or products sold in a fee-based account than for those sold with only a sales charge or commission. Higher revenue generally results in greater profitability for Ameriprise Financial Services. Employee compensation (including management and field leader compensation) and operating goals at all levels of the company are tied to the company’s success. Management, sales leaders and other employees generally spend more of their time and resources promoting Ameriprise, Columbia Threadneedle Investments and RiverSource branded products and services. • More revenue, in aggregate, from the purchase of products sponsored or managed by Ameriprise, Columbia Management and RiverSource (“proprietary products”) than from the purchase of products sponsored or managed by firms that aren’t affiliated with Ameriprise Financial, Inc. (“nonproprietary products”). Ameriprise Financial Services actively promotes the products of our affiliates through advertising, direct mail, and product support and training events. • More revenue from the purchase of products and services than from Asset-based Fees. • More revenue as the size of any margin account or Ameriprise Preferred Line of Credit balance increases. • More revenue when you purchase certain types of products, such as insurance and annuity products and direct investments. • More revenue from products and services that generate ongoing revenue streams, such as Any 12b-1 fees received by Ameriprise Financial Services for mutual funds held in any Managed Accounts will be rebated to clients, and financial advisors do not receive compensation from 12b-1 fees assessed on mutual funds held in Managed Accounts. For brokerage accounts, both Ameriprise Financial Services and individual financial advisors are compensated when clients buy mutual funds through Ameriprise Financial Services. Generally, financial advisors receive a portion of the sales charge and 12b-1 fees paid to the firm in connection with mutual fund purchases for as long as clients own the mutual fund shares. Sales charges and 12b-1 fees vary from mutual fund to mutual fund and from share class to share class. Ameriprise Financial Services and the 86 RiverSource Life of New York, affiliates of Ameriprise Financial Services. mutual funds that pay ongoing 12b-1 fees, an investment advisory account service, and insurance and annuity products with mortality and expense charges. • More revenue when you purchase shares of mutual funds or 529 plans from Full Participation Firms than from firms with other distribution support relationships, as described in the “Cost Reimbursement Services and Third Party Payments” section of this Disclosure Brochure. Ameriprise Financial Services grants RiverSource access to Ameriprise financial advisors and provides RiverSource with limited information related to Ameriprise clients to promote sales of RiverSource products and to assist financial advisors in understanding the features and benefits of those products. Ameriprise Financial Services does not grant this access to other non- affiliated companies offering similar products, thus they do not have the same access to financial advisors as RiverSource. • More revenue when you purchase investment • products for which we receive cost reimbursement payments or have similar financial arrangements, as described in the “Cost Reimbursement Services and Third Party Payments” and “Revenue Sources for Ameriprise Financial Services, LLC” sections of this Disclosure Brochure. Less revenue when a sales charge or commission is reduced or waived completely, or where there is no sales charge. • More revenue when you move assets (including retirement plan accounts) from another institution to Ameriprise Financial Services or RiverSource or into a product managed by Columbia Management or another affiliate. Financial advisors are required to take training on complex products developed by Ameriprise Financial Services and its affiliates and non-affiliated product manufacturers, prior to soliciting certain insurance and annuity products and a targeted subset of nonproprietary products. Additionally, it is possible that Ameriprise Bank would send an order on behalf of a trust account to AEIS and at the same time AEIS would execute the opposite order for a brokerage client. Investments may be made for Ameriprise Bank’s trust accounts in which Ameriprise Financial Services or its related persons have a position or interest. Although Ameriprise Financial Services and its related persons may own securities suitable for or held by clients, in no case will holdings of Ameriprise Financial, Inc., its subsidiaries or their employees or directors be directly sold to or purchased from Ameriprise Bank’s trust accounts. AEIS, an affiliate of Ameriprise Financial Services, may buy or sell for its own account securities that Ameriprise Financial Services may recommend for Ameriprise Bank’s trust accounts. Ameriprise Financial Services does not anticipate that conflicts of interest will arise because we have adopted policies and procedures prohibiting Ameriprise Financial Services and our related persons from engaging in trading activity that creates a conflict of interest with our clients, as discussed in the “Code of Ethics, Participation or Interest in Transactions and Personal Trading” section. Financial Advisors Compensation & Benefits The compensation programs for our financial advisors may vary based on, among other factors, the financial advisor’s industry experience, tenure with Ameriprise Financial Services, the type of practice structure (solo or team), and whether the financial advisor was formerly associated with a firm acquired by Ameriprise Financial, Inc. Additional general product training is available and specific product training is required for a number of complex products, including Columbia Threadneedle Investments and RiverSource branded products. It is likely that a product recommendation from your financial advisor will be drawn from the universe of products on which they were trained. Ameriprise Financial Services may enter into strategic alliances with companies that offer products or services that Ameriprise Financial Services and its financial advisors do not sell. As part of those alliances, Ameriprise financial advisors may receive gifts or non-cash compensation from the other companies, which are subject to SEC and FINRA regulations as well as Ameriprise Financial Services’ internal compliance policies. Some, but not all, of the financial planning software tools available for use by your financial advisor were developed by Ameriprise Financial Services or by unaffiliated third parties and may make it more convenient for your financial advisor to select proprietary products. An Ameriprise financial advisor is assigned to every investment advisory service. Ameriprise financial advisors have a wide range of business and educational backgrounds. They are required to have appropriate licenses and registrations to transact business, including Financial Industry Regulatory Authority (“FINRA”) registration, required state securities and insurance licenses and carrier appointments, and, where required, a state investment adviser representative registration. Most Ameriprise financial advisors are also appointed agents of RiverSource Life and, in New York only, 87 employing or contracting independent contractor franchisee, the associate financial advisor may receive a bonus. Advisory Fees and Compensation Many financial advisors hold advanced academic degrees and/or professional designations, including Certified Financial Planner™ (CFP®) designation. In addition, ongoing training is available to financial advisors. For additional important information about an advisor check FINRA BrokerCheck at www.finra.org/brokercheck or call 800.289.9999. Your financial advisor earns a living by providing you with financial advice and product recommendations to suit your goals. To understand how your financial advisor gets paid, you should first know that there are four ways Ameriprise financial advisors can be affiliated with us. The Advisory Fee is the only component of the Asset- based Fee you pay that is shared between Ameriprise Financial Services and your financial advisor. Both independent contractor franchisee financial advisors and employee financial advisors receive advisor is paid a portion of the Advisory Fee and, if applicable, a portion of the AFPS Fee as compensation for your participation in a Program. Independent contractor franchisee financial advisors, however, receive a higher portion, or payout rate. • Independent Contractor Franchisees. These financial advisors are not employed by Ameriprise Financial Services and they do not receive a salary from us. • Employee Financial Advisors. These financial advisors are employed by Ameriprise Financial Services. • Associate Financial Advisors. These financial advisors are employed by or contract with the independent contractor franchisees and they do not receive a salary or other compensation from Ameriprise Financial Services. • Financial Institution Employee Financial A portion of the Advisory Fee including the AFPS Fee, if applicable is paid to your financial advisor for their role that supports your participation in a Program, including introducing you to the service, gathering the information necessary to prepare your service, helping you establish needs and goals, preparing and presenting your service, and/or providing financial advice on behalf of Ameriprise Financial Services. The remaining portion of the Advisory Fee goes to Ameriprise Financial Services for the supervisory, technical, administrative, and other support that is provided to all financial advisors, as further discussed in the “Fees and Compensation” section. The actual portion of the Advisory Fee paid to your financial advisor depends on the payout rate for which your financial advisor qualifies and the amount of Advisory Fees you pay. • Advisors. These financial advisors are employed by the financial institution where they provide services and are compensated by the financial institution from the portion of fees and commissions it receives from Ameriprise Financial Services. The financial institution serves as paying agent for such compensation on our behalf in accordance with applicable law. Financial institution employee financial advisors’ compensation is based on their employment agreement with the financial institution. Independent contractor franchisees generally receive 72% to 91%, and employee financial advisors generally receive 0% to 46%, of the Advisory Fee (the “advisor payout rate”). In addition, the financial advisor may qualify for a bonus which could increase the effective advisor payout rate up to 91% for independent contractor franchisees and 57% for employee financial advisors, respectively. • All Ameriprise financial advisors are licensed registered representatives. Depending on the affiliation, our financial advisors are compensated differently. Financial advisors may choose to change how they are affiliated with Ameriprise Financial Services over time. Financial institution employee financial advisors generally receive 0% to 91% of the Advisory Fee based on their employment agreement with the financial institution. Salary and Bonus • If you are a client of the Ameriprise Personal Wealth Group, your employee financial advisor does not receive a portion of the Advisory Fee but may receive compensation in the form of a bonus based in part on revenue generated through your Advisory Fee. • In addition to the fees described below, employee financial advisors may receive a salary or wage from Ameriprise Financial Services. Associate financial advisors may receive either a salary or a flat fee from the independent contractor franchisee for whom they work, at the discretion of the employing or contracting independent contractor franchisee. In general, Advisory Fees generated by an associate financial advisor are paid to the employing or contracting independent contractor franchisee. At the discretion of the employing or Financial advisors may also have the potential to receive bonus compensation. At the discretion of the 88 contracting independent contractor franchisee, the associate financial advisor may receive financial advisory or referral fees. and disclosure and by supervising the suitability of recommendations made by its financial advisors in accordance with all applicable regulatory requirements. Depending on these factors, your financial advisor may retain a larger portion of the Advisory Fee and, in those instances, may earn more than Ameriprise Financial Services’ portion, however your financial advisor must make recommendations based on your best interests and without regard to how much compensation will be received. Other Compensation Available to Financial Advisors Ameriprise Financial Services offers a vast range of investment solutions to clients. Some products and services may be offered only by certain Ameriprise financial advisors. Discuss with your financial advisor the products he or she offers and the compensation your financial advisor receives, as some investment product companies and issuers, including RiverSource, may pay higher compensation than others. Importantly, financial advisor compensation does not vary depending upon the investment(s) recommended to you within a Managed Account. However, the amount of this compensation may be more or less than what your financial advisor would receive if you paid separately for investment advice, brokerage and other transaction-based services. Therefore, your financial advisor may have a financial incentive to recommend a Program over a transaction-based brokerage account. Ameriprise Financial Services seeks to address this conflict of interest through a combination of disclosures and through our policies, procedures and supervision, related to the review and determination that a Managed Account is appropriate for you based on your financial and risk profile information and investment objectives (“Client Information”) in accordance with all applicable regulatory requirements. Generally, among other things, your financial advisor may earn: The portion of the Advisory Fee allocated to your financial advisor is impacted by factors including: • The type of affiliation that your financial advisor has with Ameriprise Financial Services; • More depending on how your financial advisor is affiliated with Ameriprise Financial Services, as described above • Whether your financial advisor was assisted by • More on the sale of certain fixed life and disability another person (which may be a financial advisor or another individual who makes a referral) in providing services to you; • The total and average assets his or her clients have invested in Managed Accounts; insurance products because of special compensation programs that provide increasing levels of compensation the more a financial advisor sells of these products from each individual insurance company. • • More on the purchase of annuity and insurance The specific level of Managed Account assets within a given client’s household; and • In which Program your Managed Account is held. products and direct investments, because they are more complex than other products and take more time to service. Information for Certain Clients investing in Manager Directed Programs • More revenue from products and services that generate ongoing revenue streams, such as mutual funds that pay ongoing 12b-1 fees, an investment advisory account service, and insurance and annuity products with mortality and expense charges. • More from certain sales incentive programs to increase overall assets under management. • Less on individual purchases within a transaction- based brokerage account because of the higher transaction charges your financial advisor pays on these accounts compared to a fee-based investment advisory account. • Less when a sales charge or commission is reduced or waived completely, or where there is no sales charge. • Typically, less when you exchange an existing annuity contract, mutual fund or insurance policy for certain like or similar products from the same Your financial advisor must make recommendations based on your best interests without regard to their compensation. The portion of the Advisory Fee shared with your financial advisor is determined by several factors including the total assets their clients (or clients within an advisor’s team) have invested in Managed Accounts. Franchisees and certain financial institution financial advisors that contract with Ameriprise Financial Services on an independent contractor basis (“AFIG Independent Contractors”) receive a greater portion of the Advisory Fee for than for the SPS Advantage and SPS Advisor Programs. This difference in allocation creates is a conflict of interest for Franchisee financial advisors, their associate financial advisors and AFIG Independent Contractor financial advisors because there is a greater incentive to recommend the Manager Directed Programs. Ameriprise Financial Services manages this conflict of interest through a combination of policies, training, 89 company, unless you have held the existing product for a certain period of time. • More revenue if you purchase securities on margin that you could not otherwise purchase in a cash account. • A higher payout rate based on the level of product sales, on the number of financial plans sold, and on higher face value and/or death benefit amount for certain insurance products. • More when you move accounts (including retirement plan accounts) from another institution to Ameriprise Financial Services, CMIA or RiverSource. and receives, directly or indirectly, compensation from the unaffiliated insurer for the sale and service of that product. The compensation for these nonproprietary products and RiverSource products is separate from, and in addition to, any fee you pay for investment advisory services and may vary depending on the type and size of the life insurance or annuity product that you purchase, the insurer that issues the product, the total number of life insurance and annuity products sold by the financial advisor for that insurer, and other factors. This compensation typically will increase as the size of the insurance policy or annuity contract increases, or the amount of the payments that you make on the life insurance or annuity product increases. • If your financial advisor is a shareholder of Ameriprise Financial through our deferred compensation program, more compensation the more profitable the firm is. • Generally, the compensation that the financial advisor will receive is calculated by a formula. Compensation may also increase as the financial advisor sells increasing amounts of life and disability income insurance products issued by that insurer. Compensation for servicing trust accounts held with Ameriprise Bank. • Compensation for performing certain activities associated with your mortgage if that loan is purchased and serviced by Ameriprise Bank. • In instances where a customer already owns a financial product sold by Ameriprise Financial Services, the amount of a financial advisor’s compensation may vary in connection with the sale of an additional or replacement product, due to formulas relating to the cancellation of a product that is already owned. Compensation for providing services related to your Ameriprise Preferred Line of Credit based on an annualized fixed percentage of the client’s average daily outstanding balance. • Compensation for your Ameriprise Bank Savings Account and CD balances based on an annualized fixed percentage of the client’s average monthly balance. • As a result, the financial advisor in such a transaction may have an incentive to recommend the purchase of additional or replacement insurance or annuity products or, conversely, an incentive to recommend that you not purchase additional or replacement insurance or annuity products, depending on the relevant compensation formula. Compensation for marketing that leads to you opening a co-branded credit card account provided you activate the card and meet the initial spend requirements. Financial Advisors Compensation - Credit Products & Insurance Referral • Compensation for marketing that leads to your opening of an Ameriprise Bank Checking Account provided you meet the initial funding and other balance duration requirements. Your financial advisor receives compensation for the marketing that leads to your opening of a co-branded credit card account provided you activate the card and meet initial spend requirements. • Compensation for the sale or renewal of Ameriprise Certificates. Financial Advisors Compensation - Insurance and Annuity Products Ameriprise financial advisors will earn compensation for providing services related to your Ameriprise Preferred Line of Credit based on an annualized fixed percentage of the client’s average daily outstanding balance. Your financial advisor will receive compensation for performing certain activities associated with your mortgage if that loan is purchased and serviced by Ameriprise Bank. Our financial advisors primarily offer life and disability insurance and annuity products from RiverSource and certain pre-approved, but unaffiliated, insurance companies. However, in some situations where the client’s needs may be met more effectively by another company’s product, and RiverSource and other pre- approved providers do not offer such a product, Ameriprise financial advisors may offer insurance products issued by unaffiliated insurance companies. Your financial advisor receives referral fees when you purchase and maintain American Family Insurance, insurance products under a long-term distribution agreement between Ameriprise Financial Services, American Family Insurance Group and American Family Insurance (formerly Ameriprise Auto & Home). American If an unaffiliated insurance product is offered, the financial advisor is an appointed agent of the insurer 90 Family Insurance is not affiliated with Ameriprise Financial Services and is owned by the American Family Insurance Group. If Ameriprise Bank accepts a trust based upon a referral from your financial advisor, Ameriprise Financial Services will receive a referral fee from Ameriprise Bank. A portion of this referral fee is shared with your financial advisor. The referral fee is paid by Ameriprise Bank from the fees earned for its services and is not an additional cost to the trust account. Your financial advisor also receives a referral fee for referrals to non- affiliated structured settlement professionals for both client and non-client referrals. Financial Advisors Compensation - Incentives, Training and Education upon the value of eligible assets or accumulated production of the recruited financial advisor at a pre- determined measurement date. The funds may be payable immediately, over time, as a bonus, or as a loan. These arrangements may be structured to include a provision requiring that payment of transition compensation and/or loans will be dependent upon the advisor meeting certain agreed-upon production and/or asset level benchmarks. The financial incentives associated with these transition arrangements could influence the type and amount of product and/or service recommended by your financial advisor. Ameriprise Financial Services manages this conflict of interest by supervising the suitability of recommendations made by its financial advisors in accordance with all applicable regulatory requirements. Please review your financial advisor’s Form ADV brochure supplement or ask your advisor if you have questions about whether these transition arrangements apply to them. From time-to-time, Ameriprise Financial Services also provides compensation to financial advisors in connection with the sale of all or a portion of their client base to an Ameriprise financial advisor. Some of this compensation may be dependent on a certain percentage of the client base remaining as clients of Ameriprise Financial Services for a certain period of time. It is also determined based on valuations of the financial advisor’s practice, or book of business. Product companies with which we have agreements work with Ameriprise Financial Services and our financial advisors to promote their products. They may pay for training and education events or due diligence meetings; and may reimburse expenses for prospecting events such as seminars for employees, financial advisors, clients and prospective clients. For employees and financial advisors, these events may be held at off-site locations, and the travel, meals and accommodations may be paid for by the product company. Additionally, product companies may occasionally provide business or recreational entertainment or gifts of nominal value to employees and financial advisors. Ameriprise Financial Services or sales leaders may, from time to time, offer contests or incentive programs to individual financial advisors or groups of financial advisors in particular areas. These contests and programs are limited to such targets as new client acquisition, financial plan count, net flows, total assets under management and financial advisor recruiting. The practice valuation formula results in higher compensation for revenues received from Managed Accounts versus Ameriprise brokerage accounts. As a result, your financial advisor has an incentive to recommend the opening of new Managed Accounts or the investment of additional assets into existing Managed Accounts or, conversely, an incentive to recommend that you not open an Ameriprise brokerage account or invest additional assets into a brokerage account. In addition, if your financial advisor is selling all or a portion of their practice to another Ameriprise financial advisor, this program could incentivize your financial advisor to recommend that you remain a client of the acquiring financial advisor and/or Ameriprise Financial Services. Ameriprise Financial, Inc. Equity Programs Single product or product categories are not eligible for sales contests or incentive programs with the exception of fixed life and disability income insurance. These programs and incentives and the receipt of other cash/noncash compensation could affect your financial advisor’s recommendations of products and/or services to you. These programs and incentives and other cash and/or noncash compensation are subject to SEC and FINRA regulations as well as Ameriprise Financial Services’ internal compliance policies. Financial Advisors Compensation - Recruitment We encourage our financial advisors to take an ownership stake in our future by holding stock in our parent company, Ameriprise Financial, Inc. (NYSE: AMP). To make this possible for financial advisors, we have created equity compensation programs for them. Employee financial advisors and independent contractor franchisees may be eligible to receive an annual stock bonus. In addition, independent contractor franchisees may be eligible to defer a certain percentage of their compensation each year. They may choose to invest all or portion of this Ameriprise Financial Services from time-to-time recruits financial advisors from other firms to join Ameriprise Financial Services. In connection with these recruiting efforts, Ameriprise Financial Services may enter into arrangements with financial advisors for the payment of compensation and/or loans based 91 Shared Compensation deferral into a notional account that tracks the performance of Ameriprise Financial, Inc. stock. Financial advisors who are independent contractor franchisees may build equity in their practices and may receive payments if they sell all or a part of their practices to other Ameriprise financial advisors. Loan Programs Financial advisors may also choose to work together as a team to share fees and commissions generated from products and services you purchase. The cost of the product or service you purchase is not affected by the fact that your financial advisor is a member of a team or by the fact that the fee or commission may be split. Clients may have access to information about lending products and services through marketing and/or lending relationships Ameriprise Bank has with third- party financial institutions. Your financial advisor may be allowed to share a portion of the Advisory Fee he or she receives with one or more other Ameriprise financial advisor(s), including financial advisors who have not completed the Ameriprise Financial Services-required training, to sell the investment advisory service, franchise consultants or registered principals, as described below. Ameriprise Bank partners with Rocket Mortgage, LLC (NMLS #3030) that offers mortgage lending products and services. Ameriprise Financial Services and Ameriprise financial advisors do not accept any mortgage loan applications or offer or negotiate terms of any such loans. Financial advisors do not earn compensation related to the origination or referral of mortgage lending products offered and originated by such third-party providers. Ameriprise Bank may purchase and service some loans originated by Rocket Mortgage, LLC. Ameriprise Financial Services and Ameriprise financial advisors may receive compensation for assisting clients with mortgages serviced by Ameriprise Bank. Ameriprise Financial, Inc. is not affiliated with Rocket Mortgage, LLC. Ameriprise Bank does not guarantee products or services offered by Rocket Mortgage, LLC. In cases where two or more financial advisors are assisting you, both financial advisors may share in the Advisory Fee. Your servicing financial advisor will present the Managed Account or AFPS, set the Advisory Fee, and oversee the analysis and advice prepared for you. Your servicing advisor may or may not be the financial advisor authorized to use discretion to purchase and sell securities in your Managed Account (e.g., your SPS Discretionary Advisor). In the instance that your servicing advisor is not authorized to use discretion, the financial advisor authorized to use discretion will oversee the analysis and advice prepared for you. Only the financial advisor authorized to use discretion will purchase and sell securities in your Managed Account. Ameriprise Bank has partnered with Elan Financial Services in offering Ameriprise co-branded credit cards. Your financial advisor receives compensation for marketing efforts that lead to your opening of a co- branded credit card account provided you activate the card and make sufficient purchases. Ameriprise Bank has partnered with Goldman Sachs to make available the Ameriprise Preferred Line of Credit and Loan. Ameriprise financial advisors will earn compensation for providing services related to your Ameriprise Preferred Line of Credit and Loan based on an annualized fixed percentage of the client’s average daily outstanding balance. Apart from margin lending, offered by AEIS, neither your Ameriprise financial advisor nor Ameriprise Financial Services may arrange, promote, suggest or knowingly permit you to use line or loan proceeds to purchase securities or other investment products. Advisor-to-Advisor Training Programs Your servicing advisor may or may not be the financial advisor who has completed the required training for a particular investment advisory service or product. A financial advisor who has not completed the required training may refer a client to a financial advisor who has completed the required training for the service or product. The financial advisor who has completed the required training may pay a fee to the financial advisor who has not completed the required training for that referral. The financial advisor who has not completed the required training may provide investment advisory services for services and products that do not require training, however, only the financial advisor who has completed the required training required for a particular service or product will provide the analysis and advice prepared for you with respect to a service or product that requires the training. The financial advisor who has not completed the required training may receive a share of the commission from any services or products sold to you by your financial advisor who has completed the required training. Your financial advisor may work with a franchise consultant. In those situations, the franchise consultant, who is registered with Ameriprise Financial Services, may receive compensation based on Ameriprise Financial Services or its affiliates may also pay its financial advisors for training other financial advisors on specific products and services that we offer. A portion of this payment may be based on incremental sales of these products and services sold by the financial advisor receiving the training. 92 services and products that you purchase, and for the training and leadership of your financial advisor. The cost of the product or service you purchase is not affected. We will attempt to notify you if your Managed Account is no longer assigned to a financial advisor. If you would like to retain your Managed Account, contact us within the timeframe set out in the notification to have a financial advisor assigned. If the Managed Account remains unassigned after the designated timeframe, it will transfer to an Ameriprise brokerage account in accordance with the Relationship Agreement. Your financial advisor may employ staff or work with other Ameriprise Financial Services staff to assist with creating your financial planning recommendations. This may include leveraging services in geographic locations outside of your financial advisor’s location, including international locations. If your Managed Account does not have a financial advisor assigned to it and certain client directed trades are permitted, you may contact our Service Center at 1.800.862.7919 for assistance with a transaction. Services provided may include entering data into financial planning software, providing initial calculation and assistance in creating solutions. Your financial advisor will provide final recommendations to you. For these services, your financial advisor may pay a fee or salary to employed staff. Financial advisors and field leaders may share compensation with their registered support assistants or recommend bonuses for their non-registered support staff. Employee financial advisors and selling leaders may receive continuing commissions and fees for the sale of certain products and services for up to five years after leaving the securities industry. We will continue to collect and retain the full amount of any Asset-based Fees paid to us in connection with your Managed Account, less any Manager Fees paid to an applicable Advisory Service Provider, until the Managed Account is designated for potential transfer to an Ameriprise brokerage account or terminated. This includes the portion of the Advisory Fee that would have been paid to a financial advisor if one was assigned to your Managed Account(s). The fees retained are used in part to pay other employees and for the technology that supports the services Ameriprise Financial Services provides to you. Ameriprise offers a Business Development Account (BDA) Program. Eligible employee financial advisors may create a voluntary BDA in a predetermined amount and use this account for business-related expenses above and beyond what the company provides. Managed Accounts Without a Financial Advisor Management Compensation and Bonus Programs Employee compensation and operating goals at all levels of the company are tied to the company’s success. All employees, directly or indirectly, may receive higher compensation and other benefits when the investment products of certain providers, particularly affiliates, are purchased. Management, sales leaders and other employees spend more of their time and resources promoting Ameriprise, Columbia Threadneedle Investments, and RiverSource branded products and services. In the event that you request Ameriprise Financial Services to remove your current financial advisor from your Managed Account or your financial advisor resigns from Ameriprise Financial Services or your Managed Account, is terminated, or, for the SPS Advisor Program, your financial advisor is no longer able to act as your SPS Discretionary Advisor for any reason, the applicable Managed Account(s) will no longer have a financial advisor assigned to the Accounts. Generally, investment products in Managed Accounts can only be purchased through an Ameriprise financial advisor. Field leaders receive a salary and a bonus and are responsible for an operating budget for expenses. Bonus programs for Ameriprise Financial Services field leaders are designed to include an amount based on the aggregate sales of all products sold by financial advisors, including proprietary products, in the regions of the country those leaders are responsible for overseeing. The bonus incentive and expense programs present a potential conflict because they are based in part on sales of these products. Code of Ethics, Participation or Interest in Transactions and Personal Trading Code of Ethics Ameriprise Financial Services may reassign your Managed Account to another financial advisor and notify you of the change. If your Managed Account is reassigned to another financial advisor prior to its termination, your Managed Account(s) will continue to be billed but the Asset-based Fee rate may change based on the Advisory Fee rate you negotiate with your new assigned financial advisor. As part of an overall internal compliance program, Ameriprise Financial Services has adopted policies and procedures imposing certain conditions and restrictions on transactions for the account of Ameriprise Financial Services and the accounts of our 93 personal trades through one of three designated broker-dealers unless an exception has been granted and report any changes in their selected broker- dealer. Insider Trading Policy employees. Such policies and procedures are designed to prevent, among other things, any improper or abusive conduct when potential conflicts of interest may exist with respect to a customer or client. In addition, from time to time, restrictions are imposed to address the potential for self-dealing and conflict of interest which may arise in connection with the business of Ameriprise Financial Services as a broker- dealer. Ameriprise Financial Services has adopted various procedures to guard against insider trading. Participation or Interest in Client Transactions From time-to-time Ameriprise Financial Services and/or its affiliates and related persons may invest in the same or related securities that Ameriprise Financial Services and/or its affiliates recommend to clients. Such transactions may occur at or at about the same time that such securities are bought or sold for client accounts. Ameriprise Financial Services has adopted policies and procedures imposing certain conditions and restrictions on transactions in these securities, such as trading blackout periods and preclearance requirements. See the “Financial interest in products” subsection in the “Revenue Sources for Ameriprise Financial Services, LLC” section in this Disclosure Brochure for more information about our financial interest in the sale of certain products and services. Ameriprise Financial Services and its related persons may, from time to time, come into possession of material nonpublic information that, if disclosed, might affect an investor’s decision to buy, sell or hold a security. Under applicable law, Ameriprise Financial Services and its related persons are prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether such other person is a client. Accordingly, should Ameriprise Financial Services or its related persons come into possession of material nonpublic information with respect to any company, they may be prohibited from communicating such information to, or using such information for the benefit of, their respective clients, and have no obligation or responsibility to disclose such information to, nor responsibility to use such information for the benefit of, their clients when following policies and procedures designed to comply with law. Ameriprise Financial Services and its affiliates have adopted an “Insider Trading Policy” in accordance with Section 204A of the Advisers Act that establishes procedures to prevent the misuse of material nonpublic information by Ameriprise Financial Services and its associated persons. Personal Trading Rules and Procedures Review of Accounts Ameriprise Financial Services has adopted personal trading rules and procedures within the Ameriprise Financial Code of Ethics and Personal Trading Policy. These rules are designed to list standards of business conduct and to mitigate potential conflicts of interest for all persons of Ameriprise Financial Services when they engage in personal securities transactions. You may request a copy of the Ameriprise Financial Code of Ethics and Personal Trading Policy from your financial advisor or by contacting us at 800.290.6663. Certain supervisory functions are performed by Ameriprise Financial Services corporate office personnel. Corporate registered principals review a sampling of financial advisor’s financial planning relationships, including written financial planning recommendations periodically based on certain key factors. At the time your Managed Account(s) is opened, our corporate registered principals will review your Managed Account(s) to confirm it is appropriate based on your stated investment goals, time horizon, risk tolerance, and investment objectives. Additionally, we periodically evaluate your Managed Account(s) to help ensure the investments are within applicable Program rules. For SPS Advantage and SPS Advisor Programs, the evaluation might include a review of concentrated securities positions and low or excessive trading. If any of your Managed Accounts in the SPS Advantage Program are subject to a concentrated position review, we will allow the grouping of eligible advisory assets in related Managed Accounts that you (i) own individually and (ii) own jointly with a member of your household for the purpose of such evaluation, provided that the particular SPS Advantage Managed Account under review continues to remain appropriate based on your The standards of business conduct include compliance with applicable laws and regulations and with policies and procedures such as those contained in the Ameriprise Global Code of Conduct. Under the personal trading rules, persons are required to report their personal securities holdings and transactions, including transactions in certain mutual funds; must pre-clear certain investments; are restricted with respect to the timing of certain investments; and are prohibited from making certain investments. In addition, the Personal Trading Policy requires (i) Ameriprise employee financial advisors and their employees, (ii) its independent contractor franchisee financial advisors and their employees, and (iii) its affiliated investment advisers to conduct most 94 stated investment goals, time horizon, risk tolerance, and investment objectives. You and your financial advisor may be required to take action to satisfy Program guidelines and requirements, or to retain your Managed Account. a sharing of a portion of any total Asset-based Fees. You will not be charged an additional fee as a result of any referral arrangements. Compensation may include a one-time payment or ongoing payments for the duration of the investment advisory relationship. When appropriate, our corporate registered principals may also decide to call you directly to discuss your understanding of the Account(s), including the fees and expenses you will be paying. Our Compliance department also conducts routine surveillance of financial advisor activities. If you are in a financial planning relationship, including the consolidated advisory fee arrangement, you will receive written reports relating to your financial planning goals from your financial advisor at least annually. An important part of an advisory relationship involves providing you with the opportunity to engage in periodic reviews with your financial advisor or a designated member of the team servicing your Managed Account. In these reviews, you and your financial advisor should discuss any changes to your individual circumstances, financial situations, investment objectives and/or risk tolerance, and whether you would like to impose any reasonable restrictions on your Managed Account(s). Ameriprise Financial Services may form networking arrangements with financial institutions such as banks, credit unions, credit union service organizations, Farm Credit Services, and trust service providers (“Third Party Financial Institutions”) to allow its financial advisors to offer investment advisory services, financial planning services and certain other non-deposit investment and insurance products and services (described elsewhere in this Disclosure Brochure) to retail customers or members of the Third Party Financial Institutions. Under the terms of these networking arrangements, financial advisors may not be able to offer to retail customers or members of the Third-Party Financial Institutions certain products that are otherwise available through Ameriprise Financial Services or its affiliates. Also, because of these networking arrangements, Third Party Financial Institutions may receive, in the form of a networking payment, a portion of Asset-based Fees and securities and insurance commissions paid to financial advisors for sales to retail customers or members of the Third- Party Financial Institutions. Our supervision and surveillance do not substitute for your continued review and monitoring of your Managed Account(s). You should review your Managed Account statements, trade confirmations, and other information we send to you. If you have any questions, please discuss them with your financial advisor. Client Referrals and Other Compensation Referral Arrangements and Other Economic Benefits Ameriprise Financial Services has entered in partnership with Renaissance Charitable Foundation Inc. (“RCF”) for the referral of clients or prospects that have indicated an interest in establishing and maintaining a donor advised fund made available through RCF. No referral fee is paid by RCF to Ameriprise Financial Services or financial advisors however donor advised funds established by RCF because of the referral generally invest in eligible Programs that are advised and serviced by the referring financial advisor. The administration fee that you pay RCF for a donor advised fund solution may be more or less than if you were to purchase the donor advised fund services from RCF or another non-profit organization. Any fees charged by RCF for the administration of the donor advised fund are not shared with Ameriprise Financial Services or financial advisors. Ameriprise Financial Services maintains investment advisory referral arrangements, the terms of which are disclosed to the client, with individual professionals, professional firms, and select corporate, institutional or membership organizations (“Promoters”). For each such arrangement, Ameriprise Financial Services pays the Promoter for referral of their clients or members to Ameriprise Financial Services for its financial advisory services. The manner and amount of compensation to be paid in connection with these agreements is subject to negotiation between Ameriprise Financial Services and the applicable Promoter. Prospective clients are provided with applicable disclosures, including whether the Promoter is a client, the material terms of compensation (if any) and the material conflicts of interest (if any), that results from the Promoter's relationship with Ameriprise Financial Services. The most common compensation arrangements include a flat fee at the time of the referral, a recurring flat fee, or Ameriprise Financial Service and your financial advisor will receive Asset-based Fee revenue from a donor advised fund established by RCF and invested in a Program and no revenue if donor advised fund assets are invested with a third-party investment adviser, whether through RCF or another non- profit organization. We seek to address this conflict of interest through a combination of disclosure and through our policies, procedures and supervision related to the determination that a referral to RCF is appropriate for you based on your Client Information, 95 as underlying investment options for variable annuities and variable life insurance. 12b-1 fees may be used to pay for marketing, distribution and shareholder service expenses. and by treating assets in Managed Accounts owned and administered by RCF and assets in Managed Accounts owned directly by you as separate and distinct advisory relationships in accordance with all applicable regulatory requirements. Review of Issuers of Financial Products Investment and Interest Income. Investment and interest income from insurance company general account assets derived, in part, from the amounts you pay for insurance and annuity benefits. Ameriprise Financial Services and its affiliates have policies and procedures in place to review the issuers of financial products such as alternative investments, structured notes, and annuity and insurance products that Ameriprise Financial Services permits its financial advisors to offer to some or all of its clients. This review includes publicly available information and reports issued by third parties and may in some cases include certain nonpublic information provided by the issuer. Variable Annuity and Variable Life Insurance Financial Arrangements. RiverSource selects the funds available within your variable annuity contract or variable life insurance policy. In doing so, RiverSource may consider various objective and subjective factors. These factors include compensation RiverSource may receive from fund assets (for those funds with 12b-1 plans); assets of the fund’s adviser, sub-adviser or an affiliate of either; and assets of the fund’s distributor or an affiliate. This compensation benefits RiverSource. Ameriprise Financial Services periodically reassesses, but does not continuously monitor, the creditworthiness or financial solvency of third-party issuers. These policies and procedures are reasonably designed to mitigate our clients’ exposure to credit and default risks resulting from an inability of the issuer to repay the principal on a note or fulfill an insurance obligation. However, you should be advised that credit markets can be volatile, and the creditworthiness of an issuer may change rapidly. Ameriprise Financial Services, as a seller of these products, is prohibited by regulation from guaranteeing or providing any assurance that an issuer of financial products will be able to fulfill the issuer’s obligation to any purchaser of such a product through Ameriprise Financial Services. Revenue Sources for RiverSource RiverSource The amount of this revenue varies by fund, may be significant and may create potential conflicts of interest for RiverSource. The greatest amount and percentage of revenue that RiverSource receives comes from assets allocated to subaccounts investing in funds managed by its affiliates, CMIA, and Columbia Wanger Asset Management. In general, the revenue directly related to assets under management that RiverSource receives currently ranges up to 0.65% of the average daily net assets invested in the underlying funds through the variable annuity or variable life insurance contracts RiverSource issues. This revenue is in addition to revenues RiverSource receives from the charges you pay when buying, owning or surrendering your variable annuity contract or life insurance policy. In accordance with applicable laws, regulations and the terms of the agreements under which such revenue is paid, RiverSource may receive this compensation for various purposes including financial advisor training and compensation, marketing and distribution, customer servicing, transaction processing, record keeping, and other administrative services. Sales charges. You pay sales and other charges under RiverSource variable annuity contracts and life insurance policies. You may incur transaction costs or fees associated with structured annuities. You may pay a contingent deferred sales charge, or surrender charge, if you withdraw funds during the applicable period. Revenue Sources for Columbia Management and Threadneedle Periodic Fees and Expenses. You pay certain fees and expenses under RiverSource annuity contracts, life insurance policies and disability income insurance policies, including (depending on the type of contract or policy) mortality and expense, administrative, policy, contract, and cost of insurance fees or charges, in addition to costs associated with certain riders that may be available for both fixed and variable products. Periodic Fees and Expenses. Columbia Management and Threadneedle International Limited may receive management fees and certificate advisory and services fees for services, including, with respect to Columbia Management, investment management services for Active Portfolios® investments. These revenues may be received from the Columbia Funds, Columbia ETFs, Columbia closed-end funds, Ameriprise certificates and from other affiliated and nonaffiliated advisory clients of Columbia Management and Threadneedle International Limited. Periodic expenses are also paid from product assets, such as 12b-1 fees paid on certain funds that serve 96 Revenue Sources for Other Ameriprise Financial, Inc. Companies There are several other Ameriprise Financial, Inc. companies that will receive revenue from the charges and fees you pay, including the following: • Ameriprise Certificate Company receives These services include but are not limited to delivering shareholder communications such as updated prospectuses and statements of additional information, transaction confirmations and annual tax reporting, and monitoring compliance with share class, discounted sales charge, market timing and other mutual fund company policies. • investment spread income earned on, and any early withdrawal penalty related to, Ameriprise certificates. Ameriprise Financial, Inc. receives fees paid from Columbia and the Columbia Funds and Ameriprise certificates in exchange for the administrative services it provides. • Columbia Management Investment Services Corp. receives certain fees and expenses paid from the Columbia Funds and Ameriprise certificates in exchange for the transfer agent services it provides. • American Enterprise Investment Services Inc. is • Columbia Management Investment Distributors receives fees paid from the Columbia Funds in exchange for the distribution services it provides. Ameriprise Financial Services has a financial interest in the sale of Columbia Funds, Ameriprise certificates and RiverSource products and certain other mutual funds. • compensated for its services through the brokerage commission and other fees charged for each brokerage transaction, which may include transactions made in an Ameriprise Bank trust account, or through the brokerage commission which is included in the overall asset-based fee, depending on the account option you select. • If the Sweep Program for your Managed Account is AIMMA, AEIS receives compensation from the Program Banks based on the cash balance in the AIMMA program. If your Managed Account sweeps uninvested cash to ABISA or to Ameriprise Bank as a Program Bank in the AIMMA program, Ameriprise Bank does not compensate AEIS but reimburses AEIS for its direct out of pocket expenses related to the sweep services provided. • AEIS receives compensation in the form of Ameriprise Financial Services sells annuity and insurance products manufactured by its RiverSource affiliates, as well as products from unaffiliated providers. RiverSource is permitted to reimburse Ameriprise Financial Services for client/prospect education events and advisor sales meetings, seminars, and training events pertaining to annuity and insurance products, consistent with Ameriprise Financial Services policies and industry regulation; Ameriprise Financial Services may also receive nominal noncash benefits from time to time. Unaffiliated annuity and insurance providers may not provide some services, or the same level of services, to Ameriprise financial advisors. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource annuity and insurance products. • Ameriprise Bank charges fees, depending on the terms of trust documentation and applicable state laws governing trust administration, for its administrative trust services that are separate from investment management fees charged by financial advisors and are not shared with Ameriprise Financial Services. interest charged on your margin account balance, as well as from order handling fees. In transaction-based brokerage accounts, AEIS may also engage in principal trading of certain types of fixed income securities for brokerage accounts— that is, it may buy and sell these securities for its own account with the objective of making a profit in certain circumstances, AEIS may buy these securities from you or sell these securities to you on a principal basis, in which case you will pay a markup or markdown on the transaction. • AEIS performs, for the benefit of Ameriprise Financial Services, its financial advisors and clients, cost reimbursement and marketing support services as described in the “Cost Reimbursement and Marketing Support” section. In recognition of the above, product sponsors will compensate AEIS for these services performed by AEIS. • When Ameriprise Bank is a Program Bank in the AIMMA program or ABISA is the Sweep Program, Ameriprise Bank earns income by lending or investing the deposits it receives and charging a higher interest rate to borrowers, or earning a higher yield, than it pays on the deposits held through these sweep programs. The difference is known as the “spread.” • • Ameriprise Bank earns revenue based on the amount of credit extended and the interest rate on the Ameriprise Preferred Line of Credit and Loan. The capacity in which AEIS acts in any particular transaction is disclosed on each transaction confirmation you receive. AEIS is also compensated for the shareholder services it provides for certain mutual fund companies. 97 Custody Vista Separate Managed Account, Investor Unified Accounts and Access Account Programs, you have the right to vote proxies on the securities in which your Managed Account assets may be invested from time to time, or you may delegate the authority to vote these proxies to the Investment Manager for your Managed Account. You may alternatively delegate the authority to vote proxies on your behalf to another person. Neither Ameriprise Financial Services, your financial advisor nor any Advisory Service Provider are responsible for any other corporate actions relating to the assets in your Managed Account(s), including administrative filings such as proofs of claims related to bankruptcy or claims in class actions. Ameriprise Financial Services’ Proxy Voting Policies and Procedures In establishing a Managed Account, you establish and maintain a Managed Account with Ameriprise Financial Services. Neither Ameriprise Financial Services, nor any Advisory Service Provider will act as custodian for the brokerage account or take possession of any assets in the Managed Account. AEIS, one of our broker-dealer affiliates, provides custody and safekeeping services for Managed Account assets, and will ordinarily act as the custodian for all assets held in Managed Account. Because our affiliate maintains custody of our clients’ assets, we are required by SEC rules and regulations to obtain from AEIS at least annually a written internal control report (the “ICR”) prepared by a qualified independent public accountant, and AEIS is required to undergo an independent verification of the assets under its control. The ICR that we receive from AEIS is intended to show that our affiliate has established appropriate custodial controls with respect to client assets under custody. When Ameriprise Financial Services has proxy voting authority for applicable Select Separate Accounts, Ameriprise Financial Services will apply the following general principles to meet its proxy voting responsibilities: • Seek to ensure that proxies are voted in the best Retirement Accounts where ATC acts as custodian or trustee, AEIS shall act as an agent or sub custodian of ATC with respect to custody of assets. economic interest of clients; • Investment Discretion Address material conflicts of interest that may arise; and • Comply with disclosure and other requirements as required by law. Your Ameriprise financial advisor does not manage your securities or other investments on your behalf as part of AFPS. However, your financial advisor may offer a discretionary investment advisory service separately as part of our SPS Advisor Program. Voting Client Securities Ameriprise Financial Services intends to vote all proxies of which it becomes aware prior to the vote deadline. However, in certain limited circumstances, Ameriprise Financial Services may determine to refrain from voting. Ameriprise Financial Services and your financial advisor do not take any action or give advice regarding the voting of proxies solicited by or with respect to the issuers of securities in which assets of your Managed Account(s) may be invested, except for certain Select Separate Accounts where you delegate proxy voting authority to Ameriprise Financial Services. For all other Advisory Solution Programs, Ameriprise Financial Services and your financial advisor do not take any action or give any advice regarding the voting of proxies solicited by or with respect to the issuers of securities in which assets of your Managed Account(s) may be invested. Ameriprise Financial Services will forward to you or your designated agent, all proxy solicitations and materials related to other corporate actions that are received by Ameriprise Financial Services with respect to assets in your Managed Account(s). You are responsible for voting proxies and effectuating other corporate actions relating to the securities held in your respective Managed Account(s). Ameriprise Financial Services will use an independent third-party proxy service for its fundamental research on proxy questions and subsequent recommendations and has adopted the third-party provider’s proxy voting guidelines covering certain types of proposals. The guidelines indicate whether to vote for, against or abstain from a particular proposal. In circumstances where proposals are not covered by the guidelines or a voting determination must be made on a case-by-case basis, the Oversight Committee will make the voting determination. The Oversight Committee may consider the voting recommendations of analysts, Investment Managers and information obtained from outside resources. The Oversight Committee reserves the right to consider each proxy vote, whether covered by the guidelines or a third-party recommendation, based on the facts and circumstances of the proposal presented, and submit a vote that it believes is in the best economic interest of its clients. For Signature Wealth, Active Portfolios®, Select Separate Account, including Select Strategist UMA, Ameriprise Financial Services has implemented policies reasonably designed to identify potential 98 material conflicts of interest to help us vote proxies without undue influence from individuals or groups who may have an economic interest in the outcome of a proxy vote. These policies include: • Employing predetermined voting guidelines; records to meet our obligations under applicable law. You may obtain a copy of our proxy voting policy, and other information regarding how your proxies were voted, upon request by writing to us at the address set forth on the first page of this Disclosure Brochure or calling the phone number that appears on that page. • Financial Information Causing proxies to be voted in accordance with recommendations of an independent third party; • Causing the proxies to be delegated to an Independent third party, which may include Ameriprise Financial Services’ proxy voting service provider; or We are not required to include a balance sheet in this Disclosure Brochure because we do not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance. • We do not have any financial conditions that are reasonably likely to impair our ability to meet our contractual commitments to clients. In unusual cases, with the client’s consent and upon ample notice, forwarding the proxies to Ameriprise Financial Services’ clients so that they may vote the proxies directly. Ameriprise Financial Services has not been the subject of a bankruptcy petition during the past 10 years. Each Investment Manager to which you delegate voting authority will vote proxies according to its own applicable voting policies and procedures. Where you own both a Select Separate Managed Account and another discretionary Managed Account and both Managed Accounts invest in the same SMA strategy managed by the same Investment Manager, this may result in different voting determinations by Ameriprise Financial Services and the Investment Manager for the same particular proposal. We maintain proxy voting 99 Glossary • • • • “ABISA” means Ameriprise Bank Insured Sweep Account. “Access Account” means Ameriprise® Access Account. “Active Portfolios” means Ameriprise® Active Portfolios®. “Active Portfolios® Investment Fact Sheet” means the applicable Active Portfolios® investment fact sheet that includes biographical information about the Investment Manager and/or portfolio strategist, investment philosophy and style information, portfolio characteristics and composite performance. • “Additional Fees and Expenses” are any additional transaction related fees that may be incurred in connection with your Managed Account based on the nature of your investments. • “Advisers Act” means the Investment Advisers Act of 1940, as amended. • “Advisory Service Providers” refers, collectively, to affiliated and third-party investment advisory firms whose services Ameriprise Financial Services uses to provide discretionary and non-discretionary advisory services that include investment management, asset allocation and/or rebalancing, or providing investment models, as applicable, for certain Manager Directed Programs. • “Advisory Solutions” means the wrap fee program sponsored by Ameriprise Financial Services offering a variety of investment advisory programs. • “Advisory Shares” means advisory, institutional or other share classes that do not have a sales-load, do not have a sales-load and do not assess 12b-1 shareholder servicing fees. • “AEFA” means American Express Financial Advisors, Inc. • “AEIS” means American Enterprise Investment Services Inc. • “AFIG” means Ameriprise Financial Institutions Group. • “AFPS” means Ameriprise Financial Planning Service. • “AFPS Agreement” means the applicable financial planning service agreement, as it may be amended from time to time, that includes the specific terms under which the client will receive those services. • “AIMMA” means Ameriprise Insured Money Market Account, an FDIC insured interest-bearing multi- bank deposit product. • “Ameriprise” means Ameriprise Financial, Inc. • “Ameriprise Bank” means Ameriprise Bank, FSB. • “Ameriprise Financial Services”, “Ameriprise Financial”, “AFS”, “Sponsor” or “we”: means Ameriprise Financial Services, LLC. • “Asset Allocation Strategist” means strategist who solely provides asset allocation recommendations to the Investment Manager. • “Asset-based Fee” means our component-based pricing framework in which the sub-components of the Asset- based Fee (referred to as “fee components”) are separately itemized. • “ATC” means Ameriprise Trust Company. • “Available for Sale Firms” are firms that sponsor or manage mutual fund options to whom IRG will proceed to look for if a suitable mutual fund recommendation for a particular asset class cannot be found within the Full Participation Firms’ offerings. • “BDA” means Business Development Account. • “BDC” means a business development company. • “Brochure” or “Disclosure Brochure” means Ameriprise Managed Accounts Client Disclosure Brochure. • “Brokerage Agreement” means, collectively, the Ameriprise Brokerage Client Agreement, as it may be amended from time to time, along with the Other Important Brokerage Disclosures Document and Schedule of Account & Service Fees. • “CD” means a certificate of deposit. • “CEF” means a close-end fund. • “CFA” means Chartered Financial Analyst. 100 • “CFP®” means Certified Financial Planner™. • “CFTC” means the Commodity Futures Trading Commission. • “Client Information” means client’s financial and risk profile information and investment objectives. • “CMG” means Columbia Management Group, LLC. • “CMIA” or “Columbia Management Investment Advisers” means Columbia Management Investment Advisers, LLC. • “Columbia” or “Columbia Management” refers, collectively, to Columbia Management Investment Advisers, LLC and Columbia Wanger Asset Management, LLC. • “Columbia Funds” means investment companies and other funds advised by affiliated companies, Columbia Management Investment Advisers, LLC and Columbia Wanger Asset Management, LLC. • “Columbia Management Investment Distributors” means Columbia Management Investment Distributors, Inc. • “Columbia Wanger Asset Management” means Columbia Wanger Asset Management, LLC. • “Committee” or “Oversight Committee” means Ameriprise Financial Services, LLC’s Managed Accounts Program Oversight Committee. • “Covered shares” or “Covered Securities” means shares or securities for which Ameriprise is required to track costs basis, holding period, and certain other tax information, and report such information to the client and the IRS on Forms 1099-B (Proceeds from Broker and Barter Exchange Transactions).”CTA” means Commodity Trading Advisor. • “Discretionary Managers” refers, collectively, to Advisory Service Providers with investment selection discretion and SPS Discretionary Advisors. • “DRP” means a dividend reinvestment plan. • “ERISA” means the Employee Retirement Income Security Act of 1974, as amended. • “ETF” means an exchange-trade fund. • “ETN” means an exchange-traded note. • “Eligible Investments” means investment products (i) that meet Ameriprise Financial Services’ due diligence standards; and (ii) for which we have a selling or distribution agreement in place are offered and are available for purchase in SPS Advantage Accounts, SPS Advisor Accounts, Vista Separate Accounts and Investor Unified Accounts. • “Eligible to Hold Investments” means investment products for which our due diligence standards are met but either: (i) we do not have a selling or distribution agreement in place; or (ii) the investment is not otherwise available for purchase in Managed Accounts. • “Eligible to Hold Share Class” means a share class that is less expensive than the Advisory Share or other share class Ameriprise Financial Services offers for purchases in a given mutual fund available in the Advisory Solutions Programs. • “Envestnet” means Envestnet Asset Management, Inc. • “Envestnet Manager” means an SMA Investment Manager who entered into a sub-management agreement with Envestnet to provide discretionary Investment Manager or Model Provider investment management services. • “Exchange Act” means the Securities Exchange Act of 1934, as amended. • “Executing Party” refers, collectively, to the broker-dealer or stock exchange. • “FDIC” means the Federal Deposit Insurance Corporation. • “Feature” means the SPS Advantage automatic rebalancing feature. • “FIFO” means first in first out. • “FINRA” means the Financial Industry Regulatory Authority. • “Frequency Interval” means the rebalancing frequency interval. • “Full Participation Firms” are mutual fund firms that fully participate in the Mutual Fund Program. • “HIFO” means highest in first out. • “Household” is generally defined as an individual, his or her spouse or domestic partner, and the unmarried children under age 21 who reside at the same address and is applied separately by each Program. • “ICR” means an internal control report. • “Ineligible Investments” are investment products (i) that do not meet our due diligence standards, (ii) where due diligence has not been completed; or (iii) that are not otherwise eligible to be held more than 180 days in Managed Accounts. 101 • “Internal Revenue Code” means the Internal Revenue Code of 1986, as amended. • “IPO” means an initial public offering. • “IRA” means an individual retirement account. • “IRG” means Ameriprise Investment Research Group. • “IntraFi” means IntraFi Network LLC. • “Investments and Infrastructure Support Credit” is a credit to SPS Advisor Account clients for all sub- transfer agency fees and networking fees that AEIS receives from mutual funds firms. • “Investments and Infrastructure Support Fee” is a fee to support the cost of maintaining and serving the SPS Advisor Program. • “Investment Costs” are the underlying fees related to investment products client purchases within their Managed Account. • • “Investment Manager” is a manager with discretionary authority to purchase or sell securities or make other investments for client’s Account. “Investor Unified Account” means Ameriprise® Investor Unified Account. • “LIFO” means last in first out. • “Managed Account” means an Ameriprise investment advisory account for which you pay an ongoing Asset-based Fee • “Manager Directed Program” refers to the discretionary Programs, specifically Active Portfolios® investments, Select Separate Account, Vista Separate Account, Investor Unified Account and Access Account Programs that use the discretionary investment advisory services of Advisory Service Providers. Collectively we refer to these Programs as the Manager Directed Programs throughout this Disclosure Brochure. • “Mutual Fund Program” means Ameriprise Financial Mutual Fund Program, the structure formed by the payment of the mutual fund and 529 plan marketing and sales support payments that are received from certain mutual fund firms. • “NASD” means the National Association of Securities Dealers, a predecessor of FINRA. • “NFA” means National Futures Association. • “Non-covered” refers to securities that are not subject to mandatory tax reporting of cost basis and holding period. For more information on “covered” and “non-covered” securities, see the Cost Basis Reporting FAQ on Ameriprise.com. • “Non-Matching Shares” refer to mutual fund share classes that do not match the Advisory Share class or other share class offered by Ameriprise Financial Services as the only share class available for a particular mutual fund. • “Non-Target Securities” means securities that are purchased or transferred into the SPS Advantage • Account that are not a part of your Target Allocation. • “NYSE” means the New York Stock Exchange LLC. • “NYSE: AMP” means Ameriprise Financial, Inc. stock symbol on the NYSE. • “Outside Workplace Retirement Plan” means additional retirement plan assets not included in the Managed Account and that are held outside of Ameriprise Financial Services in a participant-directed defined contribution plan. • “Portfolio Strategist” means Portfolio Strategist who provides asset allocation and investment recommendations to the Investment Manager. • “Program” means each investment advisory program offered under Advisory Solutions. • “Program Banks” means FDIC member banks that participate in AIMMA. • “Program Bank List” means the list that identifies the Program Banks participating in AIMMA. • “Promoter” means any individual professional, professional firm, or select corporate, institutional or membership organization that provides testimonials or endorsements of Ameriprise Financial Services for its investment advisory services. • “Reasonable Restrictions” are client imposed reasonable stock or sector restrictions on the management of his/her discretionary Account(s). • • “Rebalancing Date” means the next rebalancing date for rebalancing your eligible assets to the targeted allocation. “Relationship” means an Ameriprise® Custom Advisory Relationship. • “Relationship Agreement” means the investment advisory agreement made between Ameriprise Financial Services and the client, as it may be amended from time to time. 102 • “REIT” means a real estate investment trust. • “RiverSource” refers, collectively, to RiverSource Life Insurance Company and RiverSource Life Insurance Co. of New York. • “RiverSource Distributors” means RiverSource Distributors, Inc. • “RiverSource Life” means RiverSource Life Insurance Company. • “RiverSource Life of NY” means RiverSource Life Insurance Co. of New York. • • “SEC” means the United States Securities and Exchange Commission. “Select Separate Account” means Ameriprise® Select Separate Account. • “Select Separate Account Model Provider” is a Model Provider who constructs a model portfolio according to the specific investment strategy. • “SEP” means a Simplified Employee Pension. • “Signature Wealth Investment Manager” means a non-affiliated third-party registered investment adviser as the discretionary Investment Manager for the Signature Wealth Program. The Signature Wealth Investment Manager is also the Active Portfolios® Investment Manager. • “Programs Investment Provider” means non-discriminatory investment advisers who construct the recommended model investment portfolios within the Signature and Active Portfolios® Programs. • “SIMPLE” means a Savings Incentive Match Plan for Employees. • “SIPC” means the Securities Investor Protection Corporation. • • • “SMA” means a separately managed account that follows an investment strategy offered by an Advisory Service Provider in Select Separate Account, Vista Separate Account, Investor Unified Account and Access Account Programs. SMAs typically invest in individual equity and bond securities. “SPS Advantage” means Ameriprise® Strategic Portfolio Service Advantage. “SPS Advisor” means Ameriprise® SPS Advisor. • “SPS Discretionary Advisor” means Ameriprise financial advisor authorized to use discretion in SPS Advisor. • “Sponsor” refers to Ameriprise Financial Services as the sponsor of the wrap fee program described in this Disclosure Brochure. • “Starting Point List” means mutual funds and ETF recommended list developed by IRG. • “Sweep Program” means money settlement feature offered by Ameriprise Financial Services that is intended to hold cash. • “Target Allocation” means your predetermined allocation in accordance with your instruction for Ameriprise Financial Services to rebalance your eligible assets. • “Third Party Execution Fees” means additional costs incurred when an Investment Manager directs transactions for execution with or through Executing Parties other than AEIS. • “Third Party Financial Institutions” means third party financial institutions such as community banks, credit unions, credit union service organizations, Farm Credit Services and trust service providers with whom Ameriprise Financial Services may form alliances and networking arrangements with to allow its financial advisors to offer investment advisory services, financial planning services and certain other non-deposit investment and insurance products and services, to retail customers/members of the Third Party Financial Institutions. • “Third Party Payments” means the portion of Investment Costs paid to AEIS by third parties who manage, sponsor or distribute investment products held in your Managed Account. • “TSCA” means Tax-Sheltered Custodial Account. • “UIT” means a unit investment trust. • • “UMA” means a managed account that enables you to own SMAs, mutual funds and/or eligible ETFs in a multi- account investment portfolio. “Vista Separate Accounts” means Ameriprise® Vista Separate Account. 103 Financial Planning I Retirement I Investments I Insurance 91 ©2026 Ameriprise Financial, Inc. All rights reserved. 402422 AN (03/26)

Additional Brochure: AMERIPRISE PREMIER RETIREMENT INCOME (2026-03-27)

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Ameriprise® Premier Retirement Income Client Disclosure Brochure (Form ADV Part 2A) March 2026 Ameriprise Financial Services, LLC 70400 Ameriprise Financial Center Minneapolis, MN 55474 ameriprise.com This Brochure provides information about the qualifications and business practices of Ameriprise Financial Services, LLC and the Ameriprise Premier Retirement Income service. If you have any questions about the contents of this Brochure, please consult with your financial advisor or contact us at 800.862.7919 between 7 a.m. and 6 p.m. Central time. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Ameriprise Financial Services, LLC also is available on the SEC’s website at adviserinfo.sec.gov. 117401 K (03/26) SEC Registration No. 801-28543 Material Changes This Brochure dated March 2026 is filed as an update to the Form ADV Part 2A and includes material changes that have occurred since the last annual update of our Brochure in March 2025. Following is a summary of the material changes: July 2025 • The “Overview and Appropriateness of the Service for you” section has been updated to reflect that the Service is intended for clients that have at least $1,000,000 in net investable assets, and at least $500,000 in Ameriprise Financial Managed Account (“Managed Account”) assets, held at Ameriprise Financial Services and included in your Retirement Portfolio. • The “Fees and Compensation” section has been updated to reflect that effective with the September 2025 Calculation Date, a Service Fee that ranges from 0.07% to 0.15% based on the value of your Managed Account assets included in your Retirement Portfolio as of each Calculation Date will begin to be charged and will replace your current Service Fee. No change is being made to the Calculation Date and Posting Date methodology or timing. The specific asset tier ranges and Service Fee rates are: Retirement Portfolio Managed Account Assets as of Service Fee per Engagement Period* Calculation Date $0 - $999,999 0.15% $1,000,000 - $1,999,999 0.12% $2,000,000 - $3,999,999 0.09% $4,000,000+ 0.07% *The monthly Service Fee amount you pay on each Posting Date will be 1/12 of the dollar amount determined on the Calculation Date and assumes a 12-month Engagement Period. For each Engagement Period we will provide you with a written confirmation of the Service Fee that includes a list of the Managed Accounts included in the Service Fee calculation. You may request at any time a current copy of this Disclosure Brochure from your financial advisor. The current Brochure replaces any earlier version you receive. You may also request copies of the Brochure from your financial advisor or by writing to Ameriprise Financial Services, LLC at 2661 Ameriprise Financial Center, Minneapolis, MN 55474, or by calling 800.862.7919. March 2026 • The “Cost Reimbursement Services and Third-Party Payments” section was updated to include the following sub-section: o Payments from Investment Providers offering SMA investment portfolios within the Signature Wealth Program. AEIS receives cost reimbursement payments for the sale of SMA investment portfolios offered within the Signature Wealth Program. AEIS receives an asset-based payment of up to 0.04% per year on Ameriprise Financial Services clients’ assets invested in the SMA investment portfolios. If an Investment Provider ceases to make such cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the firm. • The “How our financial advisors get paid” section was retitled “Financial Advisor Compensation and Benefits” and was updated in general for clarity and overall readability. Please retain a copy of this Brochure for your records. Table of Contents Advisory Business ........................................................ 1-7 Revenue sources for Ameriprise Financial Services, LLC ......................................................... 22-27 Financial interest in products .............................. 23-28 Economic benefits of affiliates’ products and services .......................................... 24-30 How our financial advisors get paid ..................... 29-36 Code of Ethics, Participation or Interest in Transactions and Personal Trading ............................................ 30-37 Code of ethics ............................................................ 30 Participation or interest in client transactions .......... 31 Personal trading rules and procedures ...................... 31 Insider trading policy ................................................. 31 Brokerage Practices ................................................... 31 Review of Accounts ............................................... 32-38 Ameriprise® Premier Retirement Income ........................ 1 Overview and Appropriateness of the Service for you ........................................................................... 1-3 Establishing a relationship and preparing for your analysis ................................................................. 3-4 Receiving and reviewing your Recommendation Report ................................................. 3 Changing your retirement income plans or financial situation ............................................................ 4 Implementation of your recommendations ................. 4-5 Ongoing Service relationship ........................................... 4 How to make the most of your Service relationship ................................................................... 5-7 Client Referrals and Other Compensation ............. 32-41 Other advisory services .................................................. 6 Fees and Compensation ............................................ 6-10 Client programs and promotions ..................................... 8 Termination of the Service .............................................. 8 Performance-Based Fees and Side-by-Side Management 8 Types of Clients ............................................................... 8 Referral arrangements and other economic benefits ..................................................... 33 Review of issuers of financial products ..................... 33 Revenue sources for RiverSource .............................. 34 Revenue sources for Columbia Management and Threadneedle ...................................................... 34 Revenue sources for other Ameriprise Financial, Inc. companies ..................................... 34-41 Custody ..................................................................... 35 Investment Discretion ................................................ 36 Voting Client Securities .............................................. 36 Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 9-15 Sources of information .................................................. 10 Investment strategies .................................................... 11 Investment and market risk ...................................... 11-15 Financial Information ................................................. 36 Glossary ............................................................... 36–37 Disciplinary Information ................................................ 12 Regulatory proceedings ................................................. 12 Securities and Exchange Commission (“SEC”) and FINRA Actions ............................................. 12 Other financial industry activities and affiliations .......................................................... 13-19 Broker-dealer ............................................................ 13-17 Investment company ..................................................... 14 Investment advisory firm ............................................... 14 Banking institution ......................................................... 15 Trust company ............................................................... 15 Insurance company ........................................................ 15 Ameriprise Financial Institutions Group (“AFIG”) .......................................................... 15-19 How we get paid ....................................................... 16-36 Cost Reimbursement Services and Third-Party Payments ............................................. 16--22 Other financial relationships ..................................... 19-24 Payments from other non-affiliated product companies ................................................... 20-26 Advisory Business Ameriprise Financial Services, LLC (“Ameriprise Financial Services”) is an investment advisory firm offering financial planning services since 1986. Ameriprise Financial, Inc. (NYSE: AMP), a publicly held company, is the parent company of Ameriprise Financial Services. References in this Brochure to “you” and “your” apply to each client who signs the Ameriprise Premier Retirement Income Agreement (“Service Agreement”). References to “us,” “we,” and “our” refer to Ameriprise Financial Services, LLC. References to “your financial advisor” are to your Ameriprise financial advisor.11 The services described in this Client Disclosure Brochure apply to our Ameriprise Premier Retirement Income clients only. Ameriprise Premier Retirement Income Overview and Appropriateness of the Service for you Ameriprise Premier Retirement Income service (the “Service”) is a specialized approach to retirement income planning that builds on our current investment advisory services and products and provides advice to clients approaching or in the distribution phase of retirement. The Service and your financial advisor tailor advisory services to your individual needs as discussed in the next several sections. The Service is provided by our Ameriprise retirement income consulting team (the “Service team”) in conjunction with your Ameriprise financial advisor. The Service team will review and analyze your assets, accounts and sources of income along with data and other information specific to your financial circumstances to make recommendations that can help you meet your retirement income goals. You and your financial advisor will work together to act on those recommendations, as appropriate. The Service provides you with an initial, and generally annually thereafter, retirement income plan that seeks to identify and maximize dependable income sources while managing investment and shortfall risk relating to your accounts, assets, and income sources you have designated to be included for analysis in the Service (“Retirement Portfolio”). In addition, we’ll seek to provide you with tax-smart withdrawal strategies that will help you reach your retirement goals. The Service allows you to receive ongoing retirement income planning advice for an annual flat fee. The Service is limited to your Retirement Portfolio and is appropriate for clients who desire retirement income advice and seek product or security specific advice tailored to accounts held at Ameriprise Financial Services. Generally the time frame between each Recommendation Report you receive while enrolled in the Service is based on a twelve-month period (“Engagement Period”). In determining whether the Service is appropriate for you at the time of entering into an Agreement and throughout each Engagement Period with Ameriprise Financial Services, please consider the following: • The Service is appropriate for individuals, married couples and domestic partners who are generally within five years of beginning their retirement or are already retired; • The Service is intended for clients that have at least $1,000,000 in net investable assets, and at least $500,000 in Ameriprise Financial Managed Account (“Managed Account”) assets, held at Ameriprise Financial Services and included in your Retirement Portfolio; • The Service is appropriate for clients that desire ongoing advice to help optimize income in retirement and are willing to pay a fee for that advice; • The Service is appropriate for clients that primarily choose to implement the recommendations provided in each written retirement income plan (“Recommendation Report”); • The Service is not appropriate for clients that primarily choose to implement investments, asset allocation changes and withdrawals that differ from those included in the Recommendation Report. In this case, you are doing so without a recommendation from us, and you are assuming the risk that your investment decision does not align with your stated financial goals and/or is not in your best interest; 1 If you are a client of the Ameriprise Personal Wealth Group, you may receive advice and support in for the Service from a dedicated team of financial advisors and professionals whose members may use titles such as Client Support Associate, Client Relationship Manager, or Financial Consultant. 1 • The Service is limited to retirement income planning and does not include or replace your Ameriprise® Financial Planning Service (“AFPS”) which is designed as a long-term, collaborative, ongoing financial planning relationship to help you achieve at least one financial goal or need, however if your only financial goal is related to retirement, AFPS may no longer be appropriate for you once you enroll in the Service; • The Service does not provide specific buy, sell or hold recommendations concerning individual securities in your investment accounts not held at Ameriprise Financial Services and your financial advisor cannot assist you with implementing or initiating any transactions within such outside accounts; • The Service provides only withdrawal and asset allocation advice for Ameriprise brokerage accounts. The Service does not provide specific buy, sell or hold recommendations concerning individual securities in your Ameriprise brokerage accounts. Your financial advisor can assist you separately with implementing or initiating any transactions within Ameriprise brokerage accounts; • Before enrolling in the Service or investing in any investment product, it is your responsibility to understand and consider all fees, expenses and other charges. That includes how much you will pay for the Service and when and how your advisory fee for the service (“Service Fee”) will be calculated and deducted; • Your Service Fee does not include Managed Account advisory fees, or any transaction-based markups, commissions, sales charges or other ongoing fees charged to you when you implement your Recommendation Report in whole or in part through Ameriprise Financial Services or its affiliates. Additional fee information for any Managed Account or Ameriprise brokerage account you open or maintain with us can be found in the Ameriprise Managed Accounts Client Disclosure Brochure and applicable Managed Account client agreement(s), the Ameriprise Brokerage Client Agreement, the Other Important Disclosures Document, Working in Your Best Interest – Regulation Best Interest Disclosure, and any other related disclosures and documents, all of which are available on our website at ameriprise.com/disclosures or from your financial advisor. Please review all applicable information carefully before you make an investment decision and contact your financial advisor if you have any questions about the types of fees and expenses that may be associated with your Managed Account or Ameriprise brokerage account. Specific information concerning the fees and other charges of each investment product in which your account invests is available in the product’s prospectus or other offering document; and • The same or similar services provided to you through the Service may be available to you at a lower fee from another service provider or may provide specific buy, sell or hold recommendations to you concerning accounts not held at Ameriprise Financial Services. Depending on how long you choose to be a client of the Service, and the number and types of products that you purchase from Ameriprise Financial Services in order to act on your Recommendation Report, you may pay more or less to purchase products and services through Ameriprise Financial Services and its affiliates than if you were to purchase products and services from other financial services providers. The Service and any advice you receive from your financial advisor is tailored to your specific circumstances and intended for your use only. If you choose to share your analysis and recommendations with a different broker-dealer or intermediary, neither your financial advisor nor Ameriprise Financial Services (nor any of its affiliates) is responsible for the outcome. Ameriprise Financial Services and our financial advisors owe you a fiduciary duty, as applied under the Investment Advisers Act of 1940, as amended, when you enter a Service relationship with Ameriprise Financial Services. This duty means that Ameriprise Financial Services and your financial advisor make investment recommendations that are in your best interest and place your interest ahead of our own and those of your financial advisor. This is accomplished by: • Explaining and providing to you written disclosures that outline key, relevant factors about the investment advice and recommendations you receive; and • Providing you with written disclosures that describe material conflicts of interest that your financial advisor and/or Ameriprise Financial Services have as part of the Service. You will find these written disclosures throughout this Brochure, and in the “Other Financial Industry Activities and Affiliations” and “How we get paid” sections. Your financial advisor can provide you with guidance to help you take action on your Recommendation Report, including asset allocation services that include individual retirement accounts (each, an “IRA”) and employer sponsored retirement accounts. Your financial advisor may discuss, present or offer ideas for you to consider related to the Service and these accounts. Such communications are offered solely as education, marketing and examples of the potential uses for purposes of discussion and for your independent consideration, and should not be viewed, construed or relied upon, as investment or fiduciary recommendations or advice under the Employee Retirement Income Security Act of 1974 ("ERISA") or Section 4975 of the 2 Internal Revenue Code of 1986, as amended (the “Internal Revenue Code”). Such communications should not be (and are not intended to be) relied upon as a primary basis for your investment decisions with respect to your retirement assets. To the extent that you receive recommendations related to assets held in your brokerage account or with respect to commission-based securities, such recommendations are made as part of your brokerage relationship and are made in your best interest but are not fiduciary recommendations under the Advisers Act, ERISA or the Internal Revenue Code. Also, to the extent an asset allocation service identifies any specific investment alternative in a retirement plan, please note that other investment alternatives with similar risk and return characteristics may be available to you. Such investment alternatives may be more or less costly than those available at or recommended by Ameriprise Financial Services. Your Plan sponsor (for government plans or those that fall under ERISA) or your financial advisor can assist you in obtaining information about other potential investment alternatives. Establishing a relationship and preparing for your analysis Prior to establishing a Service relationship, you will provide your financial advisor with initial information regarding your Retirement Portfolio and income needs in retirement, and you will receive and review a proposal that outlines how components of the Service could benefit you. Your Service relationship begins on the date that your Service Agreement is accepted (“Effective Date”). Your initial Engagement Period begins on the day your financial advisor confirms they have delivered your Recommendation Report to you and ends the day prior to the anniversary date of the delivery of your initial Recommendation Report. Each twelve-month period thereafter will be a new Engagement Period. Shortly after your Effective Date, you will receive an enrollment confirmation. After you have entered into a Service Agreement and are enrolled in the Service, you and your financial advisor will work together to refine your retirement goals as needed and to confirm your Retirement Portfolio to include in the Service. Your financial advisor will help you identify assets, accounts and sources of income to include in your Retirement Portfolio and gather your important documents relevant to your Retirement Portfolio such as your bank and brokerage statements, IRA and retirement plan account statements and statements for any external accounts that will be used to fund your retirement. You will also work with your financial advisor to review investment products that may offer guaranteed or stable income and determine if it is appropriate for you to plan to utilize one or more of these products to help you cover your essential expenses such as housing, food, utilities, taxes and healthcare during your retirement. Once all of your pertinent information has been received by the Service team from your financial advisor and you have satisfied other applicable eligibility criteria as outlined in the “Types of Clients” section, such as completing the transfer of assets into any new accounts you have chosen to open with us, we will begin our analysis. Provided you submit all of the information necessary to begin our analysis and you have satisfied applicable eligibility requirements, your Recommendation Report will be delivered promptly but no later than 180 days after your Effective Date. If we do not receive all of the information needed and satisfy your eligibility requirements in time to complete the analysis and allow the advisor to deliver the Recommendation Report within this 180 day period, we reserve the right to terminate of the Service relationship. If you subsequently provide any missing information or meet applicable eligibility requirements, you may resubmit an application to re-enroll in the Service. Receiving and reviewing your Recommendation Report Each Recommendation Report will address the key retirement income planning strategies described in the “Methods of Analysis, Investment Strategies and Risk of Loss” section of this Brochure. The Service team will prepare recommendations and your financial advisor will deliver a periodic Recommendation Report that will act as your blueprint to help you achieve your retirement income planning goals. The Recommendation Report will address your financial situation in relation to your Retirement Portfolio as well as the priority retirement goal(s) you have discussed with your financial advisor. You and your financial advisor will review the Recommendation Report, and align on the steps to implement this advice. Your financial advisor will review your financial situation relating to your Retirement Portfolio in the first year of your retirement income planning relationship and thereafter as needed, for example, if your personal financial circumstances or retirement income planning goals change. Changing your retirement income plans or financial situation If your personal financial circumstances or retirement income needs change, you should discuss with your financial advisor if an updated Recommendation Report is needed prior to the next Engagement Period. If your need for retirement income planning services changes, discuss with your financial advisor whether the Service is still appropriate for you. 3 You may change your retirement income planning goals at any time by discussing any desired changes with your financial advisor. Material changes to your retirement income goals or situation, such as an unexpected change in employment status, material changes to income sources, large unexpected expenses, etc., will be incorporated into your upcoming scheduled Recommendation Report unless you or your financial advisor request that a new Recommendation Report be issued sooner. In this case, your Engagement Period will restart for the upcoming year, including a recalculation of the Service Fee as described in the “Fees and Compensation” section. Implementation of your recommendations Each Recommendation Report is provided point in time and any specific and actionable investment or planning recommendations contained in your Recommendation Report are limited to the Retirement Portfolio you have designated to be included in the Service for the applicable Engagement Period. The Service does not include ongoing monitoring of your investments, accounts, or income streams. The Service is a non-discretionary investment advisory service. This means the Service does not include the implementation of any recommendations provided by the Service team and presented to you by your financial advisor. After you have reviewed your Recommendation Report, you may decide to implement the recommendations you receive in your Recommendation Report with Ameriprise Financial Services, its affiliates or unaffiliated financial services providers. Before implementing any recommendations, carefully consider the ramifications of purchasing products or services. You may want to seek further advice from your lawyer and/or accountant, particularly for estate planning, taxes, or business financial planning issues. When you choose to purchase products and services through Ameriprise Financial Services, you have the option of investing through a commission-based brokerage account, or a fee-based Managed Account, or both. You will work separately and directly with your financial advisor to implement recommendations within the Managed Accounts, Ameriprise brokerage accounts, or other products and services made available through Ameriprise Financial Service or our affiliates, as appropriate. The Service does not provide specific buy, sell or hold recommendations concerning individual securities in your Ameriprise brokerage accounts. Your financial advisor can assist you separately with implementing or initiating any transactions within Ameriprise brokerage accounts. The Service does not provide security specific recommendations regarding your investment accounts held outside of Ameriprise and neither Ameriprise Financial Services nor your financial advisor may initiate transactions in your investment accounts held outside of Ameriprise. Implementation of recommendations relating to such outside accounts or to income streams such as social security benefits must be done by you and is your responsibility. Although not part of the Service, where requested, your financial advisor may provide guidance on your retirement plan assets that are held outside of Ameriprise Financial Services in a participant-directed defined contribution plan (e.g., 401(k) plan) (“Outside Workplace Retirement Plan”). Any guidance provided to you is based on information provided by you about your Outside Workplace Retirement Plan and is limited to investments offered through the core lineup of funds established by your retirement plan sponsor. Your Outside Workplace Retirement Plan may include investment options not available at Ameriprise Financial Services or for which your financial advisor may not have access to detailed information. Neither Ameriprise Financial Services nor your financial advisor is responsible for the selection of the available investment options in your Outside Workplace Retirement Plan. Your financial advisor may not make buy recommendations related to employer stock that may be available within your Outside Workplace Retirement Plan. Your financial advisor cannot make any recommendations with respect to any current portfolio holdings or investment options available through a self-directed brokerage account associated with your Outside Workplace Retirement Plan. You are responsible for placing any transactions recommended by your financial advisor. If you desire ongoing guidance on your Outside Workplace Retirement Plan it is important that you provide your financial advisor with updated information, including statements and a list of funds available in your Outside Workplace Retirement Plan, on a regular basis. Your investment objectives and risk tolerance for your Outside Workplace Retirement Plan may differ from those of your other Ameriprise accounts, if any. However, any guidance provided for your Outside Workplace Retirement Plan is provided in consideration of the investment objectives and risk tolerance of any Ameriprise accounts you hold. Ongoing Service relationship You will receive a written Recommendation Report and pay a Service Fee during each Engagement Period. Your Service relationship will continue until you terminate it as described in the “Termination of Service” section. 4 During each Engagement Period, you and your financial advisor should work together to: • Confirm that the Service continues to remain appropriate for your retirement income planning goals and financial situation; • Discuss progress over time toward your identified retirement income planning goals; and • Identify key changes to your situation or Retirement Portfolio that might impact your retirement income goals or our analysis. How to make the most of your Service relationship At Ameriprise Financial Services, we believe that the Service will help provide a pathway to helping you achieve your retirement income planning goals. The retirement income planning relationship begins with you. As a client of the Service, you will need to: Establish clear and measurable retirement income planning goals. Talk with your financial advisor about your goals so they may be a part of the retirement income planning process. For example, if your goal is a “comfortable” retirement, think about what that means to you. The more specific you are about the lifestyle you envision, the better equipped the Service team will be to make recommendations to help you get there and the better informed your financial advisor will be to help you implement those recommendations. Provide complete and timely information to your financial advisor. The Service team will base your retirement income planning analysis and written recommendations on the information that you provide to your financial advisor. You must provide the requested information in a timely manner to receive your Recommendation Report. When you become a client of the Service, you represent that all financial and other data that you and/or your representatives or agents furnish to your financial advisor relating to your Retirement Portfolio are true and correct and may be relied upon by your financial advisor and Ameriprise Financial Services for the purposes of providing you the Service. The Service team will be better able to make recommendations to help you achieve your retirement income goals if you provide complete and thoughtful information to your financial advisor about your current financial and economic situation, the retirement income goals on which you want advice, your investment objectives, and any investment restrictions you may have. Consider signing up for OmniView on the secure site on Ameriprise.com if you have not already done so or providing hard copies for updating annual copies of account statements. Promptly inform your financial advisor if you experience significant life events, or material changes in your financial situation, risk tolerance or financial objectives. Review the written recommendations you receive. Based on the information you provided, the Service team will perform a retirement income planning analysis and give you written recommendations on the retirement income planning goals you have identified. If the Service team’s assumptions, methods, conclusions or recommendations do not meet your expectations, contact your financial advisor right away to resolve your concerns. Form reasonable expectations. Understand the benefits of and limits to the retirement income planning process and be reasonable in your expectations of the results you can achieve with your retirement income plan and investments, given your risk tolerance and objectives. Retirement income planning is an ongoing process; it will not change your situation overnight. Furthermore, events beyond your financial advisor’s control, such as changes in economic conditions, will affect your retirement income planning results. Share with your financial advisor your expectations about the retirement income planning process and what you want to achieve. If your expectations are not met, let your financial advisor know so that he or she can make adjustments to meet your needs. Take an active role in the process and the results. Understand the process, your role and your financial advisor’s role. Provide information and ask questions about the recommendations you receive in the Recommendation Report. If at any time there are additional retirement goals you would like to cover or accounts, assets or income streams you would like to add to your Retirement Portfolio, let your financial advisor know. After reviewing your Recommendation Report with your financial advisor, the next step is to act on the retirement income planning advice you have received. Take an active role in making decisions about your financial future, and you will position yourself to get the most out of your retirement income planning relationship. Ameriprise Financial Services is dedicated to providing quality client service. We work hard to ensure your satisfaction with the service that you receive and seek to meet or exceed your expectations. We will work with you to address any of your concerns, including helping you work with a different financial advisor if you so choose. If you would like to work with a different financial 5 advisor, please call us at 800.297.6663 and we will help you find another financial advisor. If for some reason your financial advisor is unable to fulfill the terms of the Service Agreement, another Ameriprise financial advisor may be assigned to you to present the Recommendation Report and help you act on it. Other advisory services Your financial advisor may offer ongoing financial planning or other services that are not included in the Service for additional fees. In addition to the Service described in this Brochure Ameriprise Financial Services offers the following advisory services for retail investors: • Ameriprise Financial Services offers a suite of Advisory Solutions that features several types of Programs, including Strategic Portfolio Service (“SPS”) Advantage, SPS Advisor, Signature Wealth, Active Portfolios® investments, Select Separate Account, Vista Separate Account, Investor Unified Account, and Access Account. Not all Managed Account Programs are available to all clients; contact your financial advisor for more information. Please review the Ameriprise Managed Accounts Client Disclosure Brochure, or if you have elected to pay a consolidated advisory fee, the Ameriprise Managed Accounts and Financial Planning Service Disclosure Brochure for a full description of these Programs. As of December 31, 2025, Ameriprise Financial Services managed $304,183,842,664 in nondiscretionary assets and $356,290,579,112 in discretionary assets. • Ameriprise Financial Planning Service You also have the option to engage in the consolidated advisory fee service. The consolidated advisory fee service is a combined investment advisory service for which you will receive AFPS and at least one Managed Account Service. The fee is based on the assets in the Managed Account(s) with a portion of the fee calculated for AFPS, as described in the “Fees and Compensation” section. Any Managed Account fees are separate from and in addition to any advisory fees you pay for these additional services. A description of the advisory services listed above and the fees, compensation and other policies associated with each may be viewed online by visiting www.ameriprise.com/disclosures and expanding the sub-heading “General Disclosures” for Ameriprise Financial Planning Service and “Managed Account Client Disclosure Brochures” for Managed Accounts and consolidated advisory fee service. You should consider the aggregate costs and expenses of investment advisory services and products as a whole. Your financial advisor may not offer all investment advisory services or accounts. Ameriprise Financial Services also offers Ameriprise® Retirement Plan Consulting Services to employers and trustees and is designed to assist in their role as a plan fiduciary. Fees and Compensation The advisory fee for the Service (the “Service Fee”) ranges from 0.07% to 0.15% based on the value of your Managed Account assets included in your Retirement Portfolio as of each Calculation Date. The specific asset tier ranges and Service Fee rates are: Service Fee per Engagement Period* Retirement Portfolio Managed Account Assets as of Calculation Date $0 - $999,999 0.15% $1,000,000 - $1,999,999 0.12% $2,000,000 - $3,999,999 0.09% $4,000,000+ 0.07% *The monthly Service Fee amount you pay on each Posting Date will be 1/12 of the dollar amount determined on the Calculation Date and assumes a 12-month Engagement Period. 6 Assets that are not included in the Service Fee calculation are (i) products purchased through an Ameriprise financial advisor that are not held in an Ameriprise brokerage account, such as Ameriprise certificates, variable insurance and variable annuity products; and (ii) assets not held at Ameriprise Financial Services including “direct at fund” and “direct at issuer” positions. Account values are determined in good faith to reflect their estimated fair market value as further described in Section 5.D of the Service Agreement and Section 9 of the Ameriprise Brokerage Client Agreement. The Service Fee for each Engagement Period will be based on the most recent Recommendation Report provided to you. The Service Fee is calculated (i) initially on the last business day of the month when we receive confirmation that your first Recommendation Report was delivered; and (ii) for each Recommendation Report delivered thereafter, the Service Fee will similarly be recalculated on the last business day of the month in which the advisor confirmations delivery (each, a “Calculation Date”). For a Recommendation Report that is provided earlier than the typical twelve- month Engagement Period due to a change in your financial situation or retirement income planning goals, each of the Calculation Date and the Engagement Period are reset and any remaining Service Fee related to the prior Engagement Period will not be charged to you. This Service Fee will generally be deducted on the first business day of the month (each, a “Posting Date”) from the fee paying account (“Fee Paying Account”) in twelve proportionate monthly payments over the term of the Engagement Period. The Fee Paying Account you designate must be a nonqualified account. The Calculation Date process and monthly Posting Date will continue until the Service is terminated as described in the “Termination of the Service” section. Ask questions about the Service Fee so that you understand how it is calculated and what you can expect for this Service Fee. You are required to maintain sufficient cash balances in your Fee Paying Account to meet the applicable monthly payment, including any amounts in arrears. If on any Posting Date there is not sufficient cash in your Fee Paying Account to cover the portion of the Service Fee amount for that period, Ameriprise Financial Services reserves the right to, or may instruct the custodian to, sell securities held in your Fee Paying Account to cover the fee. If on any Posting Date the Fee Paying Account is not in good order, we will hold the payment for that month and repost on the next scheduled Posting Date including any updates to the Fee Paying Account to be charged. If Ameriprise Financial Services is unable to deduct the monthly payment over six consecutive Posting Dates, we reserve the right to terminate the Service. A state may impose a sales tax on your Service Fee, which we will collect and remit to the applicable state. Since the value of the Managed Accounts included in your Retirement Portfolio at each Calculation Date will vary, the Service Fee that you pay will vary for each Engagement Period. For each Engagement Period we will provide you with a written confirmation of the initial or updated Service Fee, as applicable, that includes a list of the Managed Accounts included in the Service Fee calculation. You authorize Ameriprise Financial Services to apply updated Service Fee changes by continuing to accept the Service. The Service Fee compensates Ameriprise Financial Services and is not shared with your financial advisor. Our affiliate American Enterprise Investment Services Inc. (“AEIS”) receives revenue from several different sources on the products and services you purchase through Ameriprise Financial Services. These sources include arrangements we have in place with product companies, and investment and interest income. See the “Cost Reimbursement Services and Third Party Payments” subsection of the “How we get paid” section later in this Disclosure Brochure for more information on conflicts of interest regarding revenue sources for Ameriprise Financial Services and its affiliates, as well as the subsection “Revenue sources for RiverSource Life Insurance Company and, in New York only, RiverSource Life Insurance Co. of New York (collectively, “RiverSource Life”)” for more information about the fees and commissions you pay when you implement your Recommendation Report through Ameriprise Financial Services and its affiliates. Your Recommendation Report and your financial advisor may recommend mutual funds offered by mutual fund firms that make Third Party Payments to our affiliate, AEIS, as described in the “Payments from product companies” subsection later in this Disclosure Brochure. Within its investment advisory business, compensation for the sale of investment products recommended by financial advisors is not Ameriprise Financial Services’ primary source of revenue from its advisory clients. To the extent that Ameriprise Financial Services receives 12b-1 fees for share classes held in any Managed Accounts, they will be rebated to clients. 7 Your Service Fee does not include Managed Account fees, markups or brokerage commissions by Ameriprise Financial Services or your financial advisor. If you implement your Recommendation Report in whole or in part through Ameriprise Financial Services or its affiliates, Managed Account Fees, product fees, markups or markdowns and brokerage commissions will apply as applicable. Both time of sale and ongoing fees, if applicable, will apply for products and services purchased in a transaction-based brokerage account. Information to help you evaluate the benefits, risks, and costs of the investments and services we offer as part of a brokerage relationship, as well as information about material conflicts of interest associated with recommendations we or our financial advisors make to our retail brokerage clients may be found at https://www.ameriprise.com/bestinterest. More detail about the differences between Managed Accounts and Ameriprise brokerage accounts may be viewed online by visiting https://www.ameriprise.com/disclosures and expanding the sub-heading “Managed Account Client Disclosure Brochures” and then clicking on “Evaluating differences between brokerage and managed accounts”. Client programs and promotions Ameriprise Financial Services may, from time to time, offer reduced or waived fees for the Service to individuals in a particular market segment or geographic area. Your financial advisor can tell you whether there is a promotion available to you. Ameriprise Financial Services, in its sole discretion, determines when to offer, modify and/or discontinue these promotions and programs. These promotions and programs are not available to financial advisors from the Ameriprise Advisor Center. Termination of the Service The Service will remain in effect until one of the following occurs: termination by you; termination of an existing Service Agreement by replacing it with a new one; termination by Ameriprise Financial Services, in its sole discretion; or termination by you through nonpayment of the Service Fee. Termination is effective immediately and your Service Fee will discontinue as of the termination date. If you terminate at any time after Ameriprise Financial Services has provided you the Recommendation Report for the appliable Engagement Period Ameriprise Financial Services reserves the right in its sole discretion to limit the amount of the refund you receive, if any. To terminate or cancel the Service Agreement, you may contact your financial advisor or call Ameriprise Financial Services directly at 800.297.6663 between the hours of 7 a.m. and 6 p.m. Central time, Monday through Friday. Performance-Based Fees and Side-by-Side Management Neither Ameriprise Financial Services nor any of its supervised persons accepts performance-based fees for its investment advisory services. Types of Clients The Service is currently available on a limited basis through a subset of our financial advisors. Most Ameriprise financial advisors do not offer this Service at this time and therefore the Service may not be available to you. The Service is intended for individuals; married couples; and domestic partners who meet various eligibility criteria such as retirement date, amount of assets earmarked for your Retirement Portfolio, assets held at Ameriprise Financial, and types and complexity of the investment accounts and other financial products you would like to designate for inclusion in the Service. At the time of enrollment, the Service also requires you to open or maintain at least $1,000,000 in net investable assets held at Ameriprise Financial Services and included in your Retirement Portfolio. If you enroll in the Service, you will be provided at least a 90 day period to satisfy applicable eligibility requirements. If your enrollment in the Service is not possible due to one of more eligibility factors, you will be notified. Married person as individual client: If you are married and participating in the Service as an individual, your spouse is not a party to the Service Agreement. Your analysis and recommendations will be based on information that you provide regarding your retirement income planning goals, needs, and priorities. 8 Methods of Analysis, Investment Strategies and Risk of Loss The Service differs from an Ameriprise Managed Account or AFPS where your financial advisor develops advice and recommendations for you. The Service utilizes a centralized approach and financial advisor provides information about your preferences, financial situation, and goals to the Service team who will prepare recommendations for you. To develop your retirement income plan, the Service Team utilizes the retirement goals, assets, income sources and other information you and your financial advisor have provided to the Service Team in combination with research and analytics produced by Ameriprise Financial Services and its affiliates. This includes material prepared by the Ameriprise Investment Research Group ("IRG") and third-party research providers that have been approved by Ameriprise Financial Services. The Ameriprise Premier Retirement Income Oversight Committee (the “Committee”), provides oversight for Service, including the methods of analysis and investment strategies utilized by the Service Team to provide recommendations to clients. Each Recommendation Report seeks to address the following key retirement income planning strategies. Not all strategies may be available to you: Basic financial position. At a minimum, this will include a high-level compilation of the assets you intend to utilize for retirement, income (inflows) and expenses (outflows). It will also include recommended action step(s) based on information provided by you or your financial advisor at the time the analysis is completed. Covering Essential Expenses. Seeks to provide dependable income sources. The Service can incorporate covering essential expenses such as housing, food, utilities, taxes and healthcare with solutions that may offer dependable or stable income to help cover your basic needs. Consider your risk tolerance and individual circumstances and discuss with your financial advisor on whether covering essentials is appropriate for you. Retirement Goals. Seeks to provide portfolio construction and initial withdrawal amounts. Using the information you or your financial advisor provides the Service Team will provide you with recommendations that help you balance your need for regular income, resources for unexpected events and ending portfolio value. Social Security Claiming Strategy. The Recommendation Report includes an evaluation of the options available to you to claim Social Security benefits so you can evaluate the potential benefit you could receive at different ages and under different circumstances. Managing Risk. Seeks to address asset bucketing and adaptive withdrawals. To help manage the risk of outliving your savings, the Service will help you match your Retirement Portfolio assets with the point in time when you might need them in order to optimize the amount of income available. Tax Efficiency. Seeks to address tax-efficient withdrawals, tax-loss harvesting, and asset location. The Service will help you to efficiently manage the amount of taxes you may pay throughout retirement. Ameriprise Financial Services and your financial advisor do not provide legal or tax advice as part of the Service or under any other circumstances. Your external accounts are analyzed and incorporated into the overall portfolio allocation recommendation and will be included for tax efficient withdrawal purposes. However, the Service does not provide security specific recommendations in your investment accounts held outside of Ameriprise. For accounts held at Ameriprise Financial, your account assets will be incorporated into the key retirement income planning strategies listed above. When developing recommendations for you, the Service Team compares your stated retirement income goals with your financial situation, retirement risk tolerance, investment horizon and potential investment solutions. The Service Team may use current asset values, current and projected rates of return, and other assumptions based on information you provide to your financial advisor, as well as historical return analysis prepared by Ameriprise Financial Services or an affiliate. Your Recommendation Report is prepared using of one or more software packages or tools to analyze your retirement income goals using various methods of analysis, including deterministic and probability modeling. The analysis and projections generated by the tools or other analysis described in this section of the Brochure include information regarding the likelihood of various potential investment outcomes. They are hypothetical in nature, vary with each use and over time, do not reflect actual investment results, and are not guarantees of future results. 9 Investing in securities involves the risk of loss and you should be prepared to bear this loss. The projections may also vary based on differing assumptions, and from one Recommendation Report to the next based on changing circumstances and market information. Results may reflect point in time estimates only and are only one of the many factors you should consider as you determine how best to plan for your future. Your Recommendation Report also typically includes an asset allocation analysis designed to assist you in positioning your investment assets held at Ameriprise. If your Recommendation Report includes such analysis, the recommended portfolio allocation will be determined based on a variety of factors, including your personal financial information and capital market assumptions for different asset classes provided by the IRG. The analysis is meant only to illustrate the relative experience among asset classes and portfolios. Periodic rebalancing of your portfolio and reallocation among the asset classes within your Retirement Portfolio is recommended in most circumstances, but automatic ongoing rebalancing and reallocation is not part of the Service. Rebalancing your nonqualified accounts to meet asset allocation objectives may result in taxable gains or losses. Unless included in a particular Ameriprise Managed Account Program, Ameriprise Financial Services does not rebalance your portfolio or reallocate your target asset allocations on a continuous basis. If you have a substantial percentage of your net worth concentrated in a given asset or asset class, the illustrations may recommend that you sell or exchange a significant portion of such position to reduce risk by reducing the concentrated positions within your portfolio. Special tax rules apply to net unrealized appreciation of employer securities held in a retirement plan. This is particularly true if the asset in question is a stock of your employer, given that both your income and investment could be tied to the profitability of your employer. Before you actually sell any such assets, consult with your legal and tax professionals regarding the tax and other implications of any such sales. The asset allocation analysis does not provide a comprehensive financial analysis of your ability to reach your other financial planning goals, and it does not identify the impact of your investment strategy on your tax and estate planning situations. Asset allocation does not guarantee a profit or protect against a loss. The Recommendation Report will include, when appropriate for repositioning of your investment assets, recommendations to reposition your investment assets held at Ameriprise Financial Services, including recommendations to purchase mutual funds and ETFs. The Committee reviews and approves the eligible mutual funds and ETFs and the factors applied to produce the specific investments recommended. The universe of eligible mutual funds generally represents a sub-set of the funds that appear on the Starting Point List or are otherwise sponsored or managed by Full Participation Firms that make cost reimbursement payments to AEIS. The list of eligible funds is therefore designed to primarily include, and therefore favor, mutual funds from Full Participation Firms as further described in the “Cost Reimbursement Services and Third-Party Payments” and “Payments from other non-affiliated product companies” sections of this Brochure. Automated Advice Usage and Governance. Effective on or around September 2024, the Service uses algorithmic functions to automatically produce certain investment advice and recommendations for your Recommendation Report. This automation uses a key set of assumptions and methodologies that IRG has determined are appropriate. The underlying data sources that feed these key assumptions and methodologies include data we receive directly from you, from internal sources, or from third-party data sources. Periodic testing is conducted to evaluate that the automation, including any changes or updates to the automation, continues to operate as designed. The Service Team may review and replace all or a portion of the output produced from the automation in certain circumstances such as to further refine and tailor the advice and recommendations to your specific financial situation and Client Information. Sources of information The principal source of information used by the Service Team is the data provided by you, such as your personal data, assets and liabilities, income expectations, assumed overall rates of taxation, short-term and long-term retirement income planning goals, tax information, risk tolerance associated with goals, and other relevant information. Although the information and data are believed to be accurate, Ameriprise Financial Services and its financial advisors do not independently verify third-party information. Neither Ameriprise Financial Services nor its financial advisors guarantee the accuracy, completeness or timeliness of any such information nor do they imply any warranty of any kind regarding the information provided. 10 For your accounts held at Ameriprise Financial, market value (i.e., account value) is provided from the source of record and is generally captured at a point in time. If the date and market value displayed in analysis or written recommendations you receive does not correspond with the date and market value of your official Ameriprise Financial consolidated statement, the market values shown on the material you receive will differ from your consolidated statement. The information provided to you in your analysis and written recommendations is not intended to be a substitute for the valuation and other information contained in your official Ameriprise Financial consolidated statement. For your accounts and assets not held at Ameriprise Financial (“Non-Held Assets”) all asset and net worth information used in connection with your Service was provided by you or your designated agents and is shown as of the date it was provided to Ameriprise Financial Services. Ameriprise Financial Services does not have knowledge of changes in your Non-Held Assets, including your accounts and portfolio holdings, and the materials provided in connection with your Service will not reflect changes to your Non-Held Assets. This means that if we do not have access to or you do not update your Non-Held Assets, the information and assumptions provided to you will be based on data about Non-Held Assets that is not current. Ameriprise Financial and your financial advisor take reasonable steps to reproduce information obtained from you or your designated agents regarding Non-Held Assets. Neither Ameriprise Financial nor your financial advisor has undertaken to review or verify the accuracy of Non-Held Assets and the inclusion of information and assumptions about Non-Held Assets in your Recommendation Report, or any other analysis, review, or guidance offered by Ameriprise Financial Services and your financial advisor creates no duty or other responsibility to advise you to take any action or inaction regarding such Non-Held Assets. Investment strategies The Service Team may recommend long-term strategies such as long-term investing, reinvestment of dividends or other proceeds on investments, and asset allocation. Recommendations may also be made to help you realize capital gains or losses on securities or investment products that you own. Such transactions may have tax consequences for nonqualified accounts. We cannot guarantee future financial results or the achievement of your retirement income planning goals through implementation of your Recommendation Report and any advice or recommendations provided to you by your financial advisor. Ameriprise Financial Services does not monitor the day-to-day performance of your specific investments. Before implementing your Recommendation Report, you should carefully consider the ramifications of purchasing products or services, and you may want to seek further advice from your lawyer and/or accountant, particularly in connection with estate planning and taxes. Investment and market risk You should understand that: • All investments involve the risk of loss and you should be prepared to bear such a loss (the amount of which may vary significantly), • Investment performance or tax treatment of any accounts and assets included in your Retirement Portfolio can never be predicted or guaranteed, • The market value of your Retirement Portfolio will fluctuate due to market conditions and other factors such as liquidity and volatility, • There is no guarantee that the Service or its related recommendations will meet its objectives, • Past performance does not predict future performance with respect to any product or service described in this Disclosure Brochure, and • All trading in your Ameriprise Accounts or other accounts will be at your risk. The risks of participating in the Service include but are not limited to the following: • Market Risk. Market risk refers to the possibility that the market values of securities or other investments will fall, sometimes rapidly or unpredictably, or fail to rise, because of a variety of actual or perceived factors affecting issuer, industry or sector in which it operates or the market as a whole. • Interest Rate Risk. The interest rate risk is the risk that investment value is sensitive to changes in interest rates. In general, a rise in interest rates may result in a price decline of fixed-income instruments. This risk may be heightened for longer maturity and duration instruments. 11 • Inflation Risk. Inflation risk is the uncertainty over the future value of an investment due to inflation. Investments may not keep pace with inflation, which may result in losses. • Liquidity Risk. Liquidity risk is the risk associated with any event, circumstance, or characteristic of an investment or market that negatively impacts the ability to sell, or realize the proceeds from the sale of, an investment at a desirable time or price. • Tax Risk. This is the risk that the tax treatment of certain investments and of the income and gain therefrom is uncertain and can vary over time. • Legal and Regulatory Risk. This is the risk that new or revised laws or regulations may adversely affect investments included in the Service. • Business Disruption Risk. This is the risk of business disruption of varying severity and scope occurring. The types of disruption may include, but not be limited to, firm-only disruption, disruption that affects a single building, a disruption that affects the entire city or business district, and disruption that affects the entire region. Please read more in Ameriprise Financials’ Business Continuity Plan Disclosure and Ameriprise Financial Client Relationship Guide. • Cybersecurity Risk. With the use of technologies such as internet to conduct business, businesses are susceptible to cybersecurity breaches, please read more at https://www.ameriprise.com/privacy-security-fraud. • Technology Risk. Businesses must rely in part on digital and network technologies to conduct business, provide services and maintain business operations. These technology systems may fail to operate properly or become disabled as a result of events or circumstances wholly or partly beyond control. Technology failures, whether deliberate or not, could have a material adverse effect and could result in, among other things, financial loss, reputational damage, regulatory penalties or the inability to conduct business. The risks described above should not be considered to be an exhaustive list of all the risks which clients should consider. Disciplinary Information Below is notice of certain regulatory and legal settlements entered into by Ameriprise Financial Services during the last ten years: Regulatory proceedings Ameriprise Financial Services entered into each of the regulatory settlements listed below without admitting or denying the allegations. Securities and Exchange Commission (“SEC”) and FINRA Actions In August 2024, Ameriprise Financial Services reached a settlement with the SEC in connection with its industry- wide review of firms’ recordkeeping practices regarding business-related electronic communications sent or received by firm personnel using non-approved channels or methods (“off-channel communications”). The settlement resolved allegations that, from at least June 2019, the firm did not maintain or preserve the substantial majority of off-channel communications that were records required to be maintained under federal securities laws and therefore failed to reasonably supervise its personnel. The firm agreed to pay a civil penalty amount of $50 million. Prior to the settlement, the firm retained a compliance consultant to address certain undertakings outlined in the settlement and took steps to enhance its policies and procedures and increase training concerning the use of approved communications methods. In August 2018, Ameriprise Financial Services reached a settlement with the SEC regarding allegations that from 2011 through 2014 the firm failed to adopt and implement policies and procedures reasonably designed to safeguard retail investor assets against misappropriation and failed to reasonably supervise five representatives with a view to preventing and detecting violations of certain federal securities laws by these representatives. The firm agreed to pay a civil penalty amount of $4.5 million. The firm further reimbursed all impacted clients for the losses they incurred due to the misconduct. The firm also took steps to enhance policies, procedures and controls related to the safeguarding of client assets against theft or misappropriation by its associated persons and voluntarily retained a compliance consultant to assess and confirm the reasonableness of these policies, procedures and controls. 12 In December 2017, Ameriprise Financial Services reached a settlement with the SEC regarding allegations that from December 2010 through October 2013, the firm negligently relied on misrepresentations made by F- Squared Investments, Inc. regarding certain of its ETF portfolios and, as a result, the firm made false statements about the portfolios in certain advertisements. The SEC also alleged that the firm had failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the alleged violations. The firm agreed to pay a disgorgement amount of $6.3 million plus prejudgment interest of $700,000 and a civil penalty amount of $1.75 million. In September 2016, Ameriprise Financial Services reached a settlement with FINRA regarding allegations that between October 2011 and September 2013 the firm failed to detect and prevent the conversion, via wire transfers, of more than $370,000 from five of its customers by one of its registered representatives. The customers were family members of the registered representative. FINRA also alleged this went undetected because the firm failed to establish, maintain, and enforce a supervisory system that was reasonably designed to review and monitor the transmittal of funds from accounts of customers to third parties, including those controlled by registered representatives of the firm. The firm paid restitution and a fine of $850,000. Other financial industry activities and affiliations Ameriprise Financial Services, LLC is a subsidiary of Ameriprise Financial, Inc. and conducts its activities directly and through its affiliates. These activities may be material to its investment advisory business or its investment advisory clients. These affiliates include companies under common control with Ameriprise Financial Services by virtue of their status as direct or indirect subsidiaries of Ameriprise Financial, Inc. The information below provides you an overview of the Ameriprise Financial, Inc. companies. These companies work together to offer you financial products and services designed to help you reach your financial goals. Broker-dealer Ameriprise Financial Services, LLC is a registered investment adviser and broker-dealer with the SEC and is authorized to engage in the securities business in all 50 states as well as the District of Columbia, Puerto Rico, and the U.S. Virgin Islands. Registration with the SEC does not imply a certain level of skill or training. Ameriprise Financial Services is also a member of FINRA and the Securities Investor Protection Corporation (“SIPC”). Ameriprise Financial Services is registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor (“CTA”) and has obtained membership with the National Futures Association (“NFA”) in connection with such CFTC registration. In its capacity as a broker-dealer, Ameriprise Financial Services distributes or receives compensation from selling various products including but not limited to equities and fixed income products. Offerings include corporate bonds and municipal securities, mutual fund shares, ETFs, 529 plans, face-amount certificates, closed-end funds, preferred securities, UITs, non- traded REITs, non-traded BDCs, non-traded closed end funds, hedge fund offerings, structured products, real estate private placement offerings, exchange funds, private equity offerings, 1031 exchanges, fixed, structured and variable annuities, and fixed and variable insurance. Ameriprise Financial Services also sells managed futures funds that engage in trading commodity interests, including futures. In addition, Ameriprise Financial Services is the distributor of the publicly offered face-amount certificates issued by Ameriprise Certificate Company. Ameriprise Financial Services also may serve as an underwriter or member of a selling group for securities offerings, including those issued by affiliates. Retail brokerage services are made available through Ameriprise Financial Services, which has an agreement with American Enterprise Investment Services Inc. (“AEIS”), a registered broker-dealer and an affiliate of Ameriprise Financial Services. Ameriprise Financial Services requires clients to agree in their client agreements that their account(s) are introduced by Ameriprise Financial Services to AEIS on a fully-disclosed basis, and that securities purchase and sale transactions in their account(s) shall be directed through AEIS. You should consider that not all investment advisory firms require clients to direct execution of transactions through a specific broker-dealer. Brokerage accounts are carried by, and brokerage transactions are cleared and settled through, AEIS, subject to AEIS policies to assure that the resultant price to the client is as favorable as possible under the prevailing market conditions. See the “Working in Your Best Interest-Regulation Best Interest Disclosure” for more information about potential conflicts of interest relating to brokerage transactions. 13 For purposes of Form ADV Part 2 certain Ameriprise Financial Services management persons are registered representatives of Ameriprise Financial Services in its capacity as a broker-dealer, registered representatives of American Enterprise Investment Services Inc., and are associated persons of Ameriprise Financial Services in its capacity as a commodity trading advisor. Ameriprise Financial Services approves and opens accounts and accepts securities order instructions with respect to the accounts. AEIS serves as Ameriprise Financial Services’ clearing agent in providing clearing and settlement services for transactions that are executed for customers of Ameriprise Financial Services. In exchange for a fee paid by Ameriprise Financial Services, AEIS provides clearing, custody, record keeping and all clearing functions for certain advice-based accounts. In addition, AEIS may act as an agent in effecting securities transactions for certain Ameriprise Bank trust accounts. AMPF Holding LLC, an indirect wholly-owned subsidiary of Ameriprise Financial, Inc., is a holding company for Ameriprise Financial Services and AEIS. Columbia Management Investment Distributors, Inc. (“Columbia Management Investment Distributors”), an indirect wholly- owned subsidiary of Ameriprise Financial, Inc., is a registered broker-dealer serving as principal underwriter and distributor of registered mutual funds and other funds advised by affiliated companies Columbia Management Investment Advisers, LLC (“CMIA”) and Columbia Wanger Asset Management, LLC, (“Columbia Wanger Asset Management”) (collectively, “Columbia Management” or “Columbia”). These funds are collectively referred to as the “Columbia Funds.” Investment company Ameriprise Financial Services has arrangements with Ameriprise Certificate Company to distribute and sell its face- amount certificates and selling arrangements with Columbia Management Investment Distributors to distribute the Columbia Funds. Investment advisory firm Columbia Management Investment Advisers, LLC is registered as an investment adviser with the SEC. CMIA provides investment management services to: • Columbia Funds, as well as Columbia ETFs, closed-end funds and private funds • Ameriprise Certificate Company • RiverSource, as well as the Columbia Funds underlying certain variable contracts issued by RiverSource • Various wrap program sponsors, including Ameriprise Financial Services • Other affiliated and unaffiliated clients. Ameriprise Financial, Inc. has other subsidiaries that are registered as investment advisers with the SEC, including Threadneedle International Limited and Lionstone Partners, LLC. These subsidiaries are registered as investment advisers and may provide advice to domestic and foreign institutional clients, the Columbia Funds, the Columbia ETFs, the Columbia closed-end funds, private funds and other fiduciary clients. These entities provide services independent from Ameriprise Financial Services. Columbia Management and its affiliates Threadneedle Asset Management Ltd, (U.K. based), Threadneedle Investments Singapore (Pte.) Limited (Singapore based), and Columbia Threadneedle Investments (ME) Limited (Dubai based) operate under a combined global asset management brand, Columbia Threadneedle Investments. Ameriprise Financial Inc. also has non-US subsidiaries that provide asset management services. These include Columbia Threadneedle Management Limited (“CTML”), Columbia Threadneedle Netherlands B.V. (“CTLN”), Columbia Threadneedle Business Limited (“CTBL”), Columbia Threadneedle AM (Asia) Limited (“CTAMLA”), Columbia Threadneedle (EM) Investments Limited (“CT (EM)”) and Pyrford International Ltd (“Pyrford”). Each of CTML, CTLN, CTBL, CTAMLA, CT (EM) and Pyrford is registered with the appropriate respective regulators in their home jurisdictions. In addition Pyrford is also registered with the SEC as an investment adviser. Columbia Management Investment Advisers is also registered with the CFTC as a commodity pool operator and a CTA and has obtained membership with the NFA in connection with such CFTC registration. Threadneedle International Limited is registered with the CFTC as CTA and has obtained membership with the NFA in connection with such CFTC registration. 14 Banking institution Ameriprise Bank, FSB, a wholly owned subsidiary of Ameriprise Financial, Inc. and an affiliate of Ameriprise Financial Services, is a federal savings bank. In addition to its participation in the AIMMA and ABISA Sweep Programs, Ameriprise Bank currently makes available a core set of banking products, including mortgage financing, co-branded credit cards with an associated rewards program, savings, certificates of deposits (“CDs”) and checking accounts, and pledged asset loans. Ameriprise Bank provides personal trust services to clients, including trustee and investment management services for asset trusts, and investment management and custodial agency services for individual, individual trustee, association and non- profit organization accounts. Ameriprise Financial Services establishes custodial accounts and accepts securities order instructions for trust accounts at Ameriprise Bank. In addition, Ameriprise Financial Services may provide investment advice and research support to Ameriprise Bank and its clients for these trust accounts. Trust company Ameriprise Trust Company (“ATC”), a Minnesota-chartered trust company, provides custodial, investment management and collective trust fund services for employer-sponsored retirement plans, including pension, profit sharing, 401(k) and other qualified and nonqualified employee retirement plans. ATC also serves as custodian for IRAs, 403(b)s and some retirement plans qualified under section 401(a) of the Internal Revenue Code of 1986 as well as the Ameriprise Certificate Company. ATC is not a deposit bank or a member of FDIC. Insurance company Affiliated insurance products sold by Ameriprise Financial Services and its financial advisors are issued by RiverSource Life Insurance Company ("RiverSource Life”), a stock life insurance company that is qualified to do business as an insurance company in the District of Columbia, American Samoa and all states except New York; and in New York only, issued by RiverSource Life Insurance Co. of New York (“RiverSource Life of NY”), a stock life insurance company that is qualified to do business as an insurance company in New York. The products of RiverSource Life and RiverSource Life of NY (together, “RiverSource”) include structured annuities (RiverSource Life only), fixed and variable annuities, fixed and variable life insurance, disability income insurance and life insurance with long-term care benefits. Insurance products are also offered by other third parties through an arrangement with Ameriprise Financial Services and through Diversified Brokerage Services, Inc. and LTCI Partners, and Disability Resource Group, which act as co-general agents. RiverSource Distributors, Inc. (“RiverSource Distributors”), a wholly owned subsidiary of Ameriprise Financial, Inc., is a registered broker-dealer, serving as principal underwriter and distributor of RiverSource variable life insurance and annuities on behalf of RiverSource. Ameriprise Financial Services has selling arrangements with RiverSource and RiverSource Distributors to distribute these products. Ameriprise Financial Institutions Group (“AFIG”) AFIG is a business channel within Ameriprise Financial Services that specializes in delivering investment products and services to clients of financial institutions, such as banks and credit unions. Ameriprise Financial Services enters into a networking arrangement with each financial institution whereby AFIG financial advisors provide one or more of our investment advisory services, brokerage services and insurance products to clients of the financial institution and other persons or entities that may be introduced or referred to us by the financial institution. The financial institution provides AFIG financial advisors joint marketing access to a distinct client segment and may provide office space in the building where it conducts its business. As a part of the contractual arrangement with the financial institution, Ameriprise Financial Services shares with the financial institution a portion of up to 94% of fees and commissions, including Wrap Fees charged for investment advisory services, generated by AFIG financial advisors that are attributable to our operations under the joint marketing agreement with the financial institution. A portion of these fees may be paid to financial advisors who are employees of the financial institution, as described below. All AFIG financial advisors are licensed and registered through Ameriprise Financial Services. Ameriprise Financial Services has exclusive control over the activities conducted on our behalf under the agreement with the financial institution and is responsible for the supervision of certain activities of AFIG financial advisors. AFIG financial advisors are affiliated with 15 Ameriprise Financial Services in one of three ways: independent contractors and their personnel, Ameriprise employee financial advisors and financial institution employee financial advisors. Financial advisors employed by the financial institution are compensated by the financial institution from the portion of fees and commissions it receives from Ameriprise Financial Services. In such cases the financial institution serves as paying agent on our behalf in accordance with applicable law. The level of compensation received by financial advisors employed by the financial institution is based on their employment agreement with the financial institution. Ameriprise Financial Services does not pay any compensation to any non-registered employee or agent of the financial institution for referrals. Any referral fee paid by the financial institution to an employee or agent is a one-time, per-customer fee of a nominal, fixed dollar amount and is unrelated to the products and services you purchase. AFIG financial advisors who provide services at a financial institution that does not have a Trust Department can offer trust services through other providers, including our affiliate, Ameriprise Bank. Ameriprise Financial Services and the AFIG financial advisor may serve as a finder related to trust services and may receive a referral fee for business referred to unaffiliated trust providers. Ameriprise Financial Services is not a bank or credit union. Any services or products you purchase through an AFIG financial advisor are not guaranteed or insured by Ameriprise Financial Services or the financial institution. The financial institution is not a party to your Client Agreement with us. Ameriprise Financial Services and each financial institution have entered into a networking agreement under which we have agreed to share fees and commissions with the financial institution, including Wrap Fees charged for investment advisory services. Non- registered employees of the financial institution may also receive compensation for referring you to Ameriprise Financial Services. How we get paid This section should be read in connection with the “Advisory Business,” “Fees and Compensation” and/or the “Client Referrals and Other Compensation” sections in this Brochure. Ameriprise Financial Services and its affiliates receive revenue from several different sources on the products and services you purchase. These sources include the fees and charges you pay, other arrangements we have in place with product companies, and investment and interest income. The revenue generated or received supports, in part, the development of new products, maintenance of our infrastructure, and retention of employees and financial advisors. Further on in this section you will find information on how our financial advisors are paid. Cost Reimbursement Services and Third-Party Payments Payments from product companies. AEIS will receive the following types of payments with respect to the investment products we recommend and you select for the investment of your applicable Managed Account assets. This compensation is used in part to fund the cost of providing the services, maintaining Managed Accounts and offering an investment platform for our clients as well as providing revenue and net earnings to AEIS. For qualified SPS Advisor Accounts, inherited IRAs in qualified SPS Advantage Accounts where a trust has inherited the IRA and Ameriprise Bank acts as trustee of the trust and eligible trustee-directed retirement plans in Select Separate Accounts, AEIS either does not collect Third Party Payments or credits them back to client Accounts as described in the “Fees and Compensation” section. AEIS performs certain services for the benefit of Ameriprise Financial Services, its financial advisors and clients, including but not limited to recordkeeping, administration and shareholder servicing support, applicable platform level eligibility and investment product due diligence, investment research, training and education, client telephonic and other servicing, and other support related functions such as trading systems, asset allocation and performance reporting tools, websites and mobile applications (collectively “cost reimbursement services”). Any cost reimbursement payments received by AEIS that are paid by product sponsors out of assets of the investment, such as a mutual fund or unit investment trust, reduce the investor return on their investment. AEIS also receives revenues that exceed the costs of the cost reimbursement services provided. These revenues include cost reimbursement and marketing support payments (as described below under the heading "Education, training, seminar reimbursement and noncash compensation") and such payments increase the gross revenues and net earnings of AEIS. Ameriprise Financial Services has a financial incentive for its affiliate to continue to maintain these cost reimbursement arrangements, including arrangements with Full Participation Firms and for AEIS to continue to receive revenue. Because not 16 all investments provide for cost reimbursement payments, AFSI has an incentive to recommend or select investment products that make such payments within Managed Account Programs. Ameriprise Financial Services addresses this conflict of interest by applying objective due diligence standards and requiring all mutual funds, ETFs, ETNs, CEFs, UITs and alternative investments offered in the Programs to meet these standards. AEIS receives a variety of payments for cost reimbursement services from affiliated products sponsored or managed by affiliated investment advisers (e.g., Columbia Management) and by non-affiliated investment product companies which reimburse the costs of beneficial client services provided by Ameriprise Financial Services and AEIS. The most significant of these payments are reimbursement for marketing support received from the product companies. AEIS receives cost reimbursement payments from product companies for the following products: mutual funds, 529 plans, actively managed ETFs, UITs, non-traded REITs, real estate private placements, tax-deferred real estate exchanges, non-traded BDCs, fixed annuities, variable annuities, structured annuities, fixed insurance, variable insurance, structured products, managed futures funds, private equity offerings, non-traded closed end funds and hedge fund offerings. Ameriprise Financial Services receives cost reimbursement payments on our affiliated and unaffiliated annuity and insurance products which are not eligible investments for Managed Accounts. These payments are discussed in the remaining paragraphs of this section. If AEIS and its affiliates did not receive this compensation, Ameriprise Financial Services would likely charge higher fees or other charges to clients for the services provided. When evaluating the reasonableness of the fees and expenses incurred in a Managed Account, you should consider not just the Wrap Fee, but also the fund-level fees and other compensation that Ameriprise Financial Services and its affiliates receive including payments for cost reimbursement services described in this section and other cost reimbursement and marketing support payments received by us and our other affiliates, as described in the “How we get paid” and the “Revenue sources for other Ameriprise Financial, Inc. companies” sections of this Brochure as applicable. Mutual Fund and 529 Plan Marketing and Sales Support Payments. Mutual fund and 529 plan marketing and sales support payments are received from certain mutual fund firms. These payments form a structure referred to here as the Ameriprise Financial Mutual Fund Program (“Mutual Fund Program”) with approximately 140 mutual fund families offered by Ameriprise Financial Services. The goal at Ameriprise Financial Services is to offer a wide range of mutual funds using the following criteria: • Product breadth and strong-performing funds • Financial strength of the firm • Marketing and sales support payments paid to our affiliate AEIS to support cost reimbursement services Ability to provide product support and training to our financial advisors • Tax benefits offered by individual states • Overall quality of the 529 plan (specific to 529 plans) Ameriprise financial advisors may offer, and clients are free to choose, mutual funds from approximately 140 fund families available. However, certain aspects of the Mutual Fund Program create a conflict of interest or incentive if Ameriprise Financial Services promotes, or Ameriprise financial advisors recommend, the mutual funds offered by a firm participating in the Mutual Fund Program versus mutual funds offered by nonparticipating firms. As further described below, these conflicts and incentives arise from the cost reimbursement related to Education, Training, Seminar Reimbursement and noncash compensation, provided to our financial advisors by, as well as the payments AEIS receives from, firms participating in the Mutual Fund Program and with other relationships with firms, including Columbia Management; see the section titled “Columbia Funds” below. To be included in the Mutual Fund Program, firms have agreed to pay AEIS a portion of the revenue generated from the sale and/or management of mutual fund shares. Full Participation Firms make cost reimbursement payments at a higher level than do firms that have arrangements discussed in the “Other financial relationships” section. For each year a client holds shares of a particular mutual fund, the mutual fund’s advisor or distributor may pay to AEIS an amount based on the value of the collective mutual fund shares held in clients’ accounts (asset-based payment). AEIS receives an asset-based payment (up to 0.20% per year for mutual funds and 0.18% per year for 529 plans) on some or all of Ameriprise Financial Services clients’ assets managed by the participating firms. In instances where a new Full Participation Firm relationship is established, in certain instances, to offset AEIS expenses for providing cost reimbursement services, the cost reimbursement payments will initially be structured in the form of an annual flat fee in addition to 0.20% of assets invested, with the total dollar amount of such payment not to exceed $1,250,000. 17 Certain Full Participation Firms pay our affiliate AEIS more marketing support for certain types of mutual funds. In general, Full Participation Firms offer actively managed mutual funds that permit for cost reimbursement payments to be included in the Investment Costs charged by the mutual fund. The Investment Costs of actively managed mutual funds are generally higher than those of (i) passively managed ETFs which do not make cost reimbursement payments; and (ii) actively managed ETFs which do make such payments. Ameriprise Financial Services has a financial incentive to offer actively managed mutual funds and ETFs that make cost reimbursement payments to our affiliate. As a result, Ameriprise financial advisors may have an indirect incentive to sell such mutual funds and ETFs. We address this incentive by offering a full range of investment product options, including actively managed mutual funds and both actively and passively managed ETFs. In addition, we do not offer actively managed ETFs that are clones of an actively managed mutual fund from the same firm. A similar actively managed ETF may have a lower or comparable management fee as an actively managed mutual fund. Ameriprise further addresses this conflict of interest by calculating the compensation paid to our financial advisors for all assets without regard to the amount of cost reimbursement payments we or our affiliates receive in connection with client investments in mutual funds and other investment products. Additionally, Ameriprise Financial Services does not share with our financial advisors the cost reimbursement payments we or our affiliates receive. If your Account’s Sweep Program uses a money market mutual fund, AEIS receives cost reimbursement payments of up to 0.37% of the amount held in that money market fund Sweep Program. The amount that AEIS receives may be reduced based on fee waivers that are imposed by the money market fund firm. These arrangements vary between firms and may be subject to change or renegotiation at any time. If a firm ceases to make cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the mutual fund firm. Full Participation. Thirty firms fully participate in the Mutual Fund Program. These fund firms include Columbia Threadneedle Investments, Allspring Funds, American Century Investments, Amundi, BlackRock Funds, BNY Mellon, Delaware Investments, DWS Investments, Eaton Vance, Eventide Funds, Federated Hermes, Fidelity, First Eagle Funds, Goldman Sachs Asset Management, Invesco, Janus Henderson Investors, John Hancock Investments, JP Morgan Asset Management, Lord Abbott, MainStay Funds, MFS, Natixis Funds, Neuberger Berman, Nuveen, Principal, PGIM Investments, Virtus and Voya Funds. These firms are referred to as “Full Participation Firms.” We offer 529 plans from nineteen firms. Of those firms, fifteen are Full Participation Firms. These fund firms include American Century, BlackRock, Columbia Threadneedle Investments, Fidelity, Franklin Templeton, Goldman Sachs, Hartford, Invesco, John Hancock, J.P. Morgan, MFS, Nuveen, Principal, Virtus and Voya. Each of these firms is referred to as a “Full Participation Firm.” The most current Mutual Fund Program information, as well as the previous calendar year’s totals of cost reimbursement payments received from Full Participation firms, in addition to distribution support amounts, may be viewed online by visiting www.ameriprise.com/funds and clicking on “An Investor’s Guide to Purchasing Mutual Funds and 529 Plans at Ameriprise Financial.” Education, Training, Seminar Reimbursement and noncash compensation. Full Participation Firms provide to Ameriprise financial advisors and, in some cases, to their clients, education, training, and support services relating to the investment products they offer. These firms may reimburse Ameriprise Financial Services, and Ameriprise Financial Services may subsequently reimburse Ameriprise financial advisors, for client/prospect education events and financial advisor sales meetings, seminars and training events, consistent with Ameriprise Financial Services policies. Ameriprise Financial Services and its financial advisors may also receive nominal noncash benefits from time to time. As a result, Ameriprise financial advisors may have a greater familiarity with and an incentive to sell investment products of Full Participation Firms. Firms sponsoring alternative investments may also provide to Ameriprise financial advisors and, in some cases, to their clients, education, training, and support services relating to the investment products they offer. Payments for Product Implementation and Trading Technology Expenses. For most investment products, AEIS will receive payments of up to $25,000 per investment product per expense from third-party firms to reimburse expenses associated with each of (i) conducting due diligence on the investment product; and (ii) the implementation of certain technology platforms or capabilities related to the distribution of the investment product. 18 For most model investment portfolios in Signature Wealth and certain SMA strategies in Select Separate Account, AFS will receive payments of (i) up to $25,000 per investment product per expense; or (ii) reimbursement of actual costs incurred to reimburse expenses associated with the implementation of certain technology platforms or capabilities related to the distribution of the investment product. Payments from Investment Providers offering SMA investment portfolios within the Signature Wealth Program. AEIS receives cost reimbursement payments for the sale of SMA investment portfolios offered within the Signature Wealth Program. AEIS receives an asset-based payment of up to 0.04% per year on Ameriprise Financial Services clients’ assets invested in the SMA investment portfolios. If an Investment Provider ceases to make such cost reimbursement payments, Ameriprise Financial Services would likely cease the distribution relationship with the firm. Other financial relationships Distribution Support Relationships. AEIS also has cost reimbursement arrangements with firms for distribution support services. These “Available for Sale Firms” make payments to AEIS for distribution support but do not provide marketing and sales support, such as those provided by Full Participation Firms, and make payments at a lower percentage rate than Full Participation Firms. These firms make cost reimbursement payments to AEIS of up to 0.10% on assets for these services, which support the distribution of the fund’s shares and 529 plans by making them available on one or more Ameriprise Financial Services platforms. In addition, certain mutual funds’ distributors pay a fee to AEIS of up to 0.10% for cost reimbursement services provided for the mutual fund shares purchased during a given period (sales-based payment). These mutual fund firms do not provide marketing and sales support such as those provided by Full Participation Firms to Ameriprise financial advisors, thus they do not have the same access to financial advisors as Full Participation Firms. Ameriprise Financial Services sells 529 plans from seven firms that do not make cost reimbursement payments to AEIS. Moreover, 529 plans offered by these firms are available for sale to in-state residents only. Those firms are: American Funds, Ascensus, Invesco, MFS, Orion, Union Bank & Trust and Virtus. In addition, Connecticut and Iowa restrict the sale of their state plans, offered by Hartford and Voya, respectively, to in-state residents only. Certain 529 plans may pay AEIS a fee of up to 1% of assets for NAV rollovers. The mutual fund’s distributor or affiliate may also make payments to AEIS for networking and/or omnibus support and other client services and account maintenance activities. AEIS will also receive sub-transfer agency fees with respect to investments you make in affiliated and non-affiliated mutual funds. These fees vary depending on the mutual fund family and on whether the mutual fund keeps a separate record for each account (i.e., networked accounts) or relies on AEIS’s recordkeeping (i.e., omnibus accounts). Compensation for sub-transfer agency services may be up to $12 per position annually for networked accounts, and up to $19 per position annually for omnibus accounts or, if paid on an asset basis, from 0.10% to 0.15% annually of any amounts you have invested in such mutual funds. In the case of certain no-load fund families for which AEIS has a direct relationship, the compensation for sub-accounting, administrative and distribution support services are bundled into one asset-based fee of up to 0.35% (which may include a service fee up to a 0.25%) annually of the value of such shares held in an Account. AEIS and its affiliates may have other relationships with firms whose mutual funds Ameriprise Financial Services offers. These relationships may include affiliates of firms acting as a sub-adviser to CMIA, CMIA acting as a sub- adviser to a third-party firm, or affiliates of a firm managing an investment portfolio within another Ameriprise Financial Services or affiliated product, such as a RiverSource variable annuity. Firms may use CMIA to manage an underlying investment option in products offered through the Mutual Fund Program. AEIS has a cost reimbursement agreement with BlackRock Advisors, LLC with respect to mutual fund positions held by Ameriprise Financial Services customers. BlackRock, Inc. owns more than 5% of the outstanding shares of Ameriprise Financial, Inc. stock. Our affiliate CMIA has a sub-transfer agent agreement with Vanguard Group, Inc. with respect to the distribution of its investment products. Vanguard Group, Inc. owns more than 5% of the outstanding shares of Ameriprise Financial, Inc. stock. Columbia Funds. AEIS and other affiliates of Ameriprise Financial Services provide certain administrative and transfer agent services to the Columbia Funds whose shares are owned by Ameriprise Financial Services clients. Ameriprise Financial Services and its affiliates generally receive more revenue from sales of affiliated mutual funds than from sales of other mutual funds. Employee compensation and operating goals at all levels of the company are tied to the company’s success. Certain employees may receive higher compensation and other benefits based, in part, on assets invested in affiliated mutual funds.. 19 American Funds. For both affiliated and unaffiliated mutual funds we offer, AEIS receives cost reimbursement payments from mutual fund firms of up to 0.20% of assets invested in those funds. With most mutual fund firms, these payments are paid on an ongoing basis and determined solely based on total assets invested in the funds of a particular fund family held in clients’ accounts. Rather than determining the amount of the payment solely on an asset- based basis, American Funds pays AEIS an annual negotiated platform fee based on a number of factors, including prior year assets, in accordance with their prospectus governing each mutual fund. This platform fee will not exceed 0.20% of assets and will also not exceed the limits set forth in the prospectus governing each fund. You can find the total dollar amounts we receive annually from American Funds, as of the previous calendar year, by visiting www.ameriprise.com/funds and clicking on “An Investor’s Guide to Purchasing Mutual Funds and 529 Plans at Ameriprise Financial.” American Funds are generally no longer available for new purchases in Ameriprise brokerage accounts (other than add-on purchases into existing positions, which may continue), and thus new investments of American Funds can generally only be executed in our Managed Account Programs. Ameriprise Preferred Line of Credit and Loan. AEIS receives compensation from Ameriprise Bank, FSB for its Ameriprise Preferred Line of Credit and Loan support services. Payments from other non-affiliated product companies Payments from actively managed ETF sponsors. For certain actively managed ETFs offered for purchase in Ameriprise Managed Accounts, AEIS receives from the ETF manager or distributor both (i) ongoing asset-based cost reimbursement payments of up to 0.18% of the assets invested in these products; and (ii) an annual flat program fee of up to $400,000 per manager or distributor. AEIS receives these payments to help promote and support the offer, sale and servicing of actively managed ETFs. These payments form a structure referred to as the Ameriprise Financial ETF Program (“ETF Program”) and compensate AEIS for the costs of maintaining the ETF Program. Firms participating in the ETF Program are granted full access to Ameriprise Financial Services and our financial advisors to provide direct financial advisor education or sales support to promote their products. Passively managed ETFs and actively managed ETFs that are classified as Eligible to Hold Investments or Ineligible Investments do not participate in the ETF Program, do not have access to financial advisors for education or sales support and do not make cost reimbursement payments, as summarized below. As a result, Ameriprise financial advisors may have a greater familiarity with and an indirect incentive to sell ETFs participating in the ETF Program. Ameriprise Financial Services addresses this incentive as described above in the “Mutual Fund and 529 Plan Marketing and Sales Support Payments” sub-section. Participate in ETF Program Access to Ameriprise financial advisors Make cost reimbursement payments Yes Yes Yes Actively managed ETFs offered for purchase No No No Actively managed ETFs that are classified as Eligible to Hold Investments or Ineligible Investments Passively managed ETFs No No No Payments from alternative investments sponsors. AEIS, in consideration for its cost reimbursement services, may receive ongoing investor service and support fee payments from products sponsors of hedge funds and managed futures available in Ameriprise Managed Accounts. Depending on the product, AEIS will receive payments up to 0.25% of the assets invested in these products. Payments from UIT sponsors. Certain UIT sponsors with which AEIS has agreements may pay AEIS cost reimbursement payments to help promote and support the offer, sale and servicing of UITs. These UIT sponsors are granted full access to Ameriprise Financial Services and our financial advisors to provide direct financial advisor education or sales support to promote their products. UIT sponsors without such agreements do not provide direct financial advisor education or sales support, thus they do not have the same access to financial advisors as full access firms. Such marketing and sales support may create a conflict of interest if Ameriprise Financial Services promotes, or Ameriprise financial advisors recommend, the UITs from UIT sponsors that have been granted full access versus UITs offered by nonparticipating firms. These conflicts may 20 arise from the marketing and sales support provided to our financial advisors by, as well as the payments AEIS receives from, firms that have entered into such agreements. AEIS will receive both a fixed dollar amount of cost reimbursement payments, based in part on projected UIT sales, as well as sales- based volume concessions. The total amount of these payments will not exceed 0.20% of total UIT sales. Payments from insurance companies. Cost reimbursement payments are received by Ameriprise Financial Services and/or its affiliate, AEIS, from affiliated and unaffiliated insurance companies. Ameriprise Financial Services sells annuity and insurance products to its clients manufactured by its affiliate, RiverSource, as well as from select unaffiliated insurance companies. RiverSource and potentially other unaffiliated insurance companies may be permitted to reimburse Ameriprise Financial Services or AEIS and these entities may subsequently reimburse Ameriprise financial advisors for client/ prospect educational events and financial advisor sales meetings, seminars and training events consistent with Ameriprise Financial Services and AEIS policies, as applicable. These companies may also provide support to the Ameriprise Financial Services internal sales desk, which in turn provides support to financial advisors. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource insurance and annuity products and the unaffiliated insurance companies who provide added educational support. Generally, unaffiliated insurance companies that issue annuities and life and disability income insurance policies do not provide direct client or financial advisor education or sales support, other than product training materials, product sales literature and addressing client service issues. However, in some instances direct financial advisor product education may occur. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource products. From unaffiliated long-term care insurance product manufacturers, AEIS receives payments up to 27.5% of the commissionable premium. AEIS receives varying payments from unaffiliated life, disability and other insurance product manufacturers. Payments from structured products sponsors. AEIS receives cost reimbursement for the sale of structured products. Depending on the structured product, AEIS will receive payments between 0.25% and 0.60% of the amount you invest, multiplied by the product’s term up to a maximum of 1.6%. For example, a structured note with a three-year term and a 0.40% payout could have an upfront payment of 1.2% (three years x 0.40%). Payments for financial advisor support. Separately, for structured products and alternative investment products AEIS will receive marketing and sales support payments in the form of an optional subscription for financial advisor support for a fixed annual fee of up to $250,000, which when combined with the payments described above for these types of investment products may exceed the ranges noted. Mutual Fund & ETF Recommended list (“Starting Point List"). Ameriprise financial advisors may make mutual fund recommendations based on a group of funds that appear on the Starting Point List. Financial advisors are not required to use the Starting Point List as their source for mutual fund and ETF recommendations, and mutual funds contained on the Starting Point List may not be equally available across both Managed Accounts and Ameriprise brokerage accounts. All ETFs and mutual funds offered by Full Participation Firms or Available for Sale Firms, as further discussed below, must meet Ameriprise Financial Services’ due diligence standards to be eligible for inclusion on the Starting Point List. In developing the Starting Point List, the IRG applies a quantitative and qualitative evaluation process that includes an analysis of a fund’s returns, risk and expenses; the tenure and quality of the investment team; the soundness of the process and consistent implementation; and the overarching health of the organization. Certain mutual funds and ETFs that would have otherwise been included on Starting Point were excluded due to their high investment minimums. Client suitability must be considered when trading mutual funds and ETFs, including breakpoint discount eligibility and NAV transfer ability. The funds on the Starting Point List are subject to change periodically, however changes to the Starting Point List should not be the sole reason to prompt trading. The Starting Point List is developed by the IRG based on eligibility criteria established by Ameriprise Financial Services. Approximately 2,100 mutual funds are eligible for inclusion on the Starting Point List. The primary universe of ETFs includes funds available for sale at Ameriprise. The universe of mutual funds includes only mutual funds sponsored or managed by Full Participation Firms in the Mutual Fund Program. If a suitable mutual fund recommendation for a particular asset class cannot be found within the Full Participation Firms’ offerings, the IRG will proceed to look for mutual fund options sponsored or managed by Available for Sale Firms. While the Starting Point List is developed by evaluating the performance characteristics of each fund’s Class A shares, the analysis is ultimately intended to apply at the mutual fund level. Mutual funds included on the Starting Point List may or may not offer an Advisory Share class or other share class that is available in our Managed Accounts Programs. As a result, 21 Managed Account clients may be unable to purchase a fund on the Starting Point List. Similarly, Ameriprise brokerage account clients may be unable to purchase a mutual fund on the Starting Point List if that fund does not offer a share class available in Ameriprise brokerage accounts. In addition, some mutual funds included on the Starting Point List may offer lower-cost share classes than the Advisory Share class or other share class available in Managed Account Programs. You should consider whether you may be eligible to purchase these lower-cost share classes outside the Programs. These eligibility criteria are designed by AFSI to primarily include, and therefore favor, mutual funds from Full Participation Firms. To be included in the Mutual Fund Program and be eligible for inclusion on the Starting Point List, each Full Participation Firm must meet a number of criteria that consider product breadth and strong-performing funds, financial strength of the firm and the ability to provide education and training to Ameriprise financial advisors, including marketing and sales support services relating to the funds they offer. Full Participation Firms have also agreed to pay our affiliate, AEIS, a portion of the revenue generated from the sale and/or management of fund shares as further described above. Available for Sale Firms make payments at a lower percentage rate than Full Participation Firms. They do not have the same wholesaling access to financial advisors as Full Participation Firms. As a result, Ameriprise financial advisors may have a greater familiarity with and an incentive to sell funds of Full Participation Firms. The payments made to AEIS by Full Participation Firms and Available for Sale Firms reimburse the costs of client beneficial services provided by Ameriprise Financial Services and AEIS to financial advisors and clients, including but not limited to distribution, marketing, administration and shareholder servicing support, due diligence, training and education, and other support related functions (e.g., cost reimbursement services) and increase the revenues and profitability of AEIS. The most significant of these payments are reimbursement for marketing support received from Full Participation Firms and other product companies. Full Participation Firms make cost reimbursement payments at a higher percentage rate than do Available for Sale Firms. This presents a conflict of interest as Full Participation Firms pay AEIS more revenue than Available for Sale Firms, and thus AEIS earns more revenue from the purchase of mutual funds offered by Full Participation Firms than from the purchase of mutual funds offered by Available for Sale Firms. Clients may choose to follow the recommendations provided by their Ameriprise financial advisor or they may select from any of the other funds offered through Ameriprise Financial Services regardless of whether that fund appears on the Starting Point List. More information on the Full Participation Firms that participate in the Program, specific arrangements we have with them, and conflicts of interest or incentives that exist for Ameriprise Financial Services to promote (and for Ameriprise financial advisors to recommend) one fund over another fund is provided on our website at ameriprise.com/funds and click "Purchasing Mutual Funds Through Ameriprise." Revenue sources for Ameriprise Financial Services, LLC Financial planning and advisory service fees. These are fees you pay for financial planning and fee-based investment advisory account services, respectively. Ameriprise brokerage account sales charges. Sales charges, commissions and/or selling concessions are paid when you buy or sell equities or fixed income products including corporate bonds and municipal securities, mutual funds, ETFs, 529 plans, closed- end funds, preferred securities, UITs, non-traded REITs, non-traded BDCs, non-traded closed-end funds, hedge fund offerings, exchange funds, private equity offerings, managed futures funds, real estate private placement offerings and structured products. In addition, you may pay a markup or markdown in bond transactions executed in a principal capacity with AEIS. These charges vary by product and product type. For example, with respect to mutual funds, the sales charge for a stock mutual fund is typically greater than that for a bond mutual fund. For other product types such as non-traded REITs, the sales charge you pay may also include a portion of the distribution, organization and offering fees and expenses. See the Working in Your Best Interest – Regulation Best Interest Disclosure for more information about costs, compensation and potential conflicts of interest relating to brokerage products and services. Periodic Fees. Periodic fees include IRA custodial fees, brokerage fees (i.e., account maintenance and order handling fees), and a portion of the fees associated with certain banking products and services (i.e., personal trust services). Sales charges, trading commissions, markups, markdowns and financial planning and advisory services fees are not eligible for reimbursement or offered at a discount. Periodic expenses. Periodic expenses are paid from product assets, such as 12b-1 shareholder servicing fees paid from mutual fund assets (including 12b-1 fees paid on certain funds that serve as underlying investment options for 529 plan assets) and distribution fees paid from Ameriprise Certificate Company assets. 12b-1 shareholder servicing fees assessed in Ameriprise brokerage accounts may be used to pay for marketing, distribution and shareholder service expenses. Any 12b-1 shareholder servicing fees received for the share class utilized in any Managed Accounts will be rebated to clients. 22 Ameriprise Preferred Line of Credit and Loan. Ameriprise Financial Services receives compensation from Ameriprise Bank of 0.25% on an annualized basis of the amount of the credit line or loan outstanding balance. This amount is shared with your Ameriprise financial advisor based on how your advisor is affiliated with us and on the payout rate for which your financial advisor qualifies. These affiliations and compensation structures are described in the “Financial Advisors Compensation & Benefits” section of this Brochure. Ameriprise Bank Savings Account and CDs. Ameriprise Financial Services receives compensation from Ameriprise Bank of 0.05% on an annualized basis of the amount of the average monthly balance. This amount is shared with your Ameriprise financial advisor based on how your advisor is affiliated with us and on the payout rate for which your financial advisor qualifies. These affiliations and compensation structures are described in the “Financial Advisors Compensation & Benefits” section of this Brochure. Payments for referrals to structured settlements annuity brokers. Ameriprise Financial Services receives a fee, shared with financial advisors, for referrals to non- affiliated structured settlement professionals for both client and non-client referrals. The amount and basis for the referral fee varies by relationship multiplied by the notional sales amount of the product. Underwriters’ compensation. Ameriprise Financial Services receives a fee comprised of a selling concession, management fee, underwriting fee, and in some cases, a structuring fee for the sale of initial public offerings (“IPOs”) such as closed-end funds and preferred securities. The specific amounts vary by individual offering, and are disclosed in the prospectus of each offering. Distribution Access Fees. Ameriprise Financial Services directs securities purchase and sale transactions through our affiliate, AEIS, on a fully disclosed basis. In exchange, Ameriprise Financial Services receives reimbursements from AEIS for our non- distribution related expenses. Financial interest in products Ameriprise Financial Services has a financial interest in the sales of proprietary products that are manufactured by its affiliates. Ameriprise Financial Services and its affiliates receive more revenue from the sale of some financial products and services, particularly those products and services sold under the Ameriprise, Columbia Threadneedle Investments and RiverSource brands, than for the sale of other products and services. Generally, Ameriprise Financial Services receives more revenue for securities or products sold in a fee- based account than for those sold with only a sales charge or commission. Higher revenue generally results in greater profitability for Ameriprise Financial Services. Employee compensation (including management and field leader compensation) and operating goals at all levels of the company are tied to the company’s success. Management, sales leaders and other employees generally spend more of their time and resources promoting Ameriprise, Columbia Threadneedle Investments and RiverSource branded products and services. Any 12b-1 fees received by Ameriprise Financial Services for mutual funds held in any Managed Accounts will be rebated to clients, and financial advisors do not receive compensation from 12b-1 fees assessed on mutual funds held in Managed Accounts. For brokerage accounts, both Ameriprise Financial Services and individual financial advisors are compensated when clients buy mutual funds through Ameriprise Financial Services. Generally, financial advisors receive a portion of the sales charge and 12b-1 fees paid to the firm in connection with mutual fund purchases for as long as clients own the mutual fund shares. Sales charges and 12b-1 fees vary from mutual fund to mutual fund and from share class to share class. Ameriprise Financial Services and the financial advisor receive more compensation on fund or share classes that pay higher fees. Ameriprise Financial Services and the financial advisor generally receive less compensation when the sales charge and/or 12b-1 fee is reduced, waived completely, or where there is no sales charge or 12b-1 fee. Therefore, for brokerage accounts there is an incentive for our financial advisors to sell a fund that pays a load or a fund that pays a 12b-1 fee over funds that do not. Ameriprise Financial Services and Ameriprise financial advisors are paid in different ways for helping you choose mutual funds, depending on the type of fund, amount invested, and share class purchased. Financial advisors receive compensation only from 12b-1 fees for mutual funds held in brokerage accounts. Ameriprise Financial Services and financial advisors receive more compensation for sales of certain types of products, such as insurance, rather than others. 23 Economic benefits of affiliates’ products and services As with all financial services firms, a portion of our revenue and compensation can generate a profit for the firm. The revenue and compensation we receive helps us cover our expenses in providing and servicing these products and services. Employee and financial advisor compensation and operating goals at all levels of Ameriprise Financial, Inc. are tied to the success of its businesses. As a result, certain incentives and conflicts of interest may exist for Ameriprise Financial Services, our affiliates and our financial advisors if you purchase certain products or services recommended by your financial advisor. Generally, among other things, Ameriprise Financial Services and our affiliates will receive: • More revenue, in aggregate, from the purchase of products sponsored or managed by Ameriprise, Columbia Management and RiverSource (“proprietary products”) than from the purchase of products sponsored or managed by firms that aren’t affiliated with Ameriprise Financial, Inc. (“nonproprietary products”). Ameriprise Financial Services actively promotes the products of our affiliates through advertising, direct mail, and product support and training events. • More revenue from the purchase of products and services than from Wrap Fees. • More revenue as the size of any margin account or Ameriprise Preferred Line of Credit balance increases. • More revenue when you purchase certain types of products, such as insurance and annuity products and direct investments. • More revenue from products and services that generate ongoing revenue streams, such as mutual funds that pay ongoing 12b-1 fees, an investment advisory account service, and insurance and annuity products with mortality and expense charges. • More revenue when you purchase shares of mutual funds or 529 plans from Full Participation Firms than from firms with other distribution support relationships, as described in the “Cost Reimbursement Services and Third-Party Payments” section of this Brochure. • More revenue when you purchase investment products for which we receive cost reimbursement payments or have similar financial arrangements, as described in the “Cost Reimbursement Services and Third-Party Payments” and “Revenue Sources for Ameriprise Financial Services, LLC” sections of this Brochure. • Less revenue when a sales charge or commission is reduced or waived completely, or where there is no sales charge. • More revenue when you move assets (including retirement plan accounts) from another institution to Ameriprise Financial Services or RiverSource or into a product managed by Columbia Management or another affiliate. Financial advisors are required to take training on complex products developed by Ameriprise Financial Services and its affiliates and non-affiliated product manufacturers, prior to soliciting, certain insurance and annuity products and a targeted subset of nonproprietary products. Additional general product training is available and specific product training is required for a number of complex products, including Columbia Threadneedle Investments and RiverSource branded products. It is likely that a product recommendation from your financial advisor will be drawn from the universe of products on which they were trained. Ameriprise Financial Services may enter into strategic alliances with companies that offer products or services that Ameriprise Financial Services and its financial advisors do not sell. As part of those alliances, Ameriprise financial advisors may receive gifts or non-cash compensation from the other companies, which are subject to SEC and FINRA regulations as well as Ameriprise Financial Services’ internal compliance policies. Some, but not all, of the financial planning software tools available for use by your financial advisor were developed by Ameriprise Financial Services or by unaffiliated third parties and may make it more convenient for your financial advisor to select proprietary products. Most Ameriprise financial advisors are also appointed agents of RiverSource Life and, in New York only, RiverSource of New York, affiliates of Ameriprise Financial Services. Ameriprise Financial Services grants RiverSource limited access to Ameriprise financial advisors and provides RiverSource with limited information related to Ameriprise clients to promote sales of RiverSource products and to assist financial advisors in understanding the features and benefits of those products. Ameriprise Financial Services does not grant this access to other non-affiliated companies offering similar products, thus they do not have the same access to financial advisors as RiverSource. 24 Additionally, it is possible that Ameriprise Bank would send an order on behalf of a trust account to AEIS and at the same time AEIS would execute the opposite order for a brokerage client. Investments may be made for Ameriprise Bank’s trust accounts in which Ameriprise Financial Services or its related persons have a position or interest. Although Ameriprise Financial Services and its related persons may own securities suitable for or held by clients, in no case will holdings of Ameriprise Financial, Inc., its subsidiaries or their employees or directors be directly sold to or purchased from Ameriprise Bank’s trust accounts. AEIS, an affiliate of Ameriprise Financial Services, may buy or sell for its own account securities that Ameriprise Financial Services may recommend for the Ameriprise Bank’s trust accounts. Ameriprise Financial Services does not anticipate that conflicts of interest will arise because we have adopted policies and procedures prohibiting Ameriprise Financial Services and our related persons from engaging in trading activity that creates a conflict of interest with our clients, as discussed in the “Code of Ethics, Participation or Interest in Transactions and Personal Trading” section. Financial Advisors Compensation & Benefits The compensation programs for our financial advisors may vary based on, among other factors, the financial advisor’s industry experience, tenure with Ameriprise Financial Services, the type of practice structure (solo or team), and whether the financial advisor was formerly associated with a firm acquired by Ameriprise Financial, Inc. An Ameriprise financial advisor is assigned to every investment advisory service. Ameriprise financial advisors have a wide range of business and educational backgrounds. They are required to have appropriate licenses and registrations to transact business, including Financial Industry Regulatory Authority (“FINRA”) registration, required state securities and insurance licenses and carrier appointments and, where required, a state investment adviser representative registration. Many financial advisors hold advanced academic degrees and/or professional designations, including the Certified Financial Planner™ (CFP®) designation. In addition, ongoing training is available to financial advisors. For additional important information about an advisor check FINRA BrokerCheck at www.finra.org/brokercheck or call 800.289.9999. Your financial advisor earns a living by providing you with financial advice and product recommendations to suit your goals. To understand how your financial advisor gets paid, you should first know that there are four ways Ameriprise financial advisors can be affiliated with us. • Independent contractor franchisees. These financial advisors are not employed by Ameriprise Financial Services and they do not receive a salary from us. • Employee financial advisors. These financial advisors are employed by Ameriprise Financial Services. • Associate financial advisors. These financial advisors are employed by or contract with the independent contractor franchisees and they do not receive a salary or other compensation from Ameriprise Financial Services. • Financial institution employee financial advisors. These financial advisors are employed by the financial institution where they provide services and are compensated by the financial institution from the portion of fees and commissions it receives from Ameriprise Financial Services. The financial institution serves as paying agent for such compensation on our behalf in accordance with applicable law. Financial institution employee financial advisors’ compensation is based on their employment agreement with the financial institution. All Ameriprise financial advisors are licensed registered representatives. Depending on the affiliation, our financial advisors are compensated differently. Financial advisors may choose to change how they are affiliated with Ameriprise Financial Services over time. Salary and Bonus. In addition to the fees described below, employee financial advisors may receive a salary or wage from Ameriprise Financial Services. Associate financial advisors may receive either a salary or a flat fee from the independent contractor franchisee for whom they work, at the discretion of the employing or contracting independent contractor franchisee. Financial advisors may also have the potential to receive bonus compensation. At the discretion of the employing or contracting independent contractor franchisee, the associate financial advisor may receive a bonus. The Service Fee is not shared with your financial advisor, however, your financial advisor earns compensation when you implement recommendations relating to the Service within your Managed Account, Ameriprise brokerage account, or purchase other products available from Ameriprise Financial Services and its affiliates. 25 Advisory Fees and Compensation. Both independent contractor franchisee financial advisors and employee financial advisors receive a portion of the Advisory Fee and, if applicable, a portion of the AFPS Fee as compensation for your participation in a Managed Account Program. Independent contractor franchisee financial advisors, however, receive a higher portion, or payout rate. The actual portion of any Managed Account Advisory Fee or commission-based fees paid to your financial advisor depends on the payout rate for which your financial advisor qualifies and the amount of fees you pay. • Independent contractor franchisees generally receive 72% to 91%, and employee financial advisors generally receive 0% to 46% of the advisory service fees and product commissions we receive (the “advisor payout rate”). • In addition, the financial advisor may qualify for a bonus which could increase the effective advisor payout rate up to 91% for independent contractor franchisees and 57% for employee financial advisors, respectively. • Financial institution employee financial advisors generally receive an advisor payout rate of 0% to 91% based on their employment agreement with the financial institution. • If you are a client of the Ameriprise Personal Wealth Group, your employee financial advisor does not receive a portion of the fees but may receive compensation in the form of a bonus based in part on revenue generated through your fees. • In general, fees generated by an associate financial advisor are paid to the employing or contracting independent contractor franchisee. At the discretion of the employing or contracting independent contractor franchisee, the associate financial advisor may receive financial advisory or referral fees or a bonus. • Importantly, financial advisor compensation does not vary depending upon the investment(s) recommended to you within a Managed Account. However, the amount of this compensation may be more or less than what your financial advisor would receive if you paid separately for investment advice, brokerage and other transaction-based services. Therefore, your financial advisor may have a financial incentive to recommend a Program over a transaction-based brokerage account. Ameriprise Financial Services seeks to address this conflict of interest through a combination of disclosures and through our policies, procedures and supervision, related to the review and determination that a Managed Account is appropriate for you based on your financial and risk profile information and investment objectives ("Client Information") in accordance with all applicable regulatory requirements. Other Compensation Available to Financial Advisors The compensation programs for our financial advisors may vary based on, among other factors, the financial advisor’s industry experience, tenure with Ameriprise Financial Services, the type of practice structure (solo or team), and whether the financial advisor was formerly associated with a firm acquired by Ameriprise Financial, Inc. Ameriprise Financial Services offers a vast range of investment solutions to clients. Some products and services may be offered only by certain Ameriprise financial advisors. Discuss with your financial advisor the products he or she offers and the compensation your financial advisor receives, as some investment product companies and issuers, including RiverSource, may pay higher compensation than others. Generally, among other things, your financial advisor may earn: • More depending on how your financial advisor is affiliated with Ameriprise Financial Services, as described above • More on the sale of certain fixed life and disability insurance products because of special compensation programs that provide increasing levels of compensation the more a financial advisor sells of these products from each individual insurance company. • More on the purchase of annuity and insurance products and direct investments, because they are more complex than other products and take more time to service. • More revenue from products and services that generate ongoing revenue streams, such as mutual funds that pay ongoing 12b-1 fees, an investment advisory account service, and insurance and annuity products with mortality and expense charges. 26 • More from certain sales incentive programs to increase overall assets under management. • Less on individual purchases within a transaction- based brokerage account because of the higher transaction charges your financial advisor pays on these accounts compared to a fee-based investment advisory account. • Less when a sales charge or commission is reduced or waived completely, or where there is no sales charge. • Typically, less when you exchange an existing annuity contract, mutual fund or insurance policy for certain like or similar products from the same company, unless you have held the existing product for a certain period of time. • More revenue if you purchase securities on margin that you could not otherwise purchase in a cash account. • A higher payout rate based on the level of product sales, on the number of financial plans sold, and on higher face value and/or death benefit amount for certain insurance products. • More when you move accounts (including retirement plan accounts) from another institution to Ameriprise Financial Services, CMIA or RiverSource. • If your financial advisor is a shareholder of Ameriprise Financial through our deferred compensation program, more compensation the more profitable the firm is. • Compensation for servicing trust accounts held with Ameriprise Bank. • Compensation for performing certain activities associated with your mortgage if that loan is purchased and serviced by Ameriprise Bank. • Compensation for providing services related to your Ameriprise Preferred Line of Credit based on an annualized fixed percentage of the client’s average daily outstanding balance. • Compensation for your Ameriprise Bank Savings Account and CD balances based on an annualized fixed percentage of the client’s average monthly balance. • Compensation for marketing that leads to you opening a co-branded credit card account provided you activate the card and meet the initial spend requirements. • Compensation for marketing that leads to your opening of an Ameriprise Bank Checking Account provided you meet the initial funding and other balance duration requirements. • Compensation for the sale or renewal of Ameriprise Certificates. Financial Advisors Compensation - Insurance and Annuity Products Our financial advisors primarily offer life, and disability insurance and annuity products from RiverSource and certain pre- approved, but unaffiliated, insurance companies. However, in some situations where the client’s needs may be met more effectively by another company’s product, and RiverSource and other pre-approved providers do not offer such a product, Ameriprise financial advisors may offer insurance products issued by unaffiliated insurance companies. If an unaffiliated insurance product is offered, the financial advisor is an appointed agent of the insurer and receives, directly or indirectly, compensation from the unaffiliated insurer for the sale and service of that product. The compensation for these nonproprietary products and RiverSource products is separate from, and in addition to, any fee you pay for investment advisory services and may vary depending on the type and size of the life insurance or annuity product that you purchase, the insurer that issues the product, and other factors. This compensation typically will increase as the size of the insurance policy or annuity contract increases, or the amount of the payments that you make on the life insurance or annuity product increases. Generally speaking, the compensation that the financial advisor will receive is calculated by a formula. Compensation may also increase as the financial advisor sells increasing amounts of life and disability income insurance products issued by that insurer. In instances where a customer already owns a financial product sold by Ameriprise Financial Services, the amount of a financial advisor’s compensation may vary in connection with the sale of an additional or replacement product, due to formulas relating to the cancellation of a product that is already owned. As a result, the financial advisor in such a transaction may have an incentive to recommend the purchase of additional or replacement insurance or annuity products or, conversely, an incentive to recommend that you not purchase additional or replacement insurance or annuity products, depending on the relevant compensation formula. 27 Financial Advisors Compensation - Credit Products & Insurance Referral Your financial advisor receives compensation for the marketing that leads to your opening of a co-branded credit card account provided you activate the card and meet initial spend requirements. Ameriprise financial advisors will earn compensation for providing services related to your Ameriprise Preferred Line of Credit based on an annualized fixed percentage of the client’s average daily outstanding balance. Your financial advisor will receive compensation for performing certain activities associated with your mortgage if that loan is purchased and serviced by Ameriprise Bank. Your financial advisor receives referral fees when you purchase and maintain Ameriprise Auto and Home insurance products under a long-term distribution agreement between Ameriprise Financial Services, American Family Insurance Group and Ameriprise Auto & Home. Ameriprise Auto & Home is not affiliated with Ameriprise Financial Services and is owned by the American Family Insurance Group. However, Ameriprise Auto & Home Insurance and the associated logo are being used by American Family Insurance Group under a temporary license from Ameriprise Financial. If Ameriprise Bank accepts a trust based upon a referral from your financial advisor, Ameriprise Financial Services will receive a referral fee from the Bank. A portion of this referral fee is shared with your financial advisor. The referral fee is paid by the Bank from the fees earned for its services and is not an additional cost to the trust account. Your financial advisor also receives a referral fee for referrals to non-affiliated structured settlement professionals for both client and non-client referrals. Financial Advisors Compensation - Incentives, training and education. Product companies with which we have agreements work with Ameriprise Financial Services and our financial advisors to promote their products. They may pay for training and education events or due diligence meetings; and may reimburse expenses for prospecting events such as seminars for employees, financial advisors, clients and prospective clients. For employees and financial advisors, these events may be held at off-site locations, and the travel, meals and accommodations may be paid for by the product company. Additionally, product companies may occasionally provide business or recreational entertainment or gifts of nominal value to employees and financial advisors. Ameriprise Financial Services or sales leaders may, from time to time, offer contests or incentive programs to individual financial advisors or groups of financial advisors in particular areas. These contests and programs are limited to such targets as new client acquisition, financial plan count, net flows, total assets under management and financial advisor recruiting. Single product or product categories are not eligible for sales contests or incentive programs with the exception of fixed life and disability insurance. These programs and incentives and the receipt of other cash/noncash compensation could affect your financial advisor’s recommendations of products and/or services to you. These programs and incentives and other cash and/or noncash compensation are subject to SEC and FINRA regulations as well as Ameriprise Financial Services’ internal compliance policies. Financial Advisors Compensation – Recruitment Ameriprise Financial Services from time to time recruits financial advisors from other firms to join Ameriprise Financial Services. In connection with these recruiting efforts, Ameriprise Financial Services may enter into arrangements with financial advisors for the payment of compensation and/or loans based upon the value of eligible assets or accumulated production of the recruited financial advisor at a pre- determined measurement date. The funds may be payable immediately, over time, as a bonus, or as a loan. These arrangements may have been structured to include a provision requiring that payment of transition compensation and/or loans would be dependent upon the advisor meeting certain agreed-upon production and/or asset level benchmarks. The financial incentives associated with these transition arrangements could influence the type and amount of product and/or service recommended by your financial advisor. Ameriprise Financial Services manages this conflict of interest by supervising the suitability of recommendations made by its financial advisors in accordance with all applicable regulatory requirements. Please review your financial advisor’s Form ADV brochure supplement or ask your advisor if you have questions about whether these transition arrangements apply to them. From time to time, Ameriprise Financial Services also provides compensation to financial advisors in connection with the sale of all or a portion of their client base to an Ameriprise financial advisor. Some of this compensation may be dependent on a certain percentage of the client base remaining as clients of Ameriprise Financial Services for a certain period of time. It is also determined based on valuations of the financial advisor’s practice, or book of business. 28 The practice valuation formula results in higher compensation for revenues received from Managed Accounts versus Ameriprise brokerage accounts. As a result, your financial advisor has an incentive to recommend the opening of new Managed Accounts or the investment of additional assets into existing Managed Accounts or, conversely, an incentive to recommend that you not open an Ameriprise brokerage account or invest additional assets into a brokerage account. In addition, if your financial advisor is selling all or a portion of their practice to another Ameriprise financial advisor, this program could incent your financial advisor to recommend you remain a client of the acquiring financial advisor and/or Ameriprise Financial Services. Ameriprise Financial, Inc. equity programs. We encourage our financial advisors to take an ownership stake in our future by holding stock in our parent company, Ameriprise Financial, Inc. (NYSE: AMP). To make this possible for financial advisors, we have created equity compensation programs for them. Employee financial advisors and independent contractor franchisees may be eligible to receive an annual stock bonus. In addition, independent contractor franchisees may be eligible to defer a certain percentage of their compensation each year. They may choose to invest all or portion of this deferral into a notional account that tracks the performance of Ameriprise Financial, Inc. stock. Financial advisors who are independent contractor franchisees may build equity in their practices and may receive payments if they sell all or a part of their practices to other Ameriprise financial advisors. Loan programs. Clients may have access to information about lending products and services through marketing and/or lending relationships Ameriprise Bank has with third-party financial institutions. Financial advisors do not earn compensation related to the origination or referral of lending products (e.g., mortgages) offered and originated by third-party providers. Ameriprise Bank partners with Rocket Mortgage, LLC. (NMLS#3030) that offers mortgage lending products and services. Ameriprise Financial Services and Ameriprise financial advisors do not accept any mortgage loan applications or offer or negotiate terms of any such loans. Financial advisors do not earn compensation related to the origination or referral of mortgage lending products offered and originated by such third-party providers. Ameriprise Bank may purchase and service some loans originated by Rocket Mortgage, LLC. Ameriprise Financial Services and Ameriprise financial advisors may receive compensation for assisting clients with mortgages serviced by Ameriprise Bank. Ameriprise Financial, Inc. is not affiliated with Rocket Mortgage, LLC. Ameriprise Bank does not guarantee products or services offered by Rocket Mortgage, LLC. Ameriprise Bank has partnered with Elan Financial Services in offering Ameriprise co-branded credit cards. Your financial advisor receives compensation for marketing efforts that leads to your opening of a co-branded credit card account provided you activate the card and make sufficient purchases. Ameriprise Bank has partnered with Goldman Sachs to make available the Ameriprise Preferred Line of Credit and Loan. Ameriprise financial advisors will earn compensation for providing services related to your Ameriprise Preferred Line of Credit and Loan based on an annualized fixed percentage of the client’s average daily outstanding balance. Apart from margin lending, offered by AEIS, neither your Ameriprise financial advisor nor Ameriprise Financial Services may arrange, promote, suggest or knowingly permit you to use line or loan proceeds to purchase securities or other investment products. Advisor-to-advisor training programs. Ameriprise Financial Services or its affiliates may also pay its financial advisors for training other financial advisors on specific products and services that we offer. A portion of this payment may be based on incremental sales of these products and services sold by the financial advisor receiving the training. Shared compensation. Financial advisors may also choose to work together as a team to share fees and commissions generated from products and services you purchase. The cost of the product or service you purchase is not affected by the fact that your financial advisor is a member of a team or by the fact that the fee or commission may be split. Your financial advisor may be allowed to share a portion of the Wrap Fee he or she receives with one or more other Ameriprise financial advisor(s), including financial advisors who have not completed the Ameriprise Financial Services-required training to sell the investment advisory service, franchise consultants or registered principals, as described below. In cases where two or more financial advisors are assisting you, both financial advisors may share in the Wrap Fee. Your servicing financial advisor will present the Managed Account, set the Wrap Fee, and oversee the analysis and advice prepared for you. Your servicing advisor may or may not be the financial advisor authorized to use discretion to purchase and sell securities in your account, e.g., your SPS Discretionary Advisor. In the instance that your servicing advisor is not authorized to use discretion, the financial advisor authorized to use discretion will oversee the analysis and advice prepared for you. Only the financial advisor authorized to use discretion will purchase and sell securities in our Account. 29 Your servicing advisor may or may not be the financial advisor who has completed the required training. A financial advisor who has not completed the required training may refer a client to a financial advisor who has completed the required training for the service or product. The financial advisor who has completed the required training may pay a fee to the financial advisor who has not completed the required training for that referral. The financial advisor who has not completed the required training may provide investment advisory services for services and products that do not require training, however, only the financial advisor who has completed the required training required for a particular service or product will provide the analysis and advice prepared for you with respect to a service or product that requires the training. The financial advisor who has not completed the required training may receive a share of the commission from any services or products sold to you by your financial advisor who has completed the required training. Your financial advisor may work with a franchise consultant. In those situations, the franchise consultant, who is registered with Ameriprise Financial Services, may receive compensation based on services and products that you purchase, and for the training and leadership of your financial advisor. The cost of the product or service you purchase is not affected. Your financial advisor may employ staff or work with other Ameriprise Financial Services staff to assist with creating your financial planning recommendations. This may include leveraging services in geographic locations outside of your financial advisor’s location, including international locations. Services provided may include entering data into financial planning software, providing initial calculation and assistance in creating solutions. Your financial advisor will provide final recommendations to you. For these services your financial advisor may pay a fee or salary to employed staff. Financial advisors and field leaders may share compensation with their registered support assistants or recommend bonuses for their non-registered support staff. Employee financial advisors and selling leaders may receive continuing commissions and fees for the sale of certain products and services for up to five years after leaving the securities industry. Ameriprise offers a Business Development Account (BDA) Program. Eligible employee financial advisors may create a voluntary BDA in a predetermined amount and use this account for business-related expenses above and beyond what the company provides. Service relationship without a financial advisor. In the event that you request Ameriprise Financial Services to remove your current financial advisor from your Service relationship for Premier Retirement Income or your financial advisor resigns from Ameriprise Financial Services or your Service relationship or is terminated, your Service relationship will no longer have an assigned financial advisor. Ameriprise Financial Services may reassign your Service relationship to another financial advisor and notify you of the change. Management compensation and bonus programs. Employee compensation and operating goals at all levels of the company are tied to the company’s success. All employees, directly or indirectly, may receive higher compensation and other benefits when the investment products of certain providers, particularly affiliates, are purchased. Management, sales leaders and other employees spend more of their time and resources promoting Ameriprise, Columbia Threadneedle Investments, and RiverSource branded products and services. Field leaders receive a salary and a bonus and are responsible for an operating budget for expenses. Bonus programs for Ameriprise Financial Services field leaders are designed to include an amount based on the aggregate sales of all products sold by financial advisors, including proprietary products, in the regions of the country those leaders are responsible for overseeing. The bonus incentive and expense programs present a potential conflict because they are based in part on sales of these products. Code of Ethics, Participation or Interest in Transactions and Personal Trading Code of ethics As part of an overall internal compliance program, Ameriprise Financial Services has adopted policies and procedures imposing certain conditions and restrictions on transactions for the account of Ameriprise Financial Services and the accounts 30 of our employees. Such policies and procedures are designed to prevent, among other things, any improper or abusive conduct when potential conflicts of interest may exist with respect to a customer or client. In addition, from time to time, restrictions are imposed to address the potential for self-dealing and conflict of interest which may arise in connection with the business of Ameriprise Financial Services as a broker- dealer. Ameriprise Financial Services has adopted various procedures intended to guard against insider trading. Participation or interest in client transactions From time to time Ameriprise Financial Services and/or its affiliates and related persons may invest in the same or related securities that Ameriprise Financial Services and/or its affiliates recommend to clients. Such transactions may occur at or about the same time that such securities are bought or sold for client accounts. Ameriprise Financial Services has adopted policies and procedures imposing certain conditions and restrictions on transactions in these securities, such as trading blackout periods and preclearance requirements. See the “Financial interest in products” subsection in the “Revenue Sources for Ameriprise Financial Services, LLC” section in this Disclosure Brochure for more information about our financial interest in the sale of certain products and services. Personal trading rules and procedures Ameriprise Financial Services has adopted personal trading rules and procedures within the Ameriprise Financial Code of Ethics and Personal Trading Policy. These rules are designed to list standards of business conduct and to mitigate potential conflicts of interest for all persons of Ameriprise Financial Services when they engage in personal securities transactions The standards of business conduct include compliance with applicable laws and regulations and with policies and procedures such as those contained in the Ameriprise Global Code of Conduct. Under the personal trading rules, persons are required to report their personal securities holdings and transactions, including transactions in certain mutual funds; must pre-clear certain investments; are restricted with respect to the timing of certain investments; and are prohibited from making certain investments. In addition, the Personal Trading Policy requires (i) Ameriprise employee financial advisors and their employees, (ii) its independent contractor franchisee financial advisors and their employees, and (iii) its affiliated investment advisers to conduct most personal trades through one of three designated broker- dealers unless an exception has been granted, and report any changes in their selected broker-dealer. Insider trading policy Ameriprise Financial Services and its related persons may, from time to time, come into possession of material nonpublic information that, if disclosed, might affect an investor’s decision to buy, sell or hold a security. Under applicable law, Ameriprise Financial Services and its related persons are prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether such other person is a client. Accordingly, should Ameriprise Financial Services or its related persons come into possession of material nonpublic information with respect to any company, they may be prohibited from communicating such information to, or using such information for the benefit of, their respective clients, and have no obligation or responsibility to disclose such information to, nor responsibility to use such information for the benefit of, their clients when following policies and procedures designed to comply with law. Ameriprise Financial Services and its affiliates have adopted an “Insider Trading Policy” in accordance with Section 204A of the Advisers Act that establishes procedures intended to prevent the misuse of material nonpublic information by Ameriprise Financial Services and its associated persons. Any client or prospective client may request a copy of the Ameriprise Financial Code of Ethics and Personal Trading Policy from his/her financial advisor or by contacting us at 800.290.6663. Brokerage Practices Ameriprise Financial Services does not receive research or other products or services other than execution from any unaffiliated broker-dealer or other third party for client securities transactions. Ameriprise Financial Services receives and distributes research authored by its affiliate AEIS; however, this research is not provided for client securities transactions or for any other compensation. Nor do we or our affiliates receive client referrals from broker-dealers or third parties that are considered in selecting or recommending broker-dealers. 31 Retail brokerage services are made available through Ameriprise Financial Services. Ameriprise Financial Services and AEIS have an agreement in which Ameriprise Financial Services introduces customer accounts to AEIS on a fully disclosed basis. AEIS serves as Ameriprise Financial Services’ clearing agent in providing, clearing, custody and settlement services for transactions that are executed for customers of Ameriprise Financial Services. Ameriprise Financial Services approves and opens accounts and accepts securities order instructions with respect to the accounts. In exchange for a fee paid by Ameriprise Financial Services, AEIS provides, record keeping, custody, and all clearing functions for accounts introduced by Ameriprise Financial Services. Under certain circumstances, when AEIS deems a transaction to be in the best interests of you and other clients, and to the extent permitted by applicable law and regulation, AEIS is permitted to aggregate multiple client orders to obtain what AEIS believes will be the most favorable price and/or lower execution costs at the time of execution. Review of Accounts Certain supervisory functions are performed by Ameriprise Financial Services corporate office personnel. Corporate registered principals review a sampling of Service relationships, including Recommendation Reports. When appropriate, our corporate registered principals may also decide to call you directly to discuss your understanding of the Service, including the fees and expenses you will be paying. Our Compliance department also conducts routine surveillance of financial advisor activities. An important part of a Service relationship involves providing you with the opportunity to engage in periodic reviews with your financial advisor or a designated member of the team servicing your Service. In these reviews, you and your financial advisor should discuss any changes to your individual circumstances, financial situations, investment objectives and/or risk tolerance. Our supervision and surveillance do not substitute for your continued review and monitoring of your Service or any related Managed Account(s). You should review your account statements, trade confirmations, and other information we send to you. If you have any questions or concerns, please discuss them with your financial advisor. Client Referrals and Other Compensation Referral arrangements and other economic benefits Ameriprise Financial Services maintains investment advisory referral arrangements, the terms of which are disclosed to the client, with individual professionals, professional firms, and select corporate, institutional or membership organizations (“Promoters”). For each such arrangement, Ameriprise Financial Services pays the Promoter for referral of their clients or members to Ameriprise Financial Services for its financial advisory services. The manner and amount of compensation to be paid in connection with these agreements is subject to negotiation between Ameriprise Financial Services and the applicable Promoter. Prospective clients are provided with applicable disclosures, including whether the Promoter is a client, the material terms of compensation (if any) and the material conflicts of interest (if any), that results from the Promoter's relationship with Ameriprise Financial Services. The most common compensation arrangements include a flat fee at the time of the referral, a recurring flat fee, or a sharing of a portion of any total Asset-based Fees. You will not be charged an additional fee as a result of any referral arrangements. Compensation may include a one-time payment or ongoing payments for the duration of the investment advisory relationship. Ameriprise Financial Services may form networking arrangements with financial institutions such as banks, credit unions, credit union service organizations, Farm Credit Services and trust service providers (“Third Party Financial Institutions”) to allow its financial advisors to offer investment advisory services, financial planning services and certain other non-deposit investment and insurance products and services, (described elsewhere in this Brochure), to retail customers or members of the Third Party Financial Institutions. Under the terms of these networking arrangements, financial advisors may not be able to offer to retail customers or members of the Third Party Financial Institutions certain products that are otherwise available through Ameriprise Financial Services or its affiliates. Also because of these alliances or networking arrangements, Third-Party Financial Institutions may receive, in the form of a networking payment, a portion of Asset-based Fees and securities and insurance commissions paid to financial advisors for sales to retail customers or members of the Third Party Financial Institutions. 32 Ameriprise Financial Services has entered in partnership with Renaissance Charitable Foundation Inc. (“RCF”) for the referral of clients or prospects that have indicated an interest in establishing and maintaining a donor advised fund made available through RCF. No referral fee is paid by RCF to Ameriprise Financial Services or financial advisors however donor advised funds established by RCF because of the referral generally invest in eligible Managed Account Programs that are advised and serviced by the referring financial advisor. The administration fee that you pay RCF for a donor advised fund solution may be more or less than if you were to purchase the donor advised fund services from RCF or another non-profit organization. Any fees charged by RCF for the administration of the donor advised fund are not shared with Ameriprise Financial Services or financial advisors. Ameriprise Financial Service and your financial advisor will receive Asset-based Fee revenue from a donor advised fund established by RCF and invested in a Managed Account Program and no revenue if donor advised fund assets are invested with a third-party investment adviser, whether through RCF or another non-profit organization. We seek to address this conflict of interest through a combination of disclosure and through our policies, procedures and supervision related to the determination that a referral to RCF is appropriate for you based on your Client Information, and by treating assets in Managed Accounts owned and administered by RCF and assets in Managed Accounts owned directly by you as separate and distinct advisory relationships in accordance with all applicable regulatory requirements. Review of issuers of financial products Ameriprise Financial Services and its affiliates have policies and procedures in place to review the issuers of financial products such as alternative investments, structured notes, and annuity and insurance products that Ameriprise Financial Services permits its financial advisors to offer to some or all of its clients. This review includes publicly available information and reports issued by third parties and may in some cases include certain nonpublic information provided by the issuer. Ameriprise Financial Services periodically reassesses, but does not continuously monitor, the creditworthiness or financial solvency of third-party issuers. These policies and procedures are reasonably designed to mitigate our clients’ exposure to credit and default risks resulting from an inability of the issuer to repay the principal on a note or fulfill an insurance obligation. However, you should be advised that credit markets can be volatile and the creditworthiness of an issuer may change rapidly. Ameriprise Financial Services, as a seller of these products, is prohibited by regulation from guaranteeing or providing any assurance that an issuer of financial products will be able to fulfill the issuer’s obligation to any purchaser of such a product through Ameriprise Financial Services. Revenue sources for RiverSource Sales charges. You pay sales and other charges under RiverSource variable annuity contracts and life insurance policies. You may incur transaction costs or fees associated with structured annuities. You may pay a contingent deferred sales charge, or surrender charge, if you withdraw funds during the applicable period. Periodic fees and expenses. You pay certain fees and expenses under RiverSource annuity contracts, life insurance policies, and disability income insurance policies, including (depending on the type of contract or policy) mortality and expense, administrative, policy, contract, and cost of insurance fees or charges, in addition to costs associated with certain riders that may be available for both fixed, structured and variable products. Periodic expenses are also paid from product assets, such as 12b-1 fees paid on certain funds that serve as underlying investment options for variable annuities and variable life insurance. 12b-1 fees may be used to pay for marketing, distribution and shareholder service expenses. Investment and interest income. Investment and interest income from insurance company general account assets derived, in part, from the amounts you pay for insurance and annuity benefits. Variable annuity and variable life insurance financial arrangements. RiverSource selects the funds available within your variable annuity contract or variable life insurance policy. In doing so, RiverSource may consider various objective and subjective factors. These factors include compensation RiverSource may receive from fund assets (for those funds with 12b-1 plans); assets of the fund’s adviser, subadviser or an affiliate of either; and assets of the fund’s distributor or an affiliate. This compensation benefits RiverSource. The amount of this revenue varies by fund, may be significant and may create potential conflicts of interest for RiverSource. The greatest amount and percentage of revenue that RiverSource receives comes from assets allocated to subaccounts 33 investing in funds managed by its affiliates, CMIA, and Columbia Wanger Asset Management. In general, the revenue directly related to assets under management that RiverSource receives currently ranges up to 0.65% of the average daily net assets invested in the underlying funds through the variable annuity or variable life insurance contracts RiverSource issues. This revenue is in addition to revenues RiverSource receives from the charges you pay when buying, owning or surrendering your variable annuity contract or life insurance policy. In accordance with applicable laws, regulations and the terms of the agreements under which such revenue is paid, RiverSource may receive this compensation for various purposes including financial advisor training and compensation, marketing and distribution, customer servicing, transaction processing, record keeping, and other administrative services. Revenue sources for Columbia Management and Threadneedle Periodic fees and expenses. Columbia Management and Threadneedle International Limited may receive management fees and certificate advisory and services fees for services, including, with respect to Columbia Management. These revenues may be received from the Columbia Funds, Columbia ETFs, Columbia closed-end funds, Ameriprise certificates and from other affiliated and nonaffiliated advisory clients of Columbia Management and Threadneedle International Limited. Revenue sources for other Ameriprise Financial, Inc. companies There are several other Ameriprise Financial, Inc. companies that will receive revenue from the charges and fees you pay, including the following: • Ameriprise Certificate Company receives investment spread income earned on, and any early withdrawal penalty related to, Ameriprise certificates. • Columbia Management Investment Services Corp. receives certain fees and expenses paid from the Columbia Funds and Ameriprise certificates in exchange for the transfer agent services it provides. • American Enterprise Investment Services Inc. is compensated for its services through the brokerage commission and other fees charged for each brokerage transaction, which may include transactions made in a Ameriprise Bank trust account, or through the brokerage commission which is included in the overall asset-based fee, depending on the account option you select. • If the Sweep Program for your Account is AIMMA, AEIS receives compensation from the Program Banks based on the cash balance in the AIMMA program. If your account sweeps uninvested cash to ABISA or to Ameriprise Bank as the Program Bank in the AIMMA program, Ameriprise Bank does not compensate AEIS, but reimburses AEIS for its direct out-of- pocket expenses related to the sweep services provided. • AEIS receives compensation in the form of interest charged on your margin account balance as well as from order handling fees. In transaction-based brokerage accounts, AEIS may also engage in principal trading of certain types of fixed income securities for brokerage accounts—that is, it may buy and sell these securities for its own account with the objective of making a profit in certain circumstances, AEIS may buy these securities from you or sell these securities to you on a principal basis, in which case you will pay a markup or markdown on the transaction. • AEIS performs for the benefit of Ameriprise Financial Services, its financial advisors and clients, cost reimbursement and marketing support services as described in the "Cost Reimbursement and Marketing Support" section. In recognition of the above, Ameriprise Financial Services will compensate AEIS for these services performed by AEIS. • The capacity in which AEIS acts in any particular transaction is disclosed on each transaction confirmation you receive. AEIS is also compensated for the shareholder services it provides for certain mutual fund companies. These services include but are not limited to delivering shareholder communications such as updated prospectuses and statements of additional information, transaction confirmations and annual tax reporting, and monitoring compliance with share class, discounted sales charge, market timing and other mutual fund company policies. • Ameriprise Financial, Inc. receives fees paid from Columbia and the Columbia Funds and Ameriprise certificates in exchange for the administrative services it provides. • Columbia Management Investment Distributors receives fees paid from the Columbia Funds in exchange for the distribution services it provides. Ameriprise Financial Services has a financial interest in the sale of Columbia Funds, Ameriprise certificates and RiverSource products and certain other mutual funds. 34 • Ameriprise Financial Services sells annuity and insurance products manufactured by its RiverSource affiliates, as well as products from unaffiliated providers. RiverSource is permitted to reimburse Ameriprise Financial Services for client/prospect education events and advisor sales meetings, seminars, and training events pertaining to annuity and insurance products, consistent with Ameriprise Financial Services policies and industry regulation. • Ameriprise Financial Services may also receive nominal noncash benefits from time to time. Unaffiliated annuity and insurance providers may not provide some services, or the same level of services, to Ameriprise financial advisors. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource annuity and insurance products. • Ameriprise Bank charges a fee, depending on the terms of trust documentation and applicable state laws governing trust administration, for its administrative trust services that are separate from investment management fees charged by financial advisors and are not shared with Ameriprise Financial Services. • When Ameriprise Bank is a Program Bank in the AIMMA program or ABISA is the Sweep Option, Ameriprise Bank earns income by lending or investing the deposits it receives and charging a higher interest rate to borrowers, or earning a higher yield, than it pays on the deposits held through these sweep programs. The difference is known as the "spread." • Ameriprise Bank earns revenue based on the amount of credit extended and the interest rate on the Ameriprise Preferred Line of Credit and Loan. Custody Ameriprise Financial services does not maintain custody of client funds or securities or take possession of any assets in any Managed Account. AEIS, one of our broker-dealer affiliates, provides custody and safekeeping services for Managed Account assets and will ordinarily act as the custodian for all assets held in a Managed Account. Because our affiliate maintains custody of our clients’ assets, we are required by SEC rules and regulations to obtain from AEIS at least annually a written internal control report (the “ICR”) prepared by a qualified independent public accountant, and AEIS is required to undergo an independent verification of the assets under its control. The ICR that we receive from AEIS is intended to show that our affiliate has established appropriate custodial controls with respect to client assets under custody. For Retirement Accounts where Ameriprise Trust Company (“ATC”) acts as custodian or trustee, AEIS shall act as an agent or sub-custodian of ATC with respect to custody of assets. Investment Discretion None of Ameriprise Financial Services, the Service team or your Ameriprise financial advisor manages or exercises investment discretion over your securities or other investments on your behalf as part of the Service. Voting Client Securities Ameriprise Financial Services does not offer proxy voting services with respect to accounts included in the Service. Ameriprise Financial Services and your financial advisor do not take any action or give advice regarding the voting of proxies solicited by or with respect to the issuers of securities in which assets of your Ameriprise brokerage account(s) or Managed Account(s) may be invested, except for certain Select Separate Accounts where you delegate proxy voting authority to Ameriprise Financial Services. In all other instances, Ameriprise Financial Services will forward to you or your designated agent, all proxy solicitations and materials related to other corporate actions that are received by Ameriprise Financial Services with respect to assets in your Ameriprise brokerage account(s) or Managed Account(s). You are responsible for voting such proxies and effectuating other corporate actions relating to the securities held in your respective account(s). Financial Information We are not required to include a balance sheet in this Brochure because we do not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance. We do not have any financial conditions that are reasonably likely to impair our ability to meet our contractual commitments to clients. Ameriprise Financial Services has not been the subject of a bankruptcy petition during the past 10 years. 35 Glossary • • “ABISA” means Ameriprise Bank Insured Sweep Account. “Advisers Act” means the Investment Advisers Act of 1940, as amended. • • “AEIS” means American Enterprise Investment Services Inc. “AFIG” means Ameriprise Financial Institutions Group. • • “AIMMA” means Ameriprise Insured Money Market Account, an interest-bearing multi- bank deposit product. “Ameriprise” means Ameriprise Financial, Inc. • • “Ameriprise Financial Services”, “Ameriprise Financial”, “AFSI”, “we”, “us” or “our” means Ameriprise Financial Services, LLC. “ATC” means Ameriprise Trust Company. • • “Available for Sale Firms” are firms that sponsor or manage mutual fund options to whom IRG will proceed to look for if a suitable mutual fund recommendation for a particular asset class cannot be found within the Full Participation Firms’ offerings. “Bank” means Ameriprise Bank, FSB. • “Brochure” or “Disclosure Brochure” means Ameriprise Premier Retirement Income Client Disclosure Brochure. • “CD” means a Certificate of Deposit. • “CFTC” means the Commodity Futures Trading Commission. • “CMIA” or “Columbia Management Investment Advisers” means Columbia Management Investment Advisers, LLC. • “Columbia” or “Columbia Management” refers, collectively, to Columbia Management Investment Advisers, LLC and Columbia Wanger Asset Management, LLC. • “Columbia Funds” means investment companies and other funds advised by affiliated companies, Columbia Management Investment Advisers, LLC and Columbia Wanger Asset Management, LLC. • CTA” means Commodity Trading Advisor. • “Effective Date” means the effective date of the Service Agreement. • • “Engagement Period” means each applicable twelve-month period for the Service. “ERISA” means the Employee Retirement Income Security Act of 1974, as amended. • “FASB” means the Financial Accounting Standards Board. • “FDIC” means the Federal Deposit Insurance Corporation. • • • “FINRA” means the Financial Industry Regulatory Authority. “Full Participation Firms” are mutual fund firms that fully participate in the Mutual Fund Program. “Internal Revenue Code” means the Internal Revenue Code of 1986, as amended. • “IRA” means an individual retirement account. • “IRG” means Ameriprise Investment Research Group. • “Managed Account” means an Ameriprise investment advisory account for which you pay an ongoing asset- based Wrap Fee. • “Mutual Fund Program” means Ameriprise Financial Mutual Fund Program, the structure formed by the payment of the mutual fund and 529 plan marketing and sales support payments that are received from certain mutual fund firms. • • “NFA” means National Futures Association. “NYSE: AMP” means Ameriprise Financial, Inc. stock symbol on the New York Stock Exchange. • “Outside Workplace Retirement Plan” means additional retirement plan assets held outside of Ameriprise Financial Services in a participant-directed defined contribution plan. 36 • • “Promoter” means any individual professional, professional firm, or select corporate, institutional or membership organization that provides testimonials or endorsements of Ameriprise Financial Services for its investment advisory services. “Recommendation Report” means each written retirement income plan provided to you. • “Retirement Portfolio” means the accounts, assets and income sources you have designated to fund your retirement objectives, e.g., expenses and goals, and which are included for analysis in a Recommendation Report. • “RiverSource” refers, collectively, to RiverSource Life Insurance Company and RiverSource Life Insurance Co. of New York. • “SEC” means the United States Securities and Exchange Commission. • “SIPC” means the Securities Investor Protection Corporation. • • “Service Agreement” means the Ameriprise Premier Retirement Income Agreement, as it may be amended from time to time, that includes the specific terms under which the client will receive the Service. “Service Fee” means the advisory fee you pay for the Service. • “Starting Point List” means mutual funds and ETF recommended list developed by IRG. • “Sweep Program” means money settlement feature offered by Ameriprise Financial Services that is intended to hold cash. • “Third Party Financial Institutions” means third-party financial institutions such as community banks, credit unions, credit union service organizations and Farm Credit Services with whom Ameriprise Financial Services may form alliances and networking arrangements with to allow its financial advisors to offer financial planning services and certain other non-deposit investment and insurance products and services, to retail customers/members of the Third Party Financial Institutions. • “Third Party Payments” means the portion of investment costs paid to AEIS by third parties who manage, sponsor or distribute investment products held in your Managed Account. This Brochure provides information about the qualifications and business practices of Ameriprise Financial Services, LLC. If you have any questions about the contents of this Brochure, please consult with your financial advisor or contact us at 800.862.7919 between 7 a.m. and 6 p.m. Central time. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Ameriprise Financial Services, LLC’s California insurance license number is 0684538. Additional information about Ameriprise Financial Services, LLC also is available on the SEC’s website at adviserinfo.sec.gov. Financial Planning | Retirement | Investments | Insurance | Banking Investment advisory services and products are made available through Ameriprise Financial Services, LLC, a registered investment adviser with the SEC. Ameriprise Financial Services, LLC. Member FINRA and SIPC. © 2026 Ameriprise Financial, Inc. 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Additional Brochure: AMERIPRISE RETIREMENT PLAN CONSULTING SERVICES (2026-03-27)

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Ameriprise® Retirement Plan Consulting Services Client Disclosure Brochure (Form ADV Part 2A) March 2026 Ameriprise Financial Services, LLC 70400 Ameriprise Financial Center Minneapolis, MN 55474 ameriprise.com This Brochure provides information about the qualifications and business practices of Ameriprise Financial Services, LLC and the Retirement Plan Consulting Services. If you have any questions about the contents of this Brochure, please consult with your financial advisor or contact us at 800.862.7919 between 7 a.m. and 6 p.m. Central time. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Ameriprise Financial Services, LLC also is available on the SEC’s website at adviserinfo.sec.gov 118229 E (03/26) Material Changes Annual Update This Brochure dated March 2026 is filed as the update to Form ADV Part 2A and includes material changes that have occurred since the last annual update of our brochure in March 2025. Following is a summary of the material changes. • The “How our financial advisors get paid” section was retitled “Financial Advisor Compensation and Benefits” and was updated in general for clarity and overall readability. You may request copies of the Brochure by writing to Ameriprise Financial Services, LLC at 2661 Ameriprise Financial Center, Minneapolis, MN 55474, or by calling 800.862.7919. Please retain a copy of this Brochure for your records. Table of Contents Advisory Business .................................................................................................................................................................. 1 Fees and Compensation ......................................................................................................................................................... 3 Termination of RPCS .............................................................................................................................................................. 3 Performance-Based Fees and Side-by-Side Management................................................................................................ 4 Types of Clients ....................................................................................................................................................................... 4 Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................................... 4 Disciplinary Information ......................................................................................................................................................... 6 Other financial industry activities and affiliations ............................................................................................................. 7 How we get paid ..................................................................................................................................................................... 10 Code of Ethics, Participation or Interest in Transactions and Personal Trading ....................................................... 18 Brokerage Practices .............................................................................................................................................................. 19 Review of Accounts .............................................................................................................................................................. 19 Client Referrals and Other Compensation......................................................................................................................... 19 Custody ................................................................................................................................................................................... 22 Investment Discretion ........................................................................................................................................................... 22 Voting Client Securities ........................................................................................................................................................ 22 Financial Information ............................................................................................................................................................ 22 Privacy Notices ...................................................................................................................................................................... 23 Glossary .................................................................................................................................................................................. 23 About Ameriprise ................................................................................................................................................................... 25 Advisory Business Ameriprise Financial Services, LLC (“Ameriprise Financial Services”) is an investment advisory firm offering financial planning services since 1986. Ameriprise Financial, Inc., a publicly held company, is the parent company of Ameriprise Financial Services. References in this Brochure to “you” and “your” apply to each client who signs the Retirement Plan Consulting Services Agreement(“Agreement”). References to “us,” “we,” and “our” refer to Ameriprise Financial Services, LLC. References to “your financial advisor” are to your Ameriprise financial advisor. Ameriprise® Retirement Plan Consulting Services Ameriprise® Retirement Plan Consulting Services (“RPCS”) is designed to assist employers and trustees in their role as a plan fiduciary ("Plan Fiduciary"). The specific scope of services provided to each Plan Fiduciary are agreed upon by you and your financial advisor on a case­by­case basis and an engagement would typically include one or more of the following services, which may be offered in whole or in part, as negotiated with a Plan Fiduciary: Investment committee support Investment performance monitoring • • Plan lineup construction • • Attendance at Plan Fiduciary meetings and additional plan support • Participant education and client maintenance services Ameriprise Financial Services and your financial advisor provide non­discretionary investment advisory services as a fiduciary to your plan under Section 3(21) of ERISA with respect to investment monitoring and recommendations provided to the plan. Your financial advisor is not permitted to serve as a trustee for your plan or as a member of your investment committee. Neither Ameriprise Financial Services nor your financial advisor will have discretionary investment or trading authority with respect to your plan and we are therefore not an investment manager under Section 3(38) of ERISA. Participant education and client maintenance services are educational and general in nature and do not constitute “investment advice” under ERISA and therefore neither Ameriprise Financial Services nor your financial advisor will be a fiduciary to the plan or the participant with respect to those services. Investment Committee Support: The financial advisor assists a Plan Fiduciary sometimes directly and sometimes through its investment committee in developing and maintaining an investment policy statement. The financial advisor will assist in providing information to aid the Plan Fiduciary in creating policy statements or the revision thereof including risk levels, allocations, relative index selection, asset class ranges, plan investment objectives, or other criteria that may be pertinent. The financial advisor also may provide services for facilitating and documenting investment committee meetings and communicating industry trends to the Plan Fiduciary. Information regarding these services may be proprietary to Ameriprise or from an outside source. It is the responsibility of the Plan Fiduciary to verify this data. Plan Lineup Construction: The financial advisor will use the plan’s investment objectives to recommend specific investment products to be held by the plan, or in the case of a participant­directed defined contribution plan to be made available as investment options under the plan. Your financial advisor conducts due diligence on current and potential investment managers and providing reports and advice to the Plan Fiduciary. Your financial advisor may also assist Plan Fiduciaries in establishing and monitoring a watch list for investment products and/or investment managers. For Defined Benefit plans, your financial advisor will typically also recommend a target asset allocation for the plan based on a variety of factors including, but not limited to, risk tolerance, investment objective, historical performance of different asset classes, and plan funding ratios. Asset mixes are derived using available historical information and projected performance for each asset class based on the selected performance index for that class. They are meant only to illustrate the relative experience between asset classes and portfolios. Other asset classes and indices may have characteristics similar or superior to those being analyzed. Generally periodic rebalancing of the portfolio and reallocation among the asset classes is recommended. It is the Plan Fiduciary's responsibility to ultimately select and implement an asset allocation mix based on plan suitability. Investment Performance Monitoring: The financial advisor monitors plan investments on a periodic basis and prepares reports on investment or portfolio performance to the Plan Fiduciary. The strategy for meeting investment objectives for each investment 1 product or portfolio is left to the independent investment managers hired by the Plan Fiduciary, although Ameriprise Financial Services may identify and report on drift away from an investment's stated investment objectives to the Plan Fiduciary. The financial advisor may also prepare reports for clients, which may include an assessment of performance over various time periods. Plan Fiduciary Meetings and Additional Plan Support: The financial advisor may attend periodic meetings with Plan Fiduciaries. At these meetings, the financial advisor may share industry knowledge, proprietary or non­proprietary research, economic outlooks, reports from the plan record keeper regarding plan health or other pertinent information. To the extent that these sources are developed by third parties, Ameriprise Financial Services will not verify data and will not be able to attest to the points of view expressed within. Your financial advisor's attendance of these meetings is negotiated on a case­by­case basis. The financial advisor may provide additional support and services to the plan such as acting as liaison between the plan and service providers, products sponsors and/or other vendors, assisting with the preparation, distribution and evaluation of requests for proposals, finalist interviews, conversion support and analysis and assistance in identifying the fees and other costs borne by the plan. Participant Education and Client Maintenance Services: The financial advisor provides services such as participant education, which may include preparation of education materials and/or conducting investment education seminars and meetings for Plan participants, assisting you with enrolling plan participants in the plan, and other consulting services as negotiated between you and your financial advisor. These services do not include any individualized investment advice to the Plan Fiduciary or plan participants with respect to plan assets, and we do not act as fiduciaries under ERISA in providing such consulting services. When available, your financial advisor will review participant allocations against demographic information to encourage allocations aligned more closely with generally agreed upon investment theory. Ameriprise Financial Services and your financial advisor do not provide legal or tax advice. Implementation of your recommendations RPCS is a non­discretionary investment advisory service. This means RPCS does not include the implementation of any recommendations presented to you by your financial advisor. Before implementing any recommendations, carefully consider the ramifications of purchasing products or services. You may want to seek further advice from your lawyer and/or accountant, particularly for taxes, or business planning issues. RPCS does not provide specific buy, sell or hold recommendations concerning individual securities to plan participants and your financial advisor cannot assist plan participants with implementing or initiating any transactions within the plan. Investment advice provided to Plan Fiduciaries is limited to the plan you have designated to be included in the service. RPCS does not include ongoing monitoring of, or advice related to, any other investments, accounts, or income streams. Ongoing Service relationship You may change the RPCS services provided to Plan Fiduciaries by discussing any desired changes with your financial advisor. In addition, after looking at the needs of your plan, your financial advisor may decide to recommend additional services that have not already been identified. You and your financial advisor should also discuss whether your RPCS Fee needs to change in light of the changes to the needs of your plan. Other advisory services Your financial advisor may establish a client relationship with one or more plan participants. Such client relationships may occur: 1) through an IRA rollover distributed from this or any other plan; or 2) because of a decision by the participant to purchase other investment products or services from your financial advisor. Any client relationship established with a plan participant will be outside of the scope of your RPCS services. When a plan participant chooses to purchase products and services through Ameriprise Financial Services, the plan participant has the option of investing through a commission­based brokerage account, or a fee­based managed account, or both. The plan participant will work separately and directly with a financial advisor to implement recommendations within the managed accounts, Ameriprise brokerage accounts, or other products and services made available through Ameriprise Financial Service or our affiliates, as appropriate. Ameriprise Financial Services offers a suite of Advisory Solutions that features several types of Programs, 2 including Strategic Portfolio Service (“SPS”) Advantage, SPS Advisor, Signature Wealth, Active Portfolios® investments, Select Separate Account, Vista Separate Account, Investor Unified Account, and Access Account. Not all Managed Account Programs are available to all clients; contact your financial advisor for more information. Please review the Ameriprise Managed Accounts Client Disclosure Brochure, or if you have elected to pay a consolidated advisory fee, the Ameriprise Managed Accounts and Financial Planning Service Disclosure Brochure for a full description of these Programs. Your financial advisor may offer ongoing financial planning or other services that are described in the Ameriprise Financial Planning Service Client Disclosure Brochure. As of December 31, 2025, Ameriprise Financial Services managed $304,183,842,664 in nondiscretionary assets and $356,290,579,112 in discretionary assets. Fees and Compensation The fee you pay for investment advice and services for RPCS (the “RPCS Fee”) is based on one the following, as negotiated between you and your financial advisor: • a percentage of the assets held in the plan (up to 1.25% annually); or • on a flat rate basis which generally shall not exceed 1.25% of the plan’s assets, however, in certain circumstances may exceed this rate when the flat fee covers a unique or complex range of services, such as advice relating to the initial plan setup. RPCS Fees vary based on a number of factors including (1) the range of services provided; (2) your financial advisor’s years of experience, professional credentials, and other factors, such as local market considerations; and (3) the overall complexity of your plan’s needs and services. RPCS Fees are negotiable and there is no assurance that similarly situated clients will be assessed comparable fees. Ask questions about the RPCS Fee so that you understand the factors considered in arriving at your RPCS Fee and what you can expect for this fee. The RCPS Fee will be payable to Ameriprise Financial Services in advance or in arrears on the frequency (e.g., quarterly, monthly, etc.) agreed upon between you and your financial advisor. If the RPCS Fee is based on a percentage of the assets held in the plan the RPCS Fee payment generally will be based on the value of the plan assets as of the close of business on the last business day of the period as valued by the custodian of the assets. However, if the RPCS Fee is paid by the plan or by you through a third party service provider, such fee will be calculated as determined by the provider. If the RPCS Fee is paid prior to the services being provided, the plan will be entitled to a prorated refund of any prepaid fees for services not received upon termination of the Agreement. The portion of the RPCS Fee allocated to your financial advisor is impacted by factors including the level of affiliation that the financial advisor has with Ameriprise Financial Services and whether the financial advisor was assisted by another person (which may be a financial advisor or other individual who makes a referral) in providing services to you. The remaining portion of the fee goes to Ameriprise Financial Services for the supervisory, technical, infrastructure, administrative and other support provided to financial advisors offering RPCS. Ameriprise Financial Services is dedicated to providing quality client service. We work hard to ensure your satisfaction with the RPCS services that you receive and seek to meet or exceed your expectations. We will work with you to address any of your concerns, including helping you work with a different financial advisor or terminating the Agreement. Termination of RPCS RPCS will remain in effect until one of the following occurs: termination by you; termination by Ameriprise Financial Services, which would require sending you written notice reasonably in advance of the termination date to your address as shown on our records; or termination by you through nonpayment of the RPCS Fee. The Agreement will remain in effect until one of the following occurs: termination by you; termination by Ameriprise Financial Services, which would require sending you written notice reasonably in advance of the termination date to your address as shown on our records; or termination by you through nonpayment of the RPCS Fee. To terminate or cancel the Agreement and request a refund, if eligible, submit a written request including you plan name, your advisor name, 3 the recordkeeper name and if applicable, the reason your requesting the refund. Please send this request via email to RPCS.program@ampf.com. Performance­Based Fees and Side­by­Side Management Neither Ameriprise Financial Services nor any of its supervised persons accepts performance based fees for its investment advisory services. Types of Clients RPCS is available to clients that are trustees or other fiduciaries to plans, including 401(k), 457(b), 403(b) and 401(a) plans. Plans include participant directed defined contribution plans and defined benefit plans. Ameriprise Financial Services does not require a minimum asset amount, but there is a $500 minimum fee for RPCS. The investment advisory services provided by Ameriprise Financial Services and our financial advisors, as applicable, are services that are provided only to the Plan Fiduciary or the plan, and not to any particular plan participant. Methods of Analysis, Investment Strategies and Risk of Loss Methods of financial analysis When developing recommendations, your financial advisor may use training and marketing materials and prospectuses and annual reports for a particular investment product. In addition, your financial advisor may also utilize research produced by Ameriprise Financial Services or its affiliates, such as material prepared by the Ameriprise Investment Research Group ("IRG"). Your financial advisor may use asset value, current and projected rates of return, and other assumptions, as well as historical return analysis. Your recommendations may be prepared through the use of one or more third­party software packages that use one or more methods of analysis, including deterministic and probability modeling. The analysis and projections generated by this software or other analysis tools typically include information regarding the likelihood of various potential investment outcomes. They are hypothetical in nature, vary depending on which tool of analysis is used and with each use and over time, do not reflect actual investment results, and are not guarantees of future results. Investing in securities involves the risk of loss and you should be prepared to bear this loss. The probability of success also varies based on differing assumptions, on different tools, changing circumstances and market information. Your financial advisor may rely on information or data from third­ party research providers that have been approved by Ameriprise Financial Services when providing investment advice, including performance analytics services, financial publications, interviews or questionnaire responses from investment managers, and other sources when providing RPCS. From time to time, Ameriprise Financial Services or your financial advisor may provide you with general market commentary and non­securities material prepared by third parties and approved for use by Ameriprise Financial Services. Among other things, this information may include performance information or market data relating to securities and securities markets. Although the information and data are believed to be accurate, Ameriprise Financial Services and its financial advisors do not independently verify third­party information. Neither Ameriprise Financial Services nor its financial advisors guarantee the accuracy, completeness or timeliness of any such information nor do they imply any warranty of any kind regarding the information provided. For your plan accounts and assets all market value (i.e., account value) information used in connection with your RPCS was provided by you or your designated agents and is shown as of the date it was provided to Ameriprise Financial Services. Ameriprise Financial services does not have knowledge of changes in your plan assets. This means that if you do not provide updated information about plan assets, the recommendations provided to you will be based on data about plan assets that is not current. Ameriprise Financial and your financial advisor take reasonable steps to reproduce information obtained from you or your designated agents regarding plan assets. 4 The information provided to you in your analysis and written recommendations is not intended to be a substitute for the valuation and other information contained in your plan’s official statements provided by the plan custodian, recordkeeper or administrator, as applicable. Neither Ameriprise Financial nor your financial advisor has undertaken to review or verify the accuracy of plan assets. Investment strategies The investment advice and other information provided under RPCS is designed to align with the plan’s investment policy statement or the plan’s fiduciary guidelines and is intended to be consistent with generally accepted retirement plan investment strategies. We cannot guarantee future financial results or the achievement of your plan’s investment objectives through implementation of any advice or recommendations provided to you by your financial advisor. Ameriprise Financial Services does not monitor the day­to­day performance of your specific investments. Before implementing your recommendations, you should carefully consider the ramifications of purchasing products or services, and you may want to seek further advice from your lawyer and/or accountant, particularly in connection with estate planning and taxes. Investment and market risk You should understand that: • All investments involve the risk of loss and you should be prepared to bear such a loss (the amount of which may vary significantly), • Investment performance or tax treatment of any accounts and assets included in your plan can never be predicted or guaranteed, • The market value of your plan will fluctuate due to market conditions and other factors such as liquidity and volatility, • There is no guarantee that the service or its related recommendations will meet its objectives, • Past performance does not predict future performance with respect to any product or service described in this Disclosure Brochure, • All trading in your accounts will be at your risk. • The risks of participating in the Service include but are not limited to the following: • Market Risk. Market risk refers to the possibility that the market values of securities or other investments will fall, sometimes rapidly or unpredictably, or fail to rise, because of a variety of actual or perceived factors affecting issuer, industry or sector in which it operates or the market as a whole. • Interest Rate Risk. The interest rate risk is the risk that investment value is sensitive to changes in interest rates. In general, a rise in interest rates may result in a price decline of fixed­income instruments. This risk may be heightened for longer maturity and duration instruments. • Inflation Risk. Inflation risk is the uncertainty over the future value of an investment due to inflation. Investments may not keep pace with inflation, which may result in losses. • Liquidity Risk. Liquidity risk is the risk associated with any event, circumstance, or characteristic of an investment or market that negatively impacts the ability to sell, or realize the proceeds from the sale of, an investment at a desirable time or price. • Tax Risk. This is the risk that the tax treatment of certain investments and of the income and gain therefrom is uncertain and can vary over time. • Legal and Regulatory Risk. This is the risk that new or revised laws or regulations may adversely affect investments included in the Service. • Business Disruption Risk. This is the risk of business disruption of varying severity and scope occurring. The types of disruption may include, but not be limited to, firm­only disruption, disruption that affects a single building, a disruption that affects the entire city or business district, and disruption that affects the entire region. Please read more in Ameriprise Financials’ Business Continuity Plan Disclosure and Ameriprise 5 Financial Client Relationship Guide. • Cybersecurity Risk. With the use of technologies such as internet to conduct business, businesses are susceptible to cybersecurity breaches, please read more at https://www.ameriprise.com/privacy­security­fraud. • Technology Risk. Businesses must rely in part on digital and network technologies to conduct business, provide services and maintain business operations. These technology systems may fail to operate properly or become disabled as a result of events or circumstances wholly or partly beyond control. Technology failures, whether deliberate or not, could have a material adverse effect and could result in, among other things, financial loss, reputational damage, regulatory penalties or the inability to conduct business. The risks described above should not be considered to be an exhaustive list of all the risks which clients should consider. Disciplinary Information Below is notice of certain regulatory and legal settlements entered into by Ameriprise Financial Services during the last ten years: Regulatory proceedings Ameriprise Financial Services entered into each of the regulatory settlements listed below without admitting or denying the allegations. Securities and Exchange Commission (“SEC”) and FINRA actions In August 2024, Ameriprise Financial Services reached a settlement with the SEC in connection with its industry­wide review of firms’ recordkeeping practices regarding business­related electronic communications sent or received by firm personnel using non­approved channels or methods (“off­channel communications”). The settlement resolved allegations that, from at least June 2019, the firm did not maintain or preserve a substantial majority of off­channel communications that were records required to be maintained under federal securities laws and therefore failed to reasonably supervise its personnel. The firm agreed to pay a civil penalty amount of $50 million. Prior to the settlement, the firm retained a compliance consultant to address certain undertakings outlined in the settlement and took steps to enhance its policies and procedures and increase training concerning the use of approved communications methods. In August 2018, Ameriprise Financial Services reached a settlement with the SEC regarding allegations that from 2011 through 2014 the firm failed to adopt and implement policies and procedures reasonably designed to safeguard retail investor assets against misappropriation and failed to reasonably supervise five representatives with a view to preventing and detecting violations of certain federal securities laws by these representatives. The firm agreed to pay a civil penalty amount of $4.5 million. The firm further reimbursed all impacted clients for the losses they incurred due to the misconduct. The firm also took steps to enhance policies, procedures and controls related to the safeguarding of client assets against theft or misappropriation by its associated persons and voluntarily retained a compliance consultant to assess and confirm the reasonableness of these policies, procedures and controls. In December 2017, Ameriprise Financial Services reached a settlement with the SEC regarding allegations that from December 2010 through October 2013, the firm negligently relied on misrepresentations made by F­ Squared Investments, Inc. regarding certain of its ETF portfolios and, as a result, the firm made false statements about the portfolios in certain advertisements. The SEC also alleged that the firm had failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the alleged violations. The firm agreed to pay a disgorgement amount of $6.3 million plus prejudgment interest of $700,000 and a civil penalty amount of $1.75 million. In September 2016, Ameriprise Financial Services reached a settlement with FINRA regarding allegations that between October 2011 and September 2013 the firm failed to detect and prevent the conversion, via wire transfers, of more than $370,000 from five of its customers by one of its registered representatives. The customers were family members of the registered representative. FINRA also alleged this went undetected because the firm failed to establish, maintain, and enforce a supervisory system that was reasonably designed to 6 review and monitor the transmittal of funds from accounts of customers to third parties, including those controlled by registered representatives of the firm. The firm paid restitution and a fine of $850,000. Other financial industry activities and affiliations Ameriprise Financial Services, LLC is a subsidiary of Ameriprise Financial, Inc. and conducts its activities directly and through its affiliates. These activities may be material to its investment advisory business or its investment advisory clients. These affiliates include companies under common control with Ameriprise Financial Services by virtue of their status as direct or indirect subsidiaries of Ameriprise Financial, Inc. The information below provides you an overview of the Ameriprise Financial, Inc. companies. These companies work together to offer you financial products and services designed to help you reach your financial goals. Broker­dealer Ameriprise Financial Services, LLC is a registered investment adviser and broker­dealer with the SEC and is authorized to engage in the securities business in all 50 states as well as the District of Columbia, Puerto Rico, and the U.S. Virgin Islands. Ameriprise Financial Services is also a member of FINRA and the Securities Investor Protection Corporation (“SIPC”). Ameriprise Financial Services is registered with the Commodity Futures Trading Commission (“CFTC”) as a commodity trading advisor (“CTA”) and has obtained membership with the National Futures Association (“NFA”) in connection with such CFTC registration. In its capacity as a broker­dealer, Ameriprise Financial Services distributes or receives compensation from selling various products including but not limited to equities and fixed income products. Offerings include corporate bonds and municipal securities, mutual fund shares, ETFs, 529 plans, face­amount certificates, closed­end funds, preferred securities, UITs, non­ traded REITs, non­traded BDCs, non­traded closed end funds, hedge fund offerings, structured products, real estate private placement offerings, exchange funds, private equity offerings, 1031 exchanges, fixed, structured and variable annuities, and fixed and variable insurance. Ameriprise Financial Services also sells managed futures funds that engage in trading commodity interests, including futures. In addition, Ameriprise Financial Services is the distributor of the publicly offered face­amount certificates issued by Ameriprise Certificate Company. Ameriprise Financial Services also may serve as an underwriter or member of a selling group for securities offerings, including those issued by affiliates. Retail brokerage services are made available through Ameriprise Financial Services, which has an agreement with American Enterprise Investment Services Inc. (“AEIS”), a registered broker­dealer and an affiliate of Ameriprise Financial Services. Ameriprise Financial Services requires clients to agree in their client agreements that their account(s) are introduced by Ameriprise Financial Services to AEIS on a fully­disclosed basis, and that securities purchase and sale transactions in their account(s) shall be directed through AEIS. For purposes of Form ADV Part 2 certain Ameriprise Financial Services management persons are registered representatives of Ameriprise Financial Services in its capacity as a broker­dealer, registered representatives of American Enterprise Investment Services Inc., and are associated persons of Ameriprise Financial Services in its capacity as a commodity trading advisor. Ameriprise Financial Services approves and opens accounts and accepts securities order instructions with respect to the accounts. AEIS serves as Ameriprise Financial Services’ clearing agent in providing clearing and settlement services for transactions that are executed for customers of Ameriprise Financial Services. In exchange for a fee paid by Ameriprise Financial Services, AEIS provides clearing, custody, record keeping and all clearing functions for certain advice­based accounts. In addition, AEIS may act as an agent in effecting securities transactions for certain Ameriprise Bank trust accounts. AMPF Holding LLC, an indirect wholly­owned subsidiary of Ameriprise Financial, Inc., is a holding company for Ameriprise Financial Services and AEIS. Columbia Management Investment Distributors, Inc. (“Columbia Management Investment Distributors”), an indirect wholly­ owned subsidiary of Ameriprise Financial, Inc., is a registered broker­dealer serving as principal underwriter and distributor of registered mutual funds and other funds advised by affiliated companies Columbia 7 Management Investment Advisers, LLC (“CMIA”) and Columbia Wanger Asset Management, LLC, (“Columbia Wanger Asset Management”) (collectively, “Columbia Management” or “Columbia”). These funds are collectively referred to as the “Columbia Funds.” Investment company Ameriprise Financial Services has arrangements with Ameriprise Certificate Company to distribute and sell its face­amount certificates and selling arrangements with Columbia Management Investment Distributors to distribute the Columbia Funds. Investment advisory firm Columbia Management Investment Advisers, LLC (CMIA) is registered as an investment adviser with the SEC. CMIA provides investment management services to: • Columbia Funds, as well as Columbia ETFs, closed­end funds and private funds • Ameriprise Certificate Company • RiverSource, as well as the Columbia Funds underlying certain variable contracts issued by RiverSource • Various wrap program sponsors, including Ameriprise Financial Services • Other affiliated and unaffiliated clients. Ameriprise Financial, Inc. has other subsidiaries that are registered as investment advisers with the SEC, including, among others, Threadneedle International Limited, Pyrford International Ltd. and Lionstone Partners, LLC. These subsidiaries are registered as investment advisers and may provide advice to domestic and foreign institutional clients, the Columbia Funds, the Columbia ETFs, the Columbia closed­end funds, private funds and other fiduciary clients. These entities provide services independent from Ameriprise Financial Services. Columbia Management and its affiliates Threadneedle Asset Management Ltd, (U.K. based), Threadneedle Investments Singapore (Pte.) Limited (Singapore based), and Columbia Threadneedle Investments (ME) Limited (Dubai based) operate under a combined global asset management brand, Columbia Threadneedle Investments. Ameriprise Financial Inc. also has non­US subsidiaries that provide asset management services. These include Columbia Threadneedle Management Limited (“CTML”), Columbia Threadneedle Netherlands B.V. (“CTLN”), Columbia Threadneedle Business Limited (“CTBL”), Columbia Threadneedle AM (Asia) Limited (“CTAMLA”), Columbia Threadneedle (EM) Investments Limited (“CT (EM)”) and Pyrford International Ltd (“Pyrford”). Each of CTML, CTLN, CTBL, CTAMLA, CT (EM) and Pyrford is registered with the appropriate respective regulators in their home jurisdictions. In addition, Pyrford is also registered with the SEC as an investment adviser. Columbia Management Investment Advisers is also registered with the CFTC as a commodity pool operator and a CTA and has obtained membership with the NFA in connection with such CFTC registration. Threadneedle International Limited is registered with the CFTC as CTA and has obtained membership with the NFA in connection with such CFTC registration. Banking institution Ameriprise Bank, FSB, a wholly owned subsidiary of Ameriprise Financial, Inc. and an affiliate of Ameriprise Financial Services, is a federal savings bank. In addition to its participation in the AIMMA and ABISA Sweep Programs, Ameriprise Bank currently makes available a core set of banking products, including mortgage financing, co­branded credit cards with an associated rewards program, savings, certificates of deposit (“CDs”) and checking accounts, and pledged asset loans. Ameriprise Bank provides personal trust services to clients, including trustee and investment management services for asset trusts, and investment management and custodial agency services for individual, individual trustee, association and non­profit organization accounts. Ameriprise Financial Services establishes custodial accounts and accepts securities order instructions for trust accounts at Ameriprise Bank. In addition, Ameriprise Financial Services may provide investment advice and research support to Ameriprise Bank and its clients for these trust accounts. Trust company Ameriprise Trust Company (“ATC”), a Minnesota­chartered trust company, provides custodial, investment management and collective trust fund services for employer­sponsored retirement plans, including pension, profit sharing, 401(k) and other qualified and nonqualified employee retirement plans. ATC also serves as custodian for 8 IRAs, 403(b)s and some retirement plans qualified under section 401(a) of the Internal Revenue Code of 1986 as well as the Ameriprise Certificate Company. ATC is not a deposit bank or a member of FDIC. Insurance company Affiliated insurance products sold by Ameriprise Financial Services and its financial advisors are issued by RiverSource Life Insurance Company (RiverSource Life), a stock life insurance company that is qualified to do business as an insurance company in the District of Columbia, American Samoa and all states except New York; and in New York only, issued by RiverSource Life Insurance Co. of New York (“RiverSource Life of NY”), a stock life insurance company that is qualified to do business as an insurance company in New York. The products of RiverSource Life and RiverSource Life of NY (together “RiverSource”) include structured annuities (RiverSource Life only), fixed and variable annuities, fixed and variable life insurance, disability income insurance and life insurance with long­term care benefits. Insurance products are also offered by other third parties through an arrangement with Ameriprise Financial Services and through Diversified Brokerage Services, Inc., LTCI Partners and Disability Resource Group, which act as co­general agents. RiverSource Distributors, Inc. (“RiverSource Distributors”), a wholly owned subsidiary of Ameriprise Financial, Inc., is a registered broker­dealer, serving as principal underwriter and distributor of RiverSource variable life insurance and annuities on behalf of RiverSource. Ameriprise Financial Services has selling arrangements with RiverSource and RiverSource Distributors to distribute these products. Ameriprise Financial Institutions Group (“AFIG”) AFIG is a business channel within Ameriprise Financial Services that specializes in delivering investment products and services to clients of financial institutions, such as banks and credit unions. Ameriprise Financial Services enters into a networking arrangement with each financial institution whereby AFIG financial advisors provide one or more of our investment advisory services, brokerage services and insurance products to clients of the financial institution and other persons or entities that may be introduced or referred to us by the financial institution. The financial institution provides AFIG financial advisors joint marketing access to a distinct client segment and may provide office space in the building where it conducts its business. As a part of the contractual arrangement with the financial institution, Ameriprise Financial Services shares with the financial institution a portion of up to 94% of fees and commissions, including Asset­based Fees charged for investment advisory services, generated by AFIG financial advisors that are attributable to our operations under the joint marketing agreement with the financial institution. A portion of these fees may be paid to financial advisors who are employees of the financial institution, as described below. All AFIG financial advisors are licensed and registered through Ameriprise Financial Services. Ameriprise Financial Services has exclusive control over the activities conducted on our behalf under the agreement with the financial institution and is responsible for the supervision of certain activities of AFIG financial advisors. AFIG financial advisors are affiliated with Ameriprise Financial Services in one of three ways: independent contractors and their personnel, Ameriprise employee financial advisors and financial institution employee financial advisors. Financial advisors employed by the financial institution are compensated by the financial institution from the portion of fees and commissions it receives from Ameriprise Financial Services. In such cases the financial institution serves as paying agent on our behalf in accordance with applicable law. The level of compensation received by financial advisors employed by the financial institution is based on their employment agreement with the financial institution. Ameriprise Financial Services does not pay any compensation to any non­registered employee or agent of the financial institution for referrals. Any referral fee paid by the financial institution to an employee or agent is a one­time, per­customer fee of a nominal, fixed dollar amount and is unrelated to the products and services you purchase. AFIG financial advisors who provide services at a financial institution that does not have a Trust Department can offer trust services through other providers, including our affiliate, Ameriprise Bank. Ameriprise Financial Services and the AFIG financial advisor may serve as a finder related to trust services and may receive a referral fee for business referred to unaffiliated trust providers. Ameriprise Financial Services is not a bank or credit union. Any services or products you purchase through an AFIG financial advisor are not guaranteed or insured by Ameriprise Financial Services or the financial institution. The financial institution is not a party to your Client Agreement with us. Ameriprise Financial Services and each financial institution have entered into a networking agreement under which 9 we have agreed to share fees and commissions with the financial institution, including Asset-based Fees charged for investment advisory services. Non-registered employees of the financial institution may also receive compensation for referring you to Ameriprise Financial Services. How we get paid For RPCS Ameriprise Financial Services collect the RPCS Fee and we do not collect additional revenue based on investments recommended to be held by a plan. For accounts held at Ameriprise Financials Services, we and our affiliates receive revenue from several different sources on the products and services available for purchase in our managed accounts, Ameriprise brokerage accounts, or other products and services made available through Ameriprise Financial Service or our affiliates. These account types and services are not included as part of RPCS. More information about payments for cost reimbursement services and marketing support payments received by us and our other affiliates, including a description of conflict of interest, is available for Ameriprise brokerage accounts at https://www.ameriprise.com/bestinterest and for managed accounts at https://www.ameriprise.com/disclosures and clicking on the sub­heading “Managed Account Client Disclosure Brochures”. Revenue sources for Ameriprise Financial Services, LLC Financial planning and advisory service fees. These are fees you pay for financial planning and fee­based investment advisory account services, respectively. Ameriprise brokerage account sales charges. Sales charges, commissions and/or selling concessions are paid when you buy or sell equities or fixed income products including corporate bonds and municipal securities, mutual funds, ETFs, 529 plans, closed­ end funds, preferred securities, UITs, non­traded REITs, non­traded BDCs, non­traded closed­end funds, hedge fund offerings, exchange funds, private equity offerings, managed futures funds, real estate private placement offerings and structured products. In addition, you may pay a markup or markdown in bond transactions executed in a principal capacity with AEIS. These charges vary by product and product type. For example, with respect to mutual funds, the sales charge for a stock mutual fund is typically greater than that for a bond mutual fund. For other product types such as non­traded REITs, the sales charge you pay may also include a portion of the distribution, organization and offering fees and expenses. Periodic Fees. Periodic fees include IRA custodial fees, brokerage fees (i.e., account maintenance and order handling fees), and a portion of the fees associated with certain banking products and services (i.e., personal trust services). Sales charges, trading commissions, markups, markdowns and financial planning and advisory services fees are not eligible for reimbursement or offered at a discount. Periodic expenses. Periodic expenses are paid from product assets, such as 12b­1 shareholder servicing fees paid from mutual fund assets (including 12b­1 fees paid on certain funds that serve as underlying investment options for 529 plan assets) and distribution fees paid from Ameriprise Certificate Company assets. 12b­1 shareholder servicing fees assessed in Ameriprise brokerage accounts may be used to pay for marketing, distribution and shareholder service expenses. Any 12b­1 shareholder servicing fees received for the share class utilized in any Managed Accounts will be rebated to clients. Ameriprise Preferred Line of Credit and Loan. Ameriprise Financial Services receives compensation from Ameriprise Bank of 0.25% on an annualized basis of the amount of the credit line or loan outstanding balance. This amount is shared with your Ameriprise financial advisor based on how your advisor is affiliated with us and on the payout rate for which your financial advisor qualifies. These affiliations and compensation structures are described in the “Financial Advisors Compensation & Benefits” section of this Brochure. Ameriprise Bank Savings Account and CDs. Ameriprise Financial Services receives compensation from Ameriprise Bank of 0.05% on an annualized basis of the amount of the average monthly balance. This amount is shared with your Ameriprise financial advisor based on how your advisor is affiliated with us and on the payout rate for which your financial advisor qualifies. These affiliations and compensations structures are described in the “Financial Advisors Compensation & Benefits” section of this Brochure. Payments for referrals to structured settlements annuity brokers. Ameriprise Financial Services receives a fee, shared with financial advisors, for referrals to non­affiliated structured settlement professionals for both client and non­client 10 referrals. The amount and basis for the referral fee varies by relationship multiplied by the notional sales amount of the product. Financial interest in products Ameriprise Financial Services has a financial interest in the sales of proprietary products that are manufactured by its affiliates. Ameriprise Financial Services and its affiliates receive more revenue from the sale of some financial products and services, particularly those products and services sold under the Ameriprise, Columbia Threadneedle Investments and RiverSource brands, than for the sale of other products and services. Generally, Ameriprise Financial Services receives more revenue for securities or products sold in a fee­ based account than for those sold with only a sales charge or commission. Higher revenue generally results in greater profitability for Ameriprise Financial Services. Employee compensation (including management and field leader compensation) and operating goals at all levels of the company are tied to the company’s success. Management, sales leaders and other employees generally spend more of their time and resources promoting Ameriprise, Columbia Threadneedle Investments and RiverSource branded products and services. Economic benefits of affiliates’ products and services As with all financial services firms, a portion of our revenue and compensation can generate a profit for the firm. The revenue and compensation we receive helps us cover our expenses in providing and servicing these products and services. Employee and financial advisor compensation and operating goals at all levels of Ameriprise Financial Services are tied to the success of its businesses. As a result, certain incentives and conflicts of interest may exist for Ameriprise Financial Services, our affiliates and our financial advisors if you purchase certain products or services recommended by your financial advisor. Generally, among other things, Ameriprise Financial Services and our affiliates will receive: • More revenue, in aggregate, from the purchase of products sponsored or managed by Ameriprise, Columbia Management and RiverSource (“proprietary products”) than from the purchase of products sponsored or managed by firms that aren’t affiliated with Ameriprise Financial Services (“nonproprietary products”). Ameriprise Financial Services actively promotes the products of our affiliates through advertising, direct mail, and product support and training events. • More revenue from the purchase of products and services than from Asset­based Fees. • More revenue as the size of any margin account or Ameriprise Preferred Line of Credit and Loan balance increases. • More revenue when you purchase certain types of products, such as insurance and annuity products and direct investments. • More revenue from products and services that generate ongoing revenue streams, such as mutual funds that pay ongoing 12b­1 fees, an investment advisory account service, and insurance and annuity products with mortality and expense charges. • More revenue when you purchase shares of mutual funds or 529 plans from Full Participation Firms than from firms with other distribution support relationships, as described in the “Cost reimbursement services and third-party payments” section of the Ameriprise Managed Account Client Disclosure Brochure. • More revenue when you purchase investment products for which we receive cost reimbursement payments or have similar financial arrangements, as described in the “Cost reimbursement services and third-party payments” and “Revenue sources for Ameriprise Financial Services, LLC” sections of the Ameriprise Managed Account Client Disclosure Brochure. • Less revenue when a sales charge or commission is reduced or waived completely, or where there is no sales charge. • More revenue when you move assets (including retirement plan accounts) from another institution to Ameriprise Financial Services or RiverSource or into a product managed by Columbia Management or another affiliate. Financial advisors are required to take training on complex products developed by Ameriprise Financial Services and its affiliates and non­affiliated product manufacturers, prior to soliciting certain insurance and annuity products and a targeted subset of nonproprietary products. Additional general product training is available and specific product training is required for a number of complex products, including Columbia Threadneedle Investments and RiverSource branded products. It is likely that a product recommendation from your financial advisor will be drawn from the universe of products on which they were trained. Ameriprise Financial Services may enter into strategic 11 alliances with companies that offer products or services that Ameriprise Financial Services and its financial advisors do not sell. As part of those alliances, Ameriprise financial advisors may receive gifts or non­cash compensation from the other companies, which are subject to SEC and FINRA regulations as well as Ameriprise Financial Services’ internal compliance policies. Some, but not all, of the software tools available for use by your financial advisor were developed by Ameriprise Financial Services or by unaffiliated third parties and may make it more convenient for your financial advisor to select proprietary products. Most Ameriprise financial advisors are also appointed agents of RiverSource Life Insurance Company and, in New York only, RiverSource Life Insurance Co. of New York, affiliates of Ameriprise Financial Services. Ameriprise Financial Services grants RiverSource access to Ameriprise financial advisors and provides RiverSource with limited information related to Ameriprise clients to promote sales of RiverSource products and to assist financial advisors in understanding the features and benefits of those products. Ameriprise Financial Services does not grant this access to other non­affiliated companies offering similar products, thus they do not have the same access to financial advisors as RiverSource. Additionally, it is possible that Ameriprise Bank would send an order on behalf of a trust account to AEIS and at the same time AEIS would execute the opposite order for a brokerage client. Investments may be made for Ameriprise Bank’s trust accounts in which Ameriprise Financial Services or its related persons have a position or interest. Although Ameriprise Financial Services and its related persons may own securities suitable for or held by clients, in no case will holdings of Ameriprise Financial Services, its subsidiaries or their employees or directors be directly sold to or purchased from Ameriprise Bank’s trust accounts. AEIS, an affiliate of Ameriprise Financial Services, may buy or sell for its own account securities that Ameriprise Financial Services may recommend for Ameriprise Bank’s trust accounts. Ameriprise Financial Services does not anticipate that conflicts of interest will arise because we have adopted policies and procedures prohibiting Ameriprise Financial Services and our related persons from engaging in trading activity that creates a conflict of interest with our clients, as discussed in the “Code of Ethics, Participation or Interest in Transactions and Personal Trading” section. Financial Advisors Compensation & Benefits The compensation programs for our financial advisors may vary based on, among other factors, the financial advisor’s industry experience, tenure with Ameriprise Financial Services, the type of practice structure (solo or team), and whether the financial advisor was formerly associated with a firm acquired by Ameriprise Financial, Inc. An Ameriprise financial advisor is assigned to every investment advisory service. Ameriprise financial advisors have a wide range of business and educational backgrounds. They are required to have appropriate licenses and registrations to transact business, including Financial Industry Regulatory Authority (“FINRA”) registration, required state securities and insurance licenses and carrier appointments and, where required, a state investment adviser representative registration. Many financial advisors hold advanced academic degrees and/or professional designations, including the Certified Financial Planner™ (CFP®) designation. In addition, ongoing training is available to financial advisors. For additional important information about an advisor check FINRA BrokerCheck at www.finra.org/brokercheck or call 800.289.9999. Your financial advisor earns a living by providing you with financial advice and product recommendations to suit your goals. To understand how your financial advisor gets paid, you should first know that there are four ways Ameriprise financial advisors can be affiliated with us. • Independent contractor franchisees. These financial advisors are not employed by Ameriprise Financial Services and they do not receive a salary from us. • Employee financial advisors. These financial advisors are employed by Ameriprise Financial Services. • Associate financial advisors. These financial advisors are employed by or contract with the independent contractor franchisees and they do not receive a salary or other compensation from Ameriprise Financial Services. • Financial institution employee financial advisors. These financial advisors are employed by the financial 12 institution where they provide services and are compensated by the financial institution from the portion of fees and commissions it receives from Ameriprise Financial Services. The financial institution serves as paying agent for such compensation on our behalf in accordance with applicable law. Financial institution employee financial advisors’ compensation is based on their employment agreement with the financial institution. All Ameriprise financial advisors are licensed registered representatives. Depending on the affiliation, our financial advisors are compensated differently. Financial advisors may choose to change how they are affiliated with Ameriprise Financial Services over time. Salary and Bonus. In addition to the fees described below, employee financial advisors may receive a salary or wage from Ameriprise Financial Services. Associate financial advisors may receive either a salary or a flat fee from the independent contractor franchisee for whom they work, at the discretion of the employing or contracting independent contractor franchisee. Financial advisors may also have the potential to receive bonus compensation. At the discretion of the employing or contracting independent contractor franchisee, the associate financial advisor may receive a bonus. Advisory Fees and Compensation. The RPCS Fee and any applicable Advisory Fee you pay in your Managed Account is shared between Ameriprise Financial Services and your financial advisor as further described below. Both independent contractor franchisee financial advisors and employee financial advisors receive a portion of the Advisory Fee. Independent contractor franchisee financial advisors, however, receive a higher portion, or payout rate. A portion of the RPCS Fee and Advisory Fee is paid to your financial advisor for introducing you to the service, gathering the information necessary to prepare your service, helping you establish needs and goals, preparing and presenting your service, and/or providing financial advice on behalf of Ameriprise Financial Services. The remaining portion of the fees goes to Ameriprise Financial Services for the supervisory, technical, administrative and other support that is provided to all financial advisors. The portion of fees retained by Ameriprise Financial Services differs by the type of investment advisory program. The actual portion of the RPCS Fee and Advisory Fee paid to your financial advisor depends on the payout rate for which your financial advisor qualifies and the amount of Asset­based Fees you pay. Only a component the Advisory Fee component of your Aset­based Fee, is shared with your financial advisor. • Independent contractor franchisees generally receive 72% to 91%, and employee financial advisors generally receive 0% to 46% of the advisory service fees and product commissions we receive (the “advisor payout rate”). In addition, the financial advisor may qualify for a bonus which could increase the effective advisor payout rate up to 91% for independent contractor franchisees and 57% for employee financial advisors, respectively. • Financial institution employee financial advisors generally receive an advisor payout rate of 0% to 91% • • based on their employment agreement with the financial institution. If you are a client of the Ameriprise Personal Wealth Group, your employee financial advisor does not receive a portion of the fees but may receive compensation in the form of a bonus based in part on revenue generated through your RPCS Fee or Advisory Fee. In general, fees generated by an associate financial advisor are paid to the employing or contracting independent contractor franchisee. At the discretion of the employing or contracting independent contractor franchisee, the associate financial advisor may receive financial advisory or referral fees. Importantly, financial advisor compensation does not vary depending upon the investment(s) recommended to you within a Managed Account. However, the amount of this compensation may be more or less than what your financial advisor would receive if you paid separately for investment advice, brokerage and other transaction­based services. Therefore, your financial advisor may have a financial incentive to recommend a Program over a transaction­based brokerage account. Ameriprise Financial Services seeks to address this conflict of interest through a combination of disclosures and through our policies, procedures and supervision, related to the review and determination that a Managed Account is appropriate for you based on your financial and risk profile information and investment objectives (“Client Information”) in accordance with all applicable regulatory requirements. Other Compensation Available to Financial Advisors 13 The compensation programs for our financial advisors may vary based on, among other factors, the financial advisor’s industry experience, tenure with Ameriprise Financial Services, the type of practice structure (solo or team), and whether the financial advisor was formerly associated with a firm acquired by Ameriprise Financial Services. Ameriprise Financial Services offers a vast range of investment solutions to clients. Some products and services may be offered only by certain Ameriprise financial advisors. Discuss with your financial advisor the products he or she offers and the compensation your financial advisor receives, as some investment product companies and issuers, including RiverSource, may pay higher compensation than others. Generally, among other things, your financial advisor may earn: • More depending on how your financial advisor is affiliated with Ameriprise Financial Services, as described above • More on the sale of certain fixed life and disability insurance products because of special compensation programs that provide increasing levels of compensation the more a financial advisor sells of these products from each individual insurance company. • More on the purchase of annuity and insurance products and direct investments, because they are more complex than other products and take more time to service. • More revenue from products and services that generate ongoing revenue streams, such as mutual funds that pay ongoing 12b­1 fees, an investment advisory account service, and insurance and annuity products with mortality and expense charges. • More from certain sales incentive programs to increase overall assets under management. • Less on individual purchases within a transaction­ based brokerage account because of the higher transaction charges your financial advisor pays on these accounts compared to a fee­based investment advisory account. • Less when a sales charge or commission is reduced or waived completely, or where there is no sales charge. • Typically, less when you exchange an existing annuity contract, mutual fund or insurance policy for certain like or similar products from the same company, unless you have held the existing product for a certain period of time. • More revenue if you purchase securities on margin that you could not otherwise purchase in a cash account. • A higher payout rate based on the level of product sales, on the number of financial plans sold, and on higher face value and/or death benefit amount for certain insurance products. • More when you move accounts (including retirement plan accounts) from another institution to • Ameriprise Financial Services, CMIA or RiverSource. If your financial advisor is a shareholder of Ameriprise Financial through our deferred compensation program, more compensation the more profitable the firm is. • Compensation for servicing trust accounts held with Ameriprise Bank. • Compensation for performing certain activities associated with your mortgage if that loan is purchased and serviced by Ameriprise Bank. • Compensation for providing services related to your Ameriprise Preferred Line of Credit based on an annualized fixed percentage of the client’s average daily outstanding balance. • Compensation for your Ameriprise Bank Savings Account and CD balances based on an annualized fixed percentage of the client’s average monthly balance. • Compensation for marketing that leads to you opening a co­branded credit card account provided you activate the card and meet the initial spend requirements. • Compensation for marketing that leads to your opening of an Ameriprise Bank Checking Account provided you meet the initial funding and other balance duration requirements. • Compensation for the sale or renewal of Ameriprise Certificates. Financial Advisors Compensation - Insurance and Annuity Products Our financial advisors primarily offer life, and disability insurance and annuity products from RiverSource and certain pre­approved, but unaffiliated, insurance companies. However, in some situations where the client’s needs may be met 14 more effectively by another company’s product, and RiverSource and other pre­approved providers do not offer such a product, Ameriprise financial advisors may offer insurance products issued by unaffiliated insurance companies. If an unaffiliated insurance product is offered, the financial advisor is an appointed agent of the insurer and receives, directly or indirectly, compensation from the unaffiliated insurer for the sale and service of that product. The compensation for these nonproprietary products and RiverSource products is separate from, and in addition to, any fee you pay for investment advisory services and may vary depending on the type and size of the life insurance or annuity product that you purchase, the insurer that issues the product, and other factors. This compensation typically will increase as the size of the insurance policy or annuity contract increases, or the amount of the payments that you make on the life insurance or annuity product increases. Generally, the compensation that the financial advisor will receive is calculated by a formula. Compensation may also increase as the financial advisor sells increasing amounts of life and disability income insurance products issued by that insurer. In instances where a customer already owns a financial product sold by Ameriprise Financial Services, the amount of a financial advisor’s compensation may vary in connection with the sale of an additional or replacement product, due to formulas relating to the cancellation of a product that is already owned. As a result, the financial advisor in such a transaction may have an incentive to recommend the purchase of additional or replacement insurance or annuity products or, conversely, an incentive to recommend that you not purchase additional or replacement insurance or annuity products, depending on the relevant compensation formula. Financial Advisors Compensation - Credit Products & Insurance Referral Your financial advisor receives compensation for the marketing that leads to your opening of a co­branded credit card account provided you activate the card and meet initial spend requirements. Ameriprise financial advisors will earn compensation for providing services related to your Ameriprise Preferred Line of Credit and Loan based on an annualized fixed percentage of the client’s average daily outstanding balance. Your financial advisor will receive compensation for performing certain activities associated with your mortgage if that loan is purchased and serviced by Ameriprise Bank. Your financial advisor receives referral fees when you purchase and maintain Ameriprise Auto and Home insurance products under a long­term distribution agreement between Ameriprise Financial Services, American Family Insurance Group and Ameriprise Auto & Home. Ameriprise Auto & Home is not affiliated with Ameriprise Financial Services and is owned by the American Family Insurance Group. However, Ameriprise Auto & Home Insurance and the associated logo are being used by American Family Insurance Group under a temporary license from Ameriprise Financial. If Ameriprise Bank accepts a trust based upon a referral from your financial advisor, Ameriprise Financial Services will receive a referral fee from the Bank. A portion of this referral fee is shared with your financial advisor. The referral fee is paid by the Bank from the fees earned for its services and is not an additional cost to the trust account. Your financial advisor also receives a referral fee for referrals to non­affiliated structured settlement professionals for both client and non­client referrals. Financial Advisors Compensation - Incentives, training and education. Product companies with which we have agreements work with Ameriprise Financial Services and our financial advisors to promote their products. They may pay for training and education events or due diligence meetings; and may reimburse expenses for prospecting events such as seminars for employees, financial advisors, clients and prospective clients. For employees and financial advisors, these events may be held at off­site locations, and the travel, meals and accommodations may be paid for by the product company. Additionally, product companies may occasionally provide business or recreational entertainment or gifts of nominal value to employees and financial advisors. Ameriprise Financial Services or sales leaders may, from time to time, offer contests or incentive programs to individual financial advisors or groups of financial advisors in particular areas. These contests and programs are limited to such targets as new client acquisition, financial plan count, net flows, total assets under management and financial advisor recruiting. Single product or product categories are not eligible for sales contests or incentive programs with the exception of fixed life and disability insurance. These programs and incentives and the receipt of other cash/noncash compensation could affect your financial advisor’s recommendations of products and/or services to you. These programs and incentives and other cash and/or noncash compensation are subject to SEC 15 and FINRA regulations as well as Ameriprise Financial Services’ internal compliance policies. Financial Advisors Compensation - Recruitment Ameriprise Financial Services, from time­to­time recruits financial advisors from other firms to join Ameriprise Financial Services. In connection with these recruiting efforts, Ameriprise Financial Services may enter into arrangements with financial advisors for the payment of compensation and/or loans based upon the value of eligible assets or accumulated production of the recruited financial advisor at a pre­determined measurement date. The funds may be payable immediately, over time, as a bonus, or as a loan. These arrangements may have been structured to include a provision requiring that payment of transition compensation and/or loans would be dependent upon the advisor meeting certain agreed upon production and/or asset level benchmarks. The financial incentives associated with these transition arrangements could influence the type and amount of product and/or service recommended by your financial advisor. Ameriprise Financial Services manages this conflict of interest by supervising the suitability of recommendations made by its financial advisors in accordance with all applicable regulatory requirements. Please review your financial advisor’s Form ADV brochure supplement or ask your advisor if you have questions about whether these transition arrangements apply to them. From time to time, Ameriprise Financial Services also provides compensation to financial advisors in connection with the sale of all or a portion of their client base to an Ameriprise financial advisor. Some of this compensation may be dependent on a certain percentage of the client base remaining as clients of Ameriprise Financial Services for a certain period of time. It is also determined based on valuations of the financial advisor’s practice, or book of business. The practice valuation formula results in higher compensation for revenues received from Managed Accounts versus Ameriprise brokerage accounts. As a result, your financial advisor has an incentive to recommend the opening of new Managed Accounts or the investment of additional assets into existing Managed Accounts or, conversely, an incentive to recommend that you not open an Ameriprise brokerage account or invest additional assets into a brokerage account. In addition, if your financial advisor is selling all or a portion of their practice to another Ameriprise financial advisor, this program could incent your financial advisor to recommend you remain a client of the acquiring financial advisor and/or Ameriprise Financial Services. Ameriprise Financial Services equity programs. We encourage our financial advisors to take an ownership stake in our future by holding stock in our parent company, Ameriprise Financial, Inc. (NYSE: AMP). To make this possible for financial advisors, we have created equity compensation programs for them. Employee financial advisors and independent contractor franchisees may be eligible to receive an annual stock bonus. In addition, independent contractor franchisees may be eligible to defer a certain percentage of their compensation each year. They may choose to invest all or portion of this deferral into a notional account that tracks the performance of Ameriprise Financial, Inc. stock. Financial advisors who are independent contractor franchisees may build equity in their practices and may receive payments if they sell all or a part of their practices to other Ameriprise financial advisors. Loan programs. Clients may have access to information about lending products and services through marketing and/or lending relationships Ameriprise Bank has with third­party financial institutions. Financial advisors do not earn compensation related to the origination or referral of lending products (e.g., mortgages) offered and originated by third­party providers. Ameriprise Bank partners with Rocket Mortgage, LLC (NMLS#3030) that offers mortgage lending products and services. Ameriprise Financial Services and Ameriprise financial advisors do not accept any mortgage loan applications or offer or negotiate terms of any such loans. Financial advisors do not earn compensation related to the origination or referral of mortgage lending products offered and originated by such third­party providers. Ameriprise Bank may purchase and service some loans originated by Rocket Mortgage, LLC. Ameriprise Financial Services and Ameriprise financial advisors may receive compensation for assisting clients with mortgages serviced by Ameriprise Bank. Ameriprise Financial, Inc. is not affiliated with Rocket Mortgage, LLC. Ameriprise Bank does not guarantee products or services offered by Rocket Mortgage, LLC. Ameriprise Bank has partnered with Elan Financial Services in offering Ameriprise co­branded credit cards. Your financial advisor receives compensation for marketing efforts that lead to your opening of a co­branded credit card account provided you activate the card and make sufficient purchases. Ameriprise Bank has partnered with Goldman Sachs to make available the Ameriprise Preferred Line of Credit and Loan. Ameriprise financial advisors will earn compensation for providing services related to your Ameriprise 16 Preferred Line of Credit and Loan based on an annualized fixed percentage of the client’s average daily outstanding balance. Apart from margin lending offered by AEIS, neither your Ameriprise financial advisor nor Ameriprise Financial Services may arrange, promote, suggest or knowingly permit you to use line or loan proceeds to purchase securities or other investment products. Advisor-to-advisor training programs. Ameriprise Financial Services or its affiliates may also pay its financial advisors for training other financial advisors on specific products and services that we offer. A portion of this payment may be based on incremental sales of these products and services sold by the financial advisor receiving the training. Shared compensation. Financial advisors may also choose to work together as a team to share fees and commissions generated from products and services you purchase. The cost of the product or service you purchase is not affected by the fact that your financial advisor is a member of a team or by the fact that the fee or commission may be split. Your financial advisor may be allowed to share a portion of the Asset­based Fee he or she receives with one or more other Ameriprise financial advisor(s), including financial advisors who have not completed the Ameriprise Financial Services required training to sell the investment advisory service, franchise consultants or registered principals, as described below. In cases where two or more financial advisors are assisting you, both financial advisors may share in the Asset­ based Fee. Your servicing financial advisor will present the Managed Account or RPCS, set the Asset­based Fee, and oversee the analysis and advice prepared for you. Your servicing advisor may or may not be the financial advisor authorized to use discretion to purchase and sell securities in your account, e.g., your SPS Discretionary Advisor. In the instance that your servicing advisor is not authorized to use discretion, the financial advisor authorized to use discretion will oversee the analysis and advice prepared for you. Only the financial advisor authorized to use discretion will purchase and sell securities in our Account. Your servicing advisor may or may not be the financial advisor who has completed the required training. A financial advisor who has not completed the required training may refer a client to a financial advisor who has completed the required training for the service or product. The financial advisor who has completed the required training may pay a fee to the financial advisor who has not completed the required training for that referral. The financial advisor who has not completed the required training may provide investment advisory services for services and products that do not require training, however, only the financial advisor who has completed the required training required for a particular service or product will provide the analysis and advice prepared for you with respect to a service or product that requires the training. The financial advisor who has not completed the required training may receive a share of the commission from any services or products sold to you by your financial advisor who has completed the required training. Your financial advisor may work with a franchise consultant. In those situations, the franchise consultant, who is registered with Ameriprise Financial Services, may receive compensation based on services and products that you purchase, and for the training and leadership of your financial advisor. The cost of the product or service you purchase is not affected. Your financial advisor may employ staff or work with other Ameriprise Financial Services staff to assist with creating your financial planning recommendations. This may include leveraging services in geographic locations outside of your financial advisor’s location, including international locations. Services provided may include entering data into financial planning software, providing initial calculation and assistance in creating solutions. Your financial advisor will provide final recommendations to you. For these services your financial advisor may pay a fee or salary to employed staff. Financial advisors and field leaders may share compensation with their registered support assistants or recommend bonuses for their non­registered support staff. Employee financial advisors and selling leaders may receive continuing commissions and fees for the sale of certain products and services for up to five years after leaving the securities industry. Ameriprise offers a Business Development Account (BDA) Program. Eligible employee financial advisors may create a voluntary BDA in a predetermined amount and use this account for business­related expenses above and beyond what the company provides. Management compensation and bonus programs. Employee compensation and operating goals at all levels of the company are tied to the company’s success. All employees, directly or indirectly, may receive higher compensation and other benefits when the investment products of certain providers, particularly affiliates, are 17 purchased. Management, sales leaders and other employees spend more of their time and resources promoting Ameriprise, Columbia Threadneedle Investments, and RiverSource branded products and services. Field leaders receive a salary and a bonus and are responsible for an operating budget for expenses. Bonus programs for Ameriprise Financial Services field leaders are designed to include an amount based on the aggregate sales of all products sold by financial advisors, including proprietary products, in the regions of the country those leaders are responsible for overseeing. The bonus incentive and expense programs present a potential conflict because they are based in part on sales of these products. Code of Ethics, Participation or Interest in Transactions and Personal Trading Code of ethics As part of an overall internal compliance program, Ameriprise Financial Services has adopted policies and procedures imposing certain conditions and restrictions on transactions for the account of Ameriprise Financial Services and the accounts of our employees. Such policies and procedures are designed to prevent, among other things, any improper or abusive conduct when potential conflicts of interest may exist with respect to a customer or client. In addition, from time to time, restrictions are imposed to address the potential for self­dealing and conflict of interest which may arise in connection with the business of Ameriprise Financial Services as a broker­ dealer. Ameriprise Financial Services has adopted various procedures to guard against insider trading. Participation or interest in client transactions From time­to­time Ameriprise Financial Services and/or its affiliates and related persons may invest in the same or related securities that Ameriprise Financial Services and/or its affiliates recommend to clients. Such transactions may occur at or about the same time that such securities are bought or sold for client accounts. Ameriprise Financial Services has adopted policies and procedures imposing certain conditions and restrictions on transactions in these securities, such as trading blackout periods and preclearance requirements. See the “Financial interest in products” subsection in the “Revenue Sources for Ameriprise Financial Services, LLC” section in this Disclosure Brochure for more information about our financial interest in the sale of certain products and services. Personal trading rules and procedures Ameriprise Financial Services has adopted personal trading rules and procedures within the Ameriprise Financial Code of Ethics and Personal Trading Policy. These rules are designed to list standards of business conduct and to mitigate potential conflicts of interest for all persons of Ameriprise Financial Services when they engage in personal securities transactions. You may request a copy of the Ameriprise Financial Code of Ethics and Personal Trading Policy from your financial advisor or by contacting us at 800.290.6663. The standards of business conduct include compliance with applicable laws and regulations and with policies and procedures such as those contained in the Ameriprise Global Code of Conduct. Under the personal trading rules, persons are required to report their personal securities holdings and transactions, including transactions in certain mutual funds; must pre­clear certain investments; are restricted with respect to the timing of certain investments; and are prohibited from making certain investments. In addition, the Personal Trading Policy requires (i) Ameriprise employee financial advisors and their employees, (ii) its independent contractor franchisee financial advisors and their employees, and (iii) its affiliated investment advisers to conduct most personal trades through one of three designated broker­ dealers unless an exception has been granted, and report any changes in their selected broker­dealer. Insider trading policy Ameriprise Financial Services and its related persons may, from time to time, come into possession of material nonpublic information that, if disclosed, might affect an investor’s decision to buy, sell or hold a security. Under applicable law, Ameriprise Financial Services and its related persons are prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other person, regardless of whether such other 18 person is a client. Accordingly, should Ameriprise Financial Services or its related persons come into possession of material nonpublic information with respect to any company, they may be prohibited from communicating such information to, or using such information for the benefit of, their respective clients, and have no obligation or responsibility to disclose such information to, nor responsibility to use such information for the benefit of, their clients when following policies and procedures designed to comply with law. Ameriprise Financial Services and its affiliates have adopted an “Insider Trading Policy” in accordance with Section 204A of the Advisers Act that establishes procedures to prevent the misuse of material nonpublic information by Ameriprise Financial Services and its associated persons. Brokerage Practices Ameriprise Financial Services does not receive research or other products or services other than execution from any unaffiliated broker­dealer or other third party for client securities transactions. Ameriprise Financial Services receives and distributes research authored by its affiliate AEIS; however, this research is not provided for client securities transactions or for any other compensation. Nor do we or our affiliates receive client referrals from broker­dealers or third parties that are considered in selecting or recommending broker­dealers. Retail brokerage services are not made available through Ameriprise Financial Services as part of RPCS. Review of Accounts Certain supervisory functions are performed by Ameriprise Financial Services corporate office personnel. Corporate registered principals review a sampling of financial advisor’s recommendations, including written RPCS recommendations periodically based on certain key factors. When appropriate, our corporate registered principals may also decide to call you directly to discuss your understanding of RPCS, including the fees and expenses you will be paying. Our Compliance department also conducts routine surveillance of financial advisor activities. An important part of an RPCS engagement involves providing you with the opportunity to engage in periodic reviews with your financial advisor or a designated member of the team servicing your RPCS. In these reviews, you and your financial advisor should discuss any changes to your plan’s circumstances, financial situations, investment objectives and/or risk tolerance. Our supervision and surveillance do not substitute for your continued review and monitoring of your RPCS services. You should review your account statements and other information we send to you. If you have any questions, please discuss them with your financial advisor. Client Referrals and Other Compensation Referral arrangements and other economic benefits In certain circumstances your financial advisor may refer you to another retirement plan services provider. In this case, the advisory fees you pay the third­party retirement plan services provider are shared with Ameriprise Financial Services on a fully disclosed basis, as well as your financial advisor, as described in the “Financial Advisors Compensation & Benefits” section of this Brochure. Ameriprise Financial Services maintains formal and informal arrangements, the terms of which are disclosed to the client, with individual professionals, professional firms, and select corporate, institutional or membership organizations (“Promoters”). For each such arrangement, Ameriprise Financial Services pays the Promoter for referral of their clients or members to Ameriprise Financial Services for its financial advisory services. The manner and amount of compensation to be paid in connection with these agreements is subject to negotiation between Ameriprise Financial Services and the applicable Promoter. Prospective clients are provided with the applicable disclosures, including whether the Promoter is a client, the material terms of compensation (if any) and the material conflicts of interest (if any), that results from the Promotor’s relationship with Ameriprise Financial Services. The most common compensation arrangements include a flat fee at the time of the referral, a recurring flat fee, or a sharing of a portion of any total Asset­based Fees. You will not be charged an additional fee as a result of any referral arrangements. Compensation may include a one­time payment or ongoing payments for the duration of the investment advisory relationship. 19 Ameriprise Financial Services may form alliances and networking arrangements with financial institutions such as community banks, credit unions, credit union service organizations, Farm Credit Services and trust service providers (“Third­Party Financial Institutions”) to allow its financial advisors to offer investment advisory services, financial planning services and certain other non­deposit investment and insurance products and services, (described elsewhere in this Brochure), to retail customers or members of the Third Party Financial Institutions. Under the terms of these alliances or networking arrangements, financial advisors may not be able to offer to retail customers or members of the Third­Party Financial Institutions certain products that are otherwise available through Ameriprise Financial Services or its affiliates. Also, because of these alliances or networking arrangements, Third­Party Financial Institutions may receive, in the form of a networking payment, a portion of Asset­based Fees and securities and insurance commissions paid to financial advisors for sales to retail customers or members of the Third­Party Financial Institutions. Ameriprise Financial Services has entered in partnership with Renaissance Charitable Foundation Inc. (“RCF”) for the referral of clients or prospects that have indicated an interest in establishing and maintaining a donor advised fund made available through RCF. No referral fee is paid by RCF to Ameriprise Financial Services or financial advisors however donor advised funds established by RCF because of the referral generally invest in eligible Managed Account Programs that are advised and serviced by the referring financial advisor. The administration fee that you pay RCF for a donor advised fund solution may be more or less than if you were to purchase the donor advised fund services from RCF or another non­profit organization. Any fees charged by RCF for the administration of the donor advised fund are not shared with Ameriprise Financial Services or financial advisors. Ameriprise Financial Service and your financial advisor will receive Asset­based Fee revenue from a donor advised fund established by RCF and invested in a Managed Account Program and no revenue if donor advised fund assets are invested with a third­party investment adviser, whether through RCF or another non­profit organization. We seek to address this conflict of interest through a combination of disclosure and through our policies, procedures and supervision related to the determination that a referral to RCF is appropriate for you based on your Client Information, and by treating assets in Managed Accounts owned and administered by RCF and assets in Managed Accounts owned directly by you as separate and distinct advisory relationships in accordance with all applicable regulatory requirements. Review of issuers of financial products Ameriprise Financial Services and its affiliates have policies and procedures in place to review the issuers of financial products such as alternative investments in non­traded REITs, non­traded BDCs and non­traded CEFs, structured notes, and annuity and insurance products that Ameriprise Financial Services permits its financial advisors to recommend to some or all of its clients. This review includes publicly available information and reports issued by third parties and may in some cases include certain nonpublic information provided by the issuer. Ameriprise Financial Services periodically reassesses, but does not continuously monitor, the creditworthiness or financial solvency of third­party issuers. These policies and procedures are reasonably designed to mitigate our clients’ exposure to credit and default risks resulting from an inability of the issuer to repay the principal on a note or fulfill an insurance obligation. However, you should be advised that credit markets can be volatile and the creditworthiness of an issuer may change rapidly. Ameriprise Financial Services, as a seller of these products, is prohibited by regulation from guaranteeing or providing any assurance that an issuer of financial products will be able to fulfill the issuer’s obligation to any purchaser of such a product through Ameriprise Financial Services. Revenue sources for RiverSource Sales charges. You pay sales and other charges under RiverSource variable annuity contracts and life insurance policies. You may incur transaction costs or fees associated with structured annuities. You may pay a contingent deferred sales charge, or surrender charge, if you withdraw funds during the applicable period. Periodic fees and expenses. You pay certain fees and expenses under RiverSource annuity contracts, life insurance policies and disability income insurance policies, including (depending on the type of contract or policy) mortality and expense, administrative, policy, contract, and cost of insurance fees or charges, in addition to costs associated with certain riders that may be available for both fixed, structured and variable products. Periodic expenses are also paid from product assets, such as 12b­1 fees paid on certain funds that serve as underlying investment options for variable annuities and variable life insurance. 12b­1 fees may be used to pay for marketing, distribution and shareholder service expenses. 20 Investment and interest income. Investment and interest income from insurance company general account assets derived, in part, from the amounts you pay for insurance and annuity benefits. Variable annuity and variable life insurance financial arrangements. RiverSource selects the funds available within your variable annuity contract or variable life insurance policy. In doing so, RiverSource may consider various objective and subjective factors. These factors include compensation RiverSource may receive from fund assets (for those funds with 12b­1 plans); assets of the fund’s adviser, subadviser or an affiliate of either; and assets of the fund’s distributor or an affiliate. This compensation benefits RiverSource. The amount of this revenue varies by fund, may be significant and may create potential conflicts of interest for RiverSource. The greatest amount and percentage of revenue that RiverSource receives comes from assets allocated to subaccounts investing in funds managed by its affiliates, CMIA, and Columbia Wanger Asset Management. In general, the revenue directly related to assets under management that RiverSource receives currently ranges up to 0.65% of the average daily net assets invested in the underlying funds through the variable annuity or variable life insurance contracts RiverSource issues. This revenue is in addition to revenues RiverSource receives from the charges you pay when buying, owning or surrendering your variable annuity contract or life insurance policy. In accordance with applicable laws, regulations and the terms of the agreements under which such revenue is paid, RiverSource may receive this compensation for various purposes including financial advisor training and compensation, marketing and distribution, customer servicing, transaction processing, record keeping, and other administrative services. Revenue sources for Columbia Management and Threadneedle Periodic fees and expenses. Columbia Management and Threadneedle International Limited may receive management fees and certificate advisory and services fees for services, including, with respect to Columbia Management. These revenues may be received from the Columbia Funds, Columbia ETFs, Columbia closed­end funds, Ameriprise Certificates and from other affiliated and nonaffiliated advisory clients of Columbia Management and Threadneedle International Limited. Revenue sources for other Ameriprise Financial, Inc. companies There are several other Ameriprise Financial, Inc. companies that will receive revenue from the charges and fees you pay, including the following: • Ameriprise Certificate Company receives investment spread income earned on, and any early withdrawal penalty related to, Ameriprise Certificates. • Columbia Management Investment Services Corp. receives certain fees and expenses paid from the Columbia Funds and Ameriprise Certificates in exchange for the transfer agent services it provides. • American Enterprise Investment Services Inc. is compensated for its services through the brokerage • commission and other fees charged for each brokerage transaction, which may include transactions made in a Bank trust account, or through the brokerage commission which is included in the overall Asset­based fee, depending on the account option you select. If the Sweep Program for your Account is AIMMA, AEIS receives compensation from the Program Banks based on the cash balance in the AIMMA program. If your account sweeps uninvested cash to ABISA or to Ameriprise Bank as the Program Bank in the AIMMA program, Ameriprise Bank does not compensate AEIS, but reimburses AEIS for its direct out­of­pocket expenses related to the sweep services provided. • AEIS receives compensation in the form of interest charged on your margin account balance as well as from order handling fees. In transaction­based brokerage accounts, AEIS may also engage in principal trading of certain types of fixed income securities for brokerage accounts—that is, it may buy and sell these securities for its own account with the objective of making a profit in certain circumstances, AEIS may buy these securities from you or sell these securities to you on a principal basis, in which case you will pay a markup or markdown on the transaction. • AEIS performs, for the benefit of Ameriprise Financial Services, its financial advisors and clients, cost reimbursement and marketing support services as described in the “Cost Reimbursement and Marketing Support” section. In recognition of the above, Ameriprise Financial Services will compensate AEIS for these services performed by AEIS. • The capacity in which AEIS acts in any particular transaction is disclosed on each transaction confirmation you receive. AEIS is also compensated for the shareholder services it provides for certain mutual fund companies. 21 These services include but are not limited to delivering shareholder communications such as updated prospectuses and statements of additional information, transaction confirmations and annual tax reporting, and monitoring compliance with share class, discounted sales charge, market timing and other mutual fund company policies. • Ameriprise Financial Services receives fees paid from Columbia and the Columbia Funds and Ameriprise Certificates in exchange for the administrative services it provides. • Columbia Management Investment Distributors receives fees paid from the Columbia Funds in exchange for the distribution services it provides. Ameriprise Financial Services has a financial interest in the sale of Columbia Funds, Ameriprise Certificates and RiverSource products and certain other mutual funds. • Ameriprise Financial Services sells annuity and insurance products manufactured by its RiverSource affiliates, as well as products from unaffiliated providers. RiverSource is permitted to reimburse Ameriprise Financial Services for client/prospect education events and advisor sales meetings, seminars, and training events pertaining to annuity and insurance products, consistent with Ameriprise Financial Services policies and industry regulation; • Ameriprise Financial Services may also receive nominal noncash benefits from time to time. Unaffiliated annuity and insurance providers may not provide some services, or the same level of services, to Ameriprise financial advisors. As a result, Ameriprise financial advisors may have a greater familiarity with RiverSource annuity and insurance products. • Ameriprise Bank charges a fee, depending on the terms of trust documentation and applicable state laws governing trust administration for its administrative trust services that are separate from investment management fees charged by financial advisors and are not shared with Ameriprise Financial Services. • When Ameriprise Bank is a Program Bank in the AIMMA program or ABISA is the Sweep Option, Ameriprise Bank earns income by lending or investing the deposits it receives and charging a higher interest rate to borrowers, or earning a higher yield, than it pays on the deposits held through these sweep programs. The difference is known as the "spread." • Ameriprise Bank earns revenue based on the amount of credit extended and the interest rate on the Ameriprise Preferred Line of Credit and Loan. Custody Ameriprise Financial services does not maintain custody of client funds or securities or take possession of any plan assets as part of RPCS. Investment Discretion Your Ameriprise financial advisor does not manage plan assets, securities or other investments on your behalf as part of RPCS. Under RPCS your financial advisor provides investment advisory and consulting services on a non­discretionary basis. Voting Client Securities Ameriprise Financial Services does not offer proxy voting services with respect to RPCS. Financial Information We are not required to include a balance sheet in this Brochure because we do not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance. We do not have any financial conditions that are reasonably likely to impair our ability to meet our contractual commitments to clients. Ameriprise Financial Services has not been the subject of a bankruptcy petition during the past 10 years. 22 Privacy Notices Protecting your privacy is a top priority. Visit our Privacy, Security & Fraud Center at Ameriprise.com to understand our notices for how we collect, use, share and protect your personal information as well as to get answers to privacy­ related questions. • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • Glossary “Advisers Act” means the Investment Advisers Act of 1940, as amended. “AEIS” means American Enterprise Investment Services Inc. “AFIG” means Ameriprise Financial Institutions Group. “Agreement” means the applicable service agreement, as it may be amended from time to time, that includes the specific terms under which the client will receive those services. “Ameriprise” means Ameriprise Financial, Inc. “Ameriprise Financial Services”, “Ameriprise Financial”, “AFSI”, “we”, “us” or “our” means Ameriprise Financial Services, LLC. “ATC” means Ameriprise Trust Company. “Bank” means Ameriprise Bank, FSB. “CD” means a Certificate of Deposit. “CFP®” means Certified Financial Planner™ professional. “CFTC” means the Commodity Futures Trading Commission. “CMIA” or “Columbia Management Investment Advisers” means Columbia Management Investment Advisers, LLC. “Columbia” or “Columbia Management” refers, collectively, to Columbia Management Investment Advisers, LLC and Columbia Wanger Asset Management, LLC. “Columbia Funds” means investment companies and other funds advised by affiliated companies, Columbia Management Investment Advisers, LLC and Columbia Wanger Asset Management, LLC. “CTA” means Commodity Trading Advisor. “ERISA” means the Employee Retirement Income Security Act of 1974, as amended. “FASB” means the Financial Accounting Standards Board. “FDIC” means the Federal Deposit Insurance Corporation. “FINRA” means the Financial Industry Regulatory Authority. “Internal Revenue Code” means the Internal Revenue Code of 1986, as amended. “IRA” means an individual retirement account. “IRG” means Ameriprise Investment Research Group. “NFA” means National Futures Association. “NYSE: AMP” means Ameriprise Financial, Inc. stock symbol on the New York Stock Exchange. “Outside Workplace Retirement Plan” means additional retirement plan assets held outside of Ameriprise Financial Services in a participant­directed defined contribution plan. “Plan Fiduciary” or “Plan Fiduciaries” means employers and trustees of the plan enrolled in RPCS. “RiverSource” refers, collectively, to RiverSource Life Insurance Company and RiverSource Life Insurance Co. of New York. “RPCS” means Retirement Plan Consulting Service. “RPCS Fee” means the fee you pay for investment advice and services for RPCS. “SEC” means the United States Securities and Exchange Commission. “SIPC” means the Securities Investor Protection Corporation. “Solicitor” means individual professional, professional firm, and select corporate, institutional or membership organization to whom compensation is paid for referral of clients or members to Ameriprise Financial Services for its financial advisory services. 23 • “Third-Party Financial Institutions” means third­party financial institutions such as community banks, credit unions, credit union service organizations and Farm Credit Services with whom Ameriprise Financial Services may form alliances and networking arrangements with to allow its financial advisors to offer financial planning services and certain other non­deposit investment and insurance products and services, to retail customers/members of the Third­Party Financial Institutions. 24 About Ameriprise A tradition of commitment since 1894. A legacy of putting clients first. For more than 125 years, Ameriprise has been committed to putting our clients' needs first. Our advisors develop ongoing one­to­one relationships and take time to understand what's truly important to clients and their families. We offer a comprehensive approach to financial planning that helps our clients feel confident, connected and in control of their financial life. This Brochure provides information about the qualifications and business practices of Ameriprise Financial Services, LLC. If you have any questions about the contents of this Brochure, please consult with your financial advisor or contact us at 800.862.7919 between 7 a.m. and 6 p.m. Central time. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Ameriprise Financial Services, LLC’s California insurance license number is 0684538. Additional information about Ameriprise Financial Services, LLC also is available on the SEC’s website at adviserinfo.sec.gov. Financial Planning | Retirement | Investments | Insurance | Banking Ameriprise Financial 70400 Ameriprise Financial Center, Minneapolis, MN 55474 Investment advisory services and products are made available through Ameriprise Financial Services, LLC, a registered investment adviser. Ameriprise Financial Services, LLC. Member FINRA and SIPC. © 2025 Ameriprise Financial, Inc. All rights reserved 118229 E (03/26) 25

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