Ameritas Advisory Services, LLC

PART 2A Appendix 1 of Form ADV Galaxy Wrap Fee Program Brochure • March 20, 2026 This wrap fee program brochure provides information about the qualifications and business practices of Ameritas Advisory Services, LLC. (“AAS”). If you have any questions about the contents of this brochure, please contact us at (800) 335-9858, or by email at AASRIACompliance@ameritas.com. 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 Ameritas Advisory Services, LLC is available on the SEC’s website at www.adviserinfo.sec.gov by searching for Ameritas Advisory Services, LLC. Registration as an Investment Adviser does not imply a certain level of skill or training. Ameritas Advisory Services, LLC 5900 O Street / Lincoln, NE 68510 / (800) 335-9858 www.ameritas.com Item 1 – Cover  Item 2 – Material Changes This item includes a summary of the material changes that were made to this ADV Part 2A Appendix 1 (“Wrap Brochure”) since the last annual filing, which was on March 25, 2025. In addition to enhancements to information provided, the following material changes to this Wrap Brochure have been made since our last annual filing: Item 4 – Services, Fees and Compensation has been updated to clarify that the firm’s advisory services related to fee based variable annuities and variable life insurance products include managing the selection and allocation of subaccounts on a discretionary basis. It’s important to note that this service is not available through the Galaxy Wrap Fee Program. This section has also been updated to provide additional information to further describe the management of client accounts in our asset management programs. Item 4 – Services, Fees and Compensation and Item 9 – Additional Information have been updated to reflect additional sources of revenue our affiliate, Ameritas Investment Company, LLC (AIC), receives from its clearing firm and custodian, National Financial Services, LLC. Item 9 – Additional Information has been updated to include additional information regarding bonuses, additional products and services available to AAS IARs as well as compensation related conflicts of interest between Ameritas Life Insurance Corp. (ALIC) and our IARs when acting as agents of ALIC. Item 9 – Additional Information has been updated to include additional information regarding non-cash compensation received by IARs. We may update this brochure at any time. If we make any material changes relating to the disciplinary information in Item 9-Additional Information, we will provide you either: (i) a complete copy of our Galaxy Wrap Brochure (“Wrap Brochure”) that includes or is accompanied by a summary of material changes or (ii) a summary of material changes that includes an offer to provide a copy of the current Wrap Brochure. We urge you to carefully review all material change summaries as they contain information about significant changes to our advisory services, fee structure, business practices, conflicts of interest and disciplinary history. To receive a complete copy of our Wrap Brochure at no charge, please visit our website at www.ameritas.com/investments/disclosures or contact our Compliance Department at 800-335-9858. AAS 1055 Page 2 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  Item 3 – Table of Contents Item 1 – Cover . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Item 2 – Material Changes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Item 3 – Table of Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Item 4 – Services, Fees and Compensation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Item 5 – Account Requirements and Types of Clients . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Item 6 – Portfolio Manager Selection and Evaluation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 Item 7 – Client Information Provided to Portfolio Managers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 Item 8 – Client Contact with Portfolio Managers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Item 9 – Additional Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 AAS 1055 Page 3 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  Item 4 – Services, Fees and Compensation Description of our Firm & Principal Owners Ameritas Advisory Services, LLC (AAS) is an investment adviser registered with the Securities and Exchange Commission (SEC) that gives financial advice and manages investments. We work with clients through our financial advisors, called Investment Adviser Representatives (IARs). AAS took over the advisory business of Ameritas Investment Company, LLC (AIC) in October 2021. AIC still operates as a broker-dealer and is a member of FINRA and SIPC. AAS is part of the Ameritas Mutual Holding Company family of companies. Ameritas Holding Company owns Ameritas Investment Partners, Inc. (AIP) and Ameritas Life Insurance Corp. (ALIC). ALIC owns Ameritas Life Insurance Corp. of New York, AIC, AAS, and other related companies. Additional Information regarding our affiliated companies as well as their activities can be found in Item 9-Additional Information. Introduction As an investment adviser, we offer a variety of advisory services that are made available to clients through individuals associated with us as IARs. When acting as an investment adviser, we and our IARs have a fiduciary duty to our advisory clients and must make full and fair disclosure to them relating to our advisory relationships. As a fiduciary we aim to always put your interests ahead of our own, identify material conflicts, and eliminate, mitigate and/or disclose these conflicts. Most of our IARs operate under their own “doing business as” (“DBA”) trade name and logo or separate business name, which they use for marketing purposes to promote their overall financial services, and which may appear on client statements or reports. Clients should understand that even though our IARs often operate under their own DBA and market through their own website, when those IARs offer or provide advisory services through AAS, they do so under the name and supervision of AAS. These DBAs are the businesses and legal entities of the IAR and not AAS. AAS acts as the “back office” to our IARs and provides oversight over many functional areas, including operations, trading, technology, investment management, marketing, compliance, practice management, and more. An IAR may be registered with our affiliated broker-dealer, AIC as a broker-dealer registered representative and/or appointed as an agent with insurance companies including ALIC and ALIC NY. In these instances, an IAR may recommend fee-based investment advisory services, commission- based accounts, and annuities or other insurance products. Depending on the IARs licensing and affiliations, the IAR may be restricted as to the services they are able to offer or choose to offer a limited number of services such as financial planning and consulting. A small number of our IARs are employees of ALIC and may also be registered representatives of AIC. They are paid a salary and may also receive bonuses based on several factors. Their bonus structure is designed so it does not reward them for recommending certain products, product types, or advisory programs. Before engaging with an IAR, you should discuss the many differences between broker-dealer and advisory relationships as well as any limitations on the services your IAR offers. It is important to understand the associated costs and benefits of each option so that you can decide which types of accounts and services that may be best suited for your unique financial goals, investment objectives, and time horizon. You should bear in mind that the total cost for transactions under a fee account versus a commission account can vary significantly and depend on a number of facts such as account size, volume of trading activity (number of transactions), type and quantity of investments purchased or sold, anticipated holding period for the investments in your account, potential risk and return, and commission rates. Description of our Primary Advisory Services Our advisory services primarily consist of asset management services through portfolios or custom strategies created by IARs, co-advisory relationships with third-party money managers, management of variable product subaccounts, held away retirement plans or self-directed brokerage accounts, financial planning and consulting as well as retirement plan advisory services. Our services are designed to provide investment programs that are suitable for our client’s financial goals, objectives, and risk tolerances. Depending on your IAR’s registrations and qualifications, the types of investments that your IAR may recommend, purchase, and sell for your account include, but are not limited to, mutual funds, exchange traded funds (“ETFs”), unit investment trusts (“UITs”), structured products, interval funds, stocks, bonds, and money market funds (otherwise known as “securities”) as well as brokered certificates of deposit (“brokered CDs”) (which may or may not be securities) and cash. This brochure provides a description of the Galaxy Wrap Fee Program (“Galaxy Wrap Program”). For more information about our advisory services and programs other than the Galaxy Wrap Program please contact your IAR for a copy of a similar brochure that describes such services or program or go to www.adviserinfo.sec.gov. You should have a conversation with your IAR and read this and similar brochures carefully, as they explain our services in detail. Galaxy Wrap Fee Program Description The Galaxy Wrap Program is a wrap fee program sponsored by our firm. The program provides clients with customized asset management services or strategies created by their IAR. AIC acts as the introducing broker-dealer for this program and assets for the program are custodied at AIC’s clearing broker-dealer and custodian, National Financial Services, LLC (“NFS”), 245 Summer St, Boston, MA, 02210. Investment Advice and On-going Monitoring You will authorize your IAR to purchase investments based on your specific investment objectives and financial strategy. Your IAR will request information from you regarding your financial situation, investment objectives, risk tolerance, and other factors that might be considered in the management of your account. Your IAR will assist you in determining suitable investments and setting appropriate investment objectives. Depending on your IAR’s registrations and qualifications, the types of investments that your IAR may purchase and sell for your account include, but are not limited to, mutual funds, exchange traded funds (“ETFs”), unit investment trusts (“UITs”), structured products, interval funds, stocks, bonds, money market funds (otherwise known as “securities”), brokered CDs (which may or may not be securities), and cash. If you own multi-share class mutual AAS 1055 Page 4 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  funds in your account, AIC, on behalf of AAS, will convert the mutual fund shares you own to the lowest cost share classes available through NFS for the same mutual funds and with no cost or tax consequences to cash. Your IAR is not obligated to make any recommendations or give any financial advice to you that, in the sole judgment of the IAR, would be impractical, unsuitable, unattainable, or undesirable. The Galaxy Wrap Program may be non-discretionary (where investment decisions are made and authorized by you) or discretionary. Your IAR must obtain written authorization from you prior to exercising discretionary authority over your account. When acting with discretion, your IAR has the authority to buy or sell investments without contacting you in advance. You may place reasonable restrictions on the management of your account including restrictions on the types of investments that can be purchased in your account. You may withdraw your authorization at any time by providing written notice to us or your IAR. For additional information regarding discretionary asset management, please refer to Item 9 -Additional Information. Your IAR will be available to you on an ongoing basis to discuss any changes or updates in your financial situation, investment objectives, risk tolerance and time horizon as well as any reasonable restrictions you may wish to impose on the management of your account, including the type of investments that can be purchased in your account. Your IAR may make recommendations including, but not limited to, recommendations to change, hold, add, or replace investments, rebalance the mix of investments in your account, change the model selected for your account (if applicable), and increase or decrease the anticipated risk of the investments in your account. In some instances, our IARs may independently consider a security a client is trying to sell appropriate for another client. Our IARs advise numerous clients with similar or identical investment objectives or advise clients with different objectives that may trade in the same securities. Despite such similarities, portfolio recommendations relating to your investments and the performance resulting from such recommendations will differ from client to client. We and/or our IARs will not necessarily recommend, purchase, or sell the same securities at the same time or in the same amounts for all clients. To the extent our IARs have investment discretion over your account, it is our policy that the IAR allocates, to the extent practicable, investment opportunities on a basis that the IAR in good faith believes is fair and equitable to each client over time. Program Fees The Galaxy Program, like other advisory programs, has additional fees such as platform fees, transaction fees and clearing and custodial fees that are separate from your IAR’s fee. A portion of your total fee is allocated to an administrative fee which is paid to AAS and covers transaction fees as well as administrative and supervisory services. Notwithstanding the foregoing, all withdrawals from your account, apart from any fees automatically deducted from your account pursuant to your advisory agreement or your brokerage account agreement, are required to be authorized by you. The administrative fee is based on a sliding scale depending on the size of the assets in the account or a flat fee. Administrative fees are generally not negotiable. Although rare, AAS, at its discretion, may discount its administrative fee. When the administrative fee is part of your overall fee, the administrative fee reduces the portion of the overall fee paid to your IAR. In these cases, a discounted administrative fee is available to IARs based upon the aggregate total of account fee billings of all clients your IAR maintains in an advisory program. If your IAR receives a discounted administrative fee, your IAR’s compensation will increase by the amount of the discount received. Your total account fee and cost will remain unchanged unless your IAR lowers your fee. As such, your IAR has an incentive to utilize a program that offers discounted administrative fees to increase his or her overall compensation. These fees, including minimum fees are outlined in more detail below. As a participant in the Galaxy Wrap Program, you will pay an annualized fee (otherwise known as a wrap fee) based on your account value as reported by the custodian of your account and in accordance with the fee schedule below. The annual fee is comprised of your IAR’s fee, our administrative and service fees as well as transaction fees associated with the purchase and sale of investments in your account. The IAR fee compensates your IAR for ongoing advice and management of your account. The IAR’s fee is negotiable based upon factors such as total amount of assets involved in your relationship with your IAR and the range and complexity of services provided. You should consider the level and complexity of the consulting and/or advisory services provided when negotiating the fee with your IAR. Advisory fees are payable quarterly in advance and calculated based on a percentage of your account value as of the last business day of the previous quarter. The initial quarterly fee is based on the initial balance of your account and prorated based on the number of billing days in the initial quarter. If you invest or withdraw more than $1,000 from your account after the beginning of the calendar quarter, your fee will be recalculated and pro-rated as of the day of the additional investment. You may terminate your Galaxy Wrap Program Agreement without penalty within (5) business days after entering into it. If fees for advisory services are charged in advance, and you terminate your agreement any unearned advisory fees will be returned to you. AAS is responsible for the fee calculation and requesting the debiting of all fees from your accounts. You must provide the account custodian with written authorization to debit advisory fees from your accounts and pay the fees to AAS. You can elect to have the fee charged to one account, or split between other accounts, or you can elect to pay us by check. Fees can only be split between taxable accounts. We prefer to charge your accounts directly. If sufficient cash is not available to deduct advisory fees due, AAS reserves the right to liquidate investments in your account to cover fees. You will also be responsible for any transaction fees (if not covered by your advisory fee) resulting from the liquidation. NFS will send account statements to you at least quarterly, showing all withdrawals from the account including the advisory fee, if deducted from the account. Please note that payment for fees, securities and any other items cannot be made payable to an IAR, their staff members, or entities owned by the IAR. Payment for the purchase of securities and for the purpose of funding an account must be made payable to the account’s qualified custodian. The qualified custodian will never be AAS, an IAR, or AIC. AAS 1055 Page 5 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  Fee Schedule Your IAR has the option to charge a “linear fee” or “tiered fee,” with a minimum fee of 0.50% and a maximum fee as outlined below. Fee Schedule Assets Under Management Maximum Fee Up to $250,000 2.00% $250,001 – $500,000 1.75% $500,001 – $1,000,000 1.50% $1,000,001 – $3,000,000 1.25% $3,000,001 + 1.00% When choosing a linear fee arrangement, you will pay a fixed percentage on the entire value of the account that cannot exceed the maximum fee for any tier. For example, if the fixed fee is 1.00%, this amount would be applied to the total account value. In a tiered fee arrangement, once the value of your account meets the next tier, the new rate will be applied to all assets above the tier up to the next tier. For example, you will pay 2.00% on the first $250,000 in assets, 1.75% on the next $250,000, and so on. If you purchased Class A,B, C (or other commission-based) mutual fund shares or unit investment trusts (“UITs”) that were subject to a commission and sold to you by your IAR in his or her capacity as a registered representative of AIC on a commission basis and these shares are transferred to your advisory account within two years of the date of purchase, AAS will credit your account a pro rata amount of the commission as a fee credit or discount or temporarily waive your advisory fees. Credits and fee waivers will not be applied to assets transferred to an advisory account that were purchased through another broker/dealer other than AIC or matured UITs. Credits and fee waivers will only be applied if the amount of the credit or total amount of the fee waiver is $100 or more. In addition, the value of any investment designated as an “alternative investment product” such as a non-traded real estate investment trust, or mutual fund Class C shares will be excluded from the IAR fee if you purchased it in a commission-based account through a registered representative of AIC and then transferred it to a Galaxy Wrap Program account. Other investments including but not limited to stocks, bonds, ETFs, UITs, structured products, mutual funds, brokered CDs, and cash transferred into your program account, purchased at AIC, or at another broker-dealer, are subject to the investment advisory fee agreed upon in your advisory agreement. Certain holdings may be excluded from billing as well. You should discuss fee exclusions with your IAR prior to opening an account. To the extent a Class A, B or C share mutual fund pays a 12b-1 fee, such 12b-1 fees will be credited to your account. You should verify the accuracy of your advisory fee billings when you receive your account statements. Additional Fees The annualized fee does not include 1) fees for services provided by broker-dealers other than AIC or NFS for transactions executed by or through them that settle into or from accounts such as through prime brokerage or trade away services; 2) fees and charges AIC and/or NFS receive in lieu of commissions, such as, but not limited to, margin interest, electronic funds and wire transfer fees, custody and setup fees for alternative investments, transfer taxes, odd-lot differentials, certificate delivery fees, reorganization fees, fees required by law, and any other similar costs; 3) fees charged by some mutual funds, unit investment trusts (UITs), closed-end funds, and other collective investment vehicles, including but not limited to, fees assessed by the fund such as internal expenses, and short-term redemption fees; and 4) mark-ups and mark-downs, spreads paid to market makers, selling concessions and the like received by NFS in connection with transactions they may execute as principals by selling or buying securities to or from clients for its own accounts. Although we do not anticipate executing any trades away from NFS, any fees imposed would be in addition to the annualized fee you pay. If your assets are invested in mutual funds, you may also pay fees charged directly by the mutual fund companies as described in the prospectus(es). In the Galaxy Wrap program, a portion of the fee we receive is used to pay for trading costs associated with your account. AAS will pay NFS either a charge per trade or a percentage of the value of your account to cover trading costs. AAS has an incentive to limit trading in wrap fee accounts to lower our costs. Where NFS does not assess a transaction fee on certain mutual funds and ETFs (NTF funds), we and your IAR will not bear any costs associated with NTF funds selected for your account. Most NTF funds have higher internal expenses and as such, NTF funds will cost you more and cost us and your IAR less, than mutual funds that assess transaction charges but have lower internal expenses. In addition, the higher internal expenses charged to clients who hold NTF funds will adversely affect the long-term performance of their accounts when compared to share classes of the same fund that assess lower internal expenses. These differences in costs and internal fund expenses may help to maintain lower program fees but is a conflict of interest for us and your IAR as we have an incentive to select NTF funds over transaction fee funds in order to reduce our expenses. Your IAR is free to select what he or she deems to be the most appropriate mutual fund or exchange traded fund for your account and does not have a mandate to select NTF funds over other mutual funds or exchange traded funds. In most cases, mutual fund companies offer multiple share classes of the same mutual fund. Some share classes of a fund charge higher internal expenses, whereas other share classes of a fund charge lower internal expenses. Institutional and advisory share classes typically have lower expense ratios and are less costly for a client to hold than Class A shares or other share classes that are eligible for purchase in an advisory account. Mutual funds that offer institutional share classes, advisory share classes, and other share classes with lower expense ratios are available to investors who meet specific eligibility requirements that are described in the mutual fund’s prospectus or its statement of additional information. These eligibility requirements include, but may not be limited to, investments meeting certain minimum dollar amounts and accounts that the fund considers qualified fee-based programs. The lowest-cost mutual fund share class for a particular fund may not be offered through third-party broker-dealers or custodial platforms. You should never assume that you will be invested in the share class with the lowest possible expense ratio or cost. We strongly encourage you to discuss with your IAR whether lower-cost share classes are available in your particular program account. You should also ask your IAR why the particular funds or other investments that will be purchased or held in your managed account are appropriate for you in consideration of your expected holding period, investment objective, risk tolerance, time horizon, financial condition, amount invested, trading AAS 1055 Page 6 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  frequency, the amount of the advisory fee charged, whether you will pay transaction charges for fund purchases and sales, whether you will pay higher internal fund expenses in lieu of transaction charges that could adversely affect long- term performance, and relevant tax considerations. We and your IAR may recommend, select, or continue to hold a fund share class that charges you higher internal expenses than other available share classes for the same fund. Additionally, if you invest in certain products such as mutual funds and ETFs, you will pay two levels of advisory fees, the direct advisory fee to us and an indirect advisory fee as a product expense through the investment product. If you were to deal directly with the mutual fund company, you would not pay the separate advisory fee charged for the Galaxy Wrap Program. In that case, you would not receive the ongoing services we and your IAR provide which are designed, among other things, to assist you in determining which investments, investment strategies or investment programs may be most appropriate for your circumstances over time. You will be subject to fees charged by mutual funds (i.e., 12b-1 fees) included in your portfolio, if applicable, as set forth in the prospectus for each fund. If AIC receives 12b-1 fees from the mutual funds purchased in your account, these 12b-1 fees will be credited to your account. AIC adds a markup to brokerage account charges and fees (“rebillable fees”) that are assessed to client accounts participating in programs that utilize NFS as clearing firm and custodian for account assets. We do not reduce our advisory fees to offset these costs. Transaction fees and account activity fees are outlined in the NFS Brokerage Account Fee Schedule provided by your IAR when you establish an advisory account and are subject to change without notice. AIC will also charge a confirmation fee for all transactions except no-transaction-fee funds, mutual fund exchanges, and periodic investment/systematic withdrawal plans. If you choose to have confirmations sent to you in physical form the confirmation fee is $6.00 per trade. You will not pay confirmation fees if you opt for electronic delivery or if disallowed pursuant to state regulations. We offer margin accounts in our fee-based programs where you may borrow funds for the purpose of purchasing additional investments. You may also borrow money to pay for fees associated with your account or withdraw funds. If you decide to open a margin account, please carefully consider that: (i) if you do not have available cash in your account and use margin, you are borrowing money to purchase investments, pay for fees associated with your account or withdraw funds; and (ii) you are using the investments that you own in the account as collateral. We and your IAR have a conflict of interest when recommending that you purchase or sell investments using borrowed money because your advisory fee is based on the total market value of your account. If you have a margin debit balance, your margin debit balance does not reduce the total market value of your account. In fact, since you have borrowed money to purchase additional investments, the total market value of your account will be higher, which results in a higher advisory fee. Money borrowed in a margin account is charged an interest rate that is subject to change over time. This interest payment is in addition to other fees associated with your account. AIC retains a portion of the margin interest charged, which is a source of revenue. This compensation represents a conflict of interest as AIC has a financial benefit when you maintain a margin debt balance. Please carefully review the margin disclosure document for additional risks involved in opening a margin account. As further described in Item-9 Additional Information, AIC receives compensation from NFS in the form of transition assistance, credits to cover costs of technology fees, mark-ups to activity fees, margin interest, credit interest, and volume discounts on trading costs based on the number of trades processed on the NFS platform. AIC retains net profits that result from the correction of trade errors in program accounts. All losses incurred by clients, due to error, will be removed from either the IAR’s compensation or AIC’s revenues, depending on the cause of error. The revenues and compensation related to both advisory and brokerage accounts custodied on the NFS platform, create substantial financial benefits to AIC and NFS. This compensation represents a conflict of interest for us as AAS and AIC are under common ownership of our parent company. AAS has an incentive to recommend AIC as the introducing broker-dealer and NFS as the custodian and clearing firm for our advisory programs. We and your IAR may receive more compensation through the Galaxy Wrap Program than if you participated in other programs or paid separately for investment advice, brokerage, and other services. As such, we may have an incentive to recommend the Galaxy Wrap Program over other programs or services. The receipt of additional compensation itself creates a conflict of interest and may affect our judgment when making recommendations. Your IAR’s Relationship with Us and Associated Conflicts of Interest Your IAR who recommends you participate in the Galaxy Wrap Program, will be compensated as a result of your participation. The amount of this compensation may be more or less than what the IAR would receive if you participated in other advisory programs or paid separately for investment advice, brokerage, and other services. The amount your IAR is compensated may vary between the advisory programs we offer. An IAR may recommend commission-based accounts or products as a registered representative of AIC, fee-based accounts or services through AAS, the purchase of variable insurance products issued by ALIC, or financial services available through affiliates of AAS. AIC, an AIC Registered Representative and/or AAS IAR would receive compensation or/or commissions as a result of the sale of the insurance and other financial products, or services recommended. As a result, there is a conflict for us and our IARs in recommending certain affiliated programs and proprietary products. Your IAR receives compensation from us which includes a portion of the advisory fee. The portion of the advisory fee received by your IAR may be more or less than what he or she would receive at another investment adviser firm. This compensation includes bonuses, awards or other things of value offered to your financial professional. When compensation is based on the level of sales or advisory assets of an IAR, the IAR has a financial incentive to meet those sales targets or asset levels. AIC and AAS also offer your IAR one or more forms of financial benefits based on your IAR’s total commission-based accounts held at AIC or in AAS advisory accounts held at NFS and/or for transitioning from another firm to AIC and/or AAS. The types of financial benefits your IAR receives from AIC/AAS include, but may not be limited to, forgivable or unforgivable loans provided at below-market rates, bonuses for meeting certain predetermined production benchmarks, increased payouts, and discounts or waivers on transaction fees, platform fees, technology fees, administrative fees, and brokerage account fees. AIC and AAS may also reimburse expenses incurred by IARs for services and products used to operate and/or market their services. These products and services include but are not limited to texting solutions, marketing services, website vendors, web-based conferencing tools, and consulting. These products and services are made available as part of a financial professional’s affiliation with AIC and/or AAS or based on predetermined production benchmarks or assets under management. AAS 1055 Page 7 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  AIC and AAS provide some financial professionals with one-time payments, bonuses, or forgivable loans to assist in the expense associated in growing their business. The payments, bonuses, and loans are based on certain criteria related to increasing the number of commission-based accounts or the amount of client assets invested in AAS advisory programs on the NFS custodial platform. AIC and AAS may vary the amount of the payment, bonus, and/or loan based on the type of business conducted. For example, AIC and AAS will generally provide a higher loan amount for advisory business on the NFS custodial platform than on broker-dealer or commission-based business. The provision of these payments, bonuses, or loans creates a conflict for IARs as they have an incentive to recommend transitioning accounts to NFS rather than holding them directly with a product sponsor or AAS advisory programs over other programs or services offered by AAS in order to receive payment and/or not repay the forgivable loan. We also charge IARs various fees under their independent contractor agreement, for example, for administrative, custody and clearing services to accounts, technology, and licensing. These fees and compensation may be based on the IAR’s overall business production. When compensation or fees charged is based on the level of production of an IAR, the IAR has a financial incentive to meet those production levels. The amount of this compensation could be more, and the amount of these fees charged by us could be less, than what the IAR would receive, or pay, if he or she associated with another investment adviser firm. We also provide various benefits and/or payments to IARs that are newly associated with us to assist the IAR with the costs (including foregone revenues during account transition) associated with transitioning his or her business to AIC and/or AAS (collectively referred to as “Transition Assistance”). The amount of the Transition Assistance payments is often significant in relation to the overall revenue earned or compensation received by the IAR at his or her prior firm. These payments are commonly in the form of forgivable loans that are reduced over a multiyear term subject to continued affiliation with AIC and/or AAS and based on the amount of total assets they manage or are held at NFS as of a milestone date. These financial benefits, which can be significant to an IAR, present a conflict of interest because they provide a financial incentive for your IAR to select or maintain a business relationship with AIC/AAS over other firms that may not provide your IAR similar financial benefits. They also provide a financial incentive for your IAR to recommend that a client open and maintain accounts with AIC/AAS and its clearing firm NFS, and/or use AAS advisory programs custodied with NFS over other programs custodied with Schwab or Fidelity or third-party co-advisory platforms available through AAS. In addition, we will provide additional financial incentives to IARs which may be paid immediately or over time. Additional financial incentives are generally dependent upon the IAR meeting certain predetermined production and/or assets under management benchmarks. These financial benefits, which can be significant to an IAR present a conflict of interest because they provide a financial incentive for your IAR to select or maintain a business relationship with AIC as a broker-dealer, AAS as an investment adviser, or service and support provider for your accounts over other firms that may not provide your IAR similar financial benefits. They also provide a financial incentive for your IAR to recommend that a client open and maintain accounts with AIC and its clearing firm NFS and/or use AAS advisory programs custodied with NFS over other programs available through AAS. We manage this conflict of interest by supervising the suitability of recommendations made by our IARs in accordance with applicable regulatory requirements. The receipt of Transition Assistance creates a conflict of interest in that an IAR has a financial incentive to recommend that a client open and maintain an account with them for advisory and or brokerage services in order to receive the Transition Assistance benefit or payment. If the amount of the loan or grant exceeds the cost of transition, the recipient may use the remaining funds for other purposes, such as normal operating costs, satisfying any debt owed to the financial professional’s prior firm or offsetting the foregone revenues during the account transition process. AIC and AAS do not require, nor do they verify, that any such transition payments or loans are used for transition costs. We attempt to mitigate these conflicts of interest by evaluating and recommending that clients use AIC’s and AAS’s services based on the benefits such services provide to clients, rather than the Transition Assistance earned by the IAR. However, clients should be aware of this conflict and take it into consideration when deciding whether to establish or maintain a relationship with AIC or AAS. Subject to certain qualifications and restrictions, AIC and/or AAS will make payments to affiliated financial professionals for referrals of unaffiliated financial professionals. For each qualified referred financial professional who affiliates with AIC and/or AAS, the referring financial professional will receive a one-time referral payment in an amount determined by AIC and/or AAS and a percentage of the referred financial professional’s first 12 months of fees and/or commissions earned by the referred financial professional. AIC and/or AAS are responsible for these payments and the payments to the IAR are not a portion of the fees and/or commission you pay. Financial professionals receive compensation by the products they sell and services they offer. As the financial professional sells products and services, their compensation can increase or decrease in any given year. We have established a payout grid which illustrates the level of compensation a financial professional will receive. The more they sell the higher their compensation and the less they sell the lower their compensation. This creates an incentive for a financial professional to sell more products or increase their advisory fees to achieve a higher payout. You are encouraged to speak with your financial professional regarding their compensation and review more information about the “How Financial Professionals Get Paid / Compensation Grid Description” at www.ameritas.com/investments/disclosures. Financial professionals are also eligible to receive reimbursements, marketing and distribution allowances, due diligence fees, or other compensation based on sales directly from product sponsors for the costs of marketing, distribution, business and client development, educational enhancement, and/or due diligence reviews incurred by financial professionals relating to the promotion or distribution of the services. Because a financial professional can receive such additional compensation, a conflict of interest exists. To mitigate this conflict, we require our financial professionals to submit receipts for all expenses for which reimbursement is requested. All such reimbursements must be approved by and paid through the firm. Wrap Fees We offer asset management services through both wrap and non-wrap fee programs. A wrap fee program is defined as an advisory program in which the client pays a specified fee for portfolio management services and trading costs. In non-wrap programs, you pay the advisory fee plus separate fees for each trade. We receive a portion of the investment advisory fee you pay when you participate in the wrap fee programs we offer. A portion of the fee we receive is used to pay for trading costs associated with your account. AAS will pay the custodian either a charge per trade or a percentage of the value of your account to cover trading costs. AAS has an incentive to limit trading in wrap fee accounts to lower our costs. AAS 1055 Page 8 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  A wrap fee program is more expensive when trading activity is low and less expensive when trading activity is higher (such as when an account is established or actively managed). Conversely, a non-wrap fee program is more expensive when trading activity is high and lower when trading activity is less frequent. If the number of transactions in a wrap fee program is low enough, the wrap fee you pay will exceed the stand-alone investment advisory fee and separate brokerage commissions that would otherwise have been charged. We do not charge our clients higher advisory fees in wrap fee programs based on their trading activity however you should be aware that we may have an incentive to limit our trading activities in your account(s) because we are charged for executed trades. A wrap fee program is not appropriate for every client. You should carefully consider and discuss the investment objectives for your account to determine whether a wrap or non-wrap fee program is most appropriate. Retirement Accounts Guidance from the US Department of Labor (DOL) under Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code (Code), requires AAS to inform you that when we and our financial professionals provide nondiscretionary investment advice (including recommendations of our advisory program(s)) to you regarding your ERISA retirement plan or participant account or individual retirement account (which are all referred to as “retirement accounts”), that we and our financial professionals are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so for retirement accounts we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Regulations under ERISA and the Code define fiduciary investment advice as (1) advice or recommendations, for a fee or other compensation, regarding investing in, purchasing or selling securities or other property to a plan, plan participant, or IRA owner; (2) provided on a regular basis; (3) where the advice is provided pursuant to a mutual agreement or understanding that; (4) the advice serves as a primary basis for investment decisions with respect to the plan or IRA assets; and (5) the advice is individualized to the plan, participant or IRA owner. Retirement Plan Rollovers When leaving an employer, you typically have four options regarding your existing retirement plan: (1) leave the assets in the former employer’s plan, if permitted, (2) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (3) roll over the assets to an Individual Retirement Account (“IRA”), or (4) take a full withdrawal in cash, which would result in ordinary income tax and a penalty tax if you are under age 59 ½. If your IAR recommends that you roll over your 401(k) or other qualified plan assets to an IRA, this rollover recommendation presents a conflict of interest in that we and your IAR would receive compensation (or may increase current compensation) when investment advice is provided following your decision to roll over your plan assets. Your IAR will discuss your retirement plan options including retention of your 401(k) or qualified plan assets with your current plan, if allowed. You should carefully review the information regarding your rollover options, including the associated costs, and are under no obligation to rollover retirement plan assets to an account managed by us. General Disclosure Regarding ERISA Qualified Accounts If an advisory account is subject to the provisions of ERISA or certain tax deferred treatment under the Internal Revenue Code (such as individual retirement accounts, 457 plans and 403(b) plans), (collectively, “Qualified Accounts”) we and our IARs who act as a fiduciary by providing investment advice for such Qualified Accounts are generally prohibited from receiving both an advisory fee and any transaction-based compensation unless in compliance with applicable prohibited transaction exemptions under ERISA or the Internal Revenue Code or authorized by the U.S. Department of Labor. You will represent that the Qualified Account and any instructions given by you regarding the Qualified Account are consistent with applicable Plan documents, including any investment policies, guidelines, or restrictions. You will provide us with a copy of all relevant documents and agree that the advisory program you have selected is consistent with those documents. You will notify us, promptly in writing, of any changes to any of the Plan’s investment policies, guidelines, or restrictions, or other Plan documents pertaining to investments by the Plan. If the assets in the Qualified Account constitute only a part of your Plan assets, you shall provide us and your IAR with documentation of any of the Plan’s investment guidelines or policies that affect the Qualified Account. The compliance of any recommendation or investment your IAR makes for the Qualified Account with any such investment guidelines, policies, or restrictions shall only be determined on the date of the recommendation or purchase. You have the responsibility to give us prompt written notice if any investments made for the Qualified Account are inconsistent with such guidelines, policies, restrictions, or instructions. You understand that the services that we and your IAR perform shall have no effect on the assets of the Plan that are not in the Qualified Account, and that we shall have no responsibility for such other assets. We are not responsible for Plan administration or for performing any other duties that are not expressly set forth in the advisory agreement. You shall obtain and maintain at your own expense any insurance or bonds you deem necessary to cover yourself and any of your affiliates, officers, directors, employees, and agents in connection with the advisory agreement. Item 5 – Account Requirements and Types of Clients Minimum Account Size The minimum account size is $250,000 but may be waived for certain accounts at our discretion. Types of Clients The Galaxy Wrap Program is available to individuals, including high net worth individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. AAS 1055 Page 9 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  Item 6 – Portfolio Manager Selection and Evaluation Your IAR serves as your portfolio manager in the Galaxy Wrap Program. Each IAR will complete the review of investments and analysis of investment and recommendations or may create model portfolios based on the IARs own research and allocation methodology. Each IAR has the independence to take the approach that he or she believes is the most appropriate when analyzing investment products and strategies for clients. We perform periodic account reviews to verify that transactions in client accounts are consistent with the established investment objectives of the client. Description of Other Advisory Services In addition to providing services through the Galaxy Wrap Program, we offer fee based financial planning and consulting services as well as fee- based asset management services through portfolios or custom strategies created by IARs, co-advisory relationships with third-party money managers, and may refer clients to third-party programs. Your account may be managed on a discretionary or non-discretionary basis. In a discretionary account we, our IARs or third-party investment advisers have the authority to buy or sell investments without contacting you in advance. This may include selection of model portfolios, sub-account selection in variable annuities, or the selection, purchase, or sale of investments. For more detailed information on other advisory services we offer, please refer to our Form ADV Part 2A or respective Wrap Fee Program Brochure. These documents are available through your IAR. How Services are Tailored to Fit your Needs When you open an account with us or consult one of our IARs for a financial plan, your IAR will obtain the necessary financial data from you in the form of a Risk Assessment Questionnaire, a Client Data Sheet, and/or a New Account Form. Your IAR will examine your investment objectives, risk tolerance, and other factors to recommend specific investments or programs to suit your needs. If there are any changes to this information, please notify your IAR immediately. Your IAR will review your account annually, or more frequently as necessary, to determine whether or not your assets should be reallocated due to changes in your financial situation, market conditions or other factors. The investment advisory services provided largely depend on the personal information you provide to your IAR. In order for your IAR to provide appropriate investment advice to, or in the case of discretionary accounts, make appropriate investment decisions for you, it is important that you provide accurate and complete responses to your IAR’s questions about your financial condition, investment objectives and needs as well as any reasonable investment restrictions you wish to apply to the investments or types of investments to be bought, sold, or held in your account. It is also important for you to inform your IAR of any changes to your personal or financial circumstances, investment objectives or risk tolerance as well as any reasonable investment restrictions which may affect the advice we provide. Performance-Based Fees and Side-By-Side Management We do not charge performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Nor do we engage in side-by-side management (managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees.) Methods of Analysis, Investment Strategies and Risk of Loss Each IAR has the independence to take the approach that he or she believes is most appropriate when analyzing investment products and strategies for clients. The IAR chooses his or her own research methods, investment style and management philosophy. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. When developing recommendations for you, IARs compare your financial goals with your investment risk tolerance and the risk and potential return of a specific investment. IARs have wide latitude in designing investment strategies. As a firm, we do not favor any specific method of analysis over another, and therefore would not be considered to have one approach deemed to be a “significant strategy.” There are, however, a few common approaches that may be used in the course of providing advice to clients as described below: • Asset Allocation: An investment strategy that aims to balance risk and reward by allocating assets among a variety of asset classes. At a high level, there are three main asset classes – equities (stocks), fixed income (bonds), and cash or cash equivalents – each of which have different risk and rewards. Asset classes are further divided into domestic and foreign investments with equities divided into small, mid, and large capitalization. Bonds have varying durations and credit quality. By diversifying a portfolio amongst a wide range of asset classes, investors seek to reduce (but not eliminate) the overall risk of a portfolio through avoiding overexposure to any one asset class during various market cycles. Asset allocation can be tactical or strategic. A tactical allocation allows for a percentage of assets in each asset class (e.g., 40% stocks and 60% bonds). Strategic allocations include setting targets then rebalancing the portfolio back to those targets as investment returns increase or decrease. • Fundamental Analysis: A method of evaluating a security that involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure what is deemed to be the true value of the company’s stock compared to the current market value. The end goal of performing fundamental analysis is to produce a value that an investor can compare to the security’s current price and whether the security is over or under priced. • Technical Analysis: A method of evaluating securities by studying past price patterns and trends in the financial markets in an attempt to predict the direction of the overall market, specific stocks, or both. Technical analysts do not attempt to measure a security’s intrinsic value. Instead they use charts and other tools to identify patterns that suggest future activity. When looking at individual equities, a person using technical analysis generally believes that performance of the stock, rather than performance of the company itself, has more to do with a company’s future stock price. AAS 1055 Page 10 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  • Cyclical Analysis: A type of technical analysis that involves evaluating recurring price patterns and trends with the goal buying or selling securities based upon expected price movements or “market timing.” The risk of market timing based on technical analysis is that charts may not accurately predict future price movements. Current prices of securities may not reflect all information known about the security and day to day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Risk Factors As mentioned above, regardless of the strategy or analysis used, all investments carry the risk of loss including the loss of principal invested. Some risks may be avoided or mitigated, while others are completely unavoidable. Some of the common risks you should consider prior to investing include, but are not limited to: • Alternative Investment Product Risk: An investment that is not one of the three traditional asset types (stocks, bonds, and cash) and generally has low correlations to stocks and bonds. Alternative Investments may have complex terms and features that are not easily understood and are not suitable for all investors. Risks that may be associated with liquid alternative investments include: (1) Leverage – Leverage may enhance a fund’s returns in up markets but exacerbate returns in a bad market. Some firms with leverage inherent in their portfolios may experience “margin call” types of actions in the event of liquidity dry-ups or if certain counterparties cannot provide the leverage needed. (2) Shorting – Certain securities may be difficult to sell short at the price that the manager would wish to execute a trade. A short position may have the possibility of an infinite loss if a security continues to go up in price and the manager does not cover. (3) Security valuation – Certain securities held in alternative mutual funds, such as derivatives or thinly traded stocks, bonds or swaps may not have a market in which the money manager may need to trade it quickly in case of fund redemptions. High Bid/Ask spreads or the lack of another buyer/seller to take the opposite position of a thinly traded security could cause inaccurate estimates in underlying security valuation by the administrator. (4) Nightly reconciliation – The use of thinly traded securities, shorting and leverage may make it difficult for some alternative funds, based on their investment strategy, to provide accurate nightly NAVs for the mutual fund. • American Depository Receipts (ADRs): Positions in these securities are not necessarily denominated in the same currency as the common stocks into which they may be converted. ADRs are receipts typically issued by an American bank or trust company evidencing ownership of the underlying securities. Generally, ADRs, in registered form, are designed for the U.S. securities markets. An account may invest in sponsored or unsponsored ADRs. In the case of an unsponsored ADR, shareholders are likely to bear their proportionate share of the expenses of the depository and they may have greater difficulty in receiving shareholder communications than they would have with a sponsored ADR. • Brokered CD Risks: Brokered CDs differ from traditional CDs purchased directly from your bank and held as a bank deposit, in that brokered CDs may have longer holding periods, may be more complex, may have different features and fees, and carry more risk. Although most brokered CDs are bank products, some may be securities and won’t be FDIC insured. Unlike a traditional CD, brokered CDs must be sold in the secondary market which may be quite limited. If you need to liquidate your brokered CD before it matures, the CD may be worth less than your initial investment particularly if current interest rates are higher than the CD you currently own. For brokered CDs with long holding periods, any interest you might receive could be significantly reduced by the advisory fee you pay. Some brokered CDs are callable and may be called by the issuer if interest rates go down. Make sure you understand the fees, features, and risks of the particular brokered CD you are considering. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it (a lengthy process) before they can generate a profit. They have a greater uncertainty of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Call Risk: This is the risk that your bond or other fixed-income investment will be called or purchased back from you when conditions are favorable for the issuer and unfavorable to you. • Concentration Risk: This is the risk of loss because your money is concentrated in one investment or type of investment. When you diversify your investments, you spread the risk over different types of investments, industries, and geographic locations. • Credit Risk: This is the risk that the government entity or company that issued the investment will run into financial difficulties and won’t be able to pay the interest or repay the principal of a bond at maturity. Credit risk applies to debt investments such as municipal bond, agency bonds, and corporate bonds. You can evaluate credit risk by looking at the credit rating of a bond or bond issuer. For example, long-term US government bonds currently have a credit rating of AAA, which indicates the lowest possible credit risk. • Currency Risk: This is the risk of losing money because of a movement in the exchange rate. For example, if the U.S. dollar becomes less valuable relative to the Canadian dollar, your U.S. stocks will be worth less in Canadian dollars. This applies when you own foreign investments. • Default Risk: This is the risk that a bond or other fixed income investment issuer is unable to pay the contractual interest or principal on the product in a timely manner or at all. • ESG Investment Risks: ESG stands for environmental, social and corporate governance practices of publicly traded companies. Environmental criteria gauge how a company safeguards the environment. Social criteria examine how it manages relationships with employees, suppliers, customers, and communities. Governance measures a company’s leadership, executive pay, audits, internal controls, and shareholder rights. Investment strategies, mutual funds and ETFs that focus on ESG practices of corporations in evaluating investments are subjective and may be defined in different ways by different funds and managers. A portfolio manager’s ESG practices may significantly influence performance causing performance to be higher or lower than the overall market or comparable funds or strategies that do not employ ESG practices. • ETF Risks, including Net Asset Valuations and Tracking Error: ETF performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track (“tracking error”) because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the future for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depositary Receipts, or AAS 1055 Page 11 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate. An ETF typically includes embedded expenses that reduce the fund’s net asset value and therefore directly affect the fund’s performance, a client’s portfolio performance and index benchmark comparison. Expenses of the fund generally include investment adviser management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses can change from time to time at the sole discretion of the ETF issuer. ETF tracking errors and expenses may vary. • Financial Risk: Excessive borrowing to finance a business’s operations increases the uncertainty of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Fixed Income Risks: Portfolios that invest in fixed income securities are subject to several general risks, including interest rate risk, credit risk, and market risk, which could reduce the yield that an investor receives from his or her portfolio. These risks may occur from fluctuations in interest rates, a change to an issuer’s individual situation or industry, or events in the financial markets. • Foreign, Emerging Markets Risk: Investments in these types of securities have considerable risks. Risks associated with investing in foreign securities include fluctuations in the exchange rates of foreign currencies that may affect the U.S. dollar value of a security, the possibility of substantial price volatility as a result of political and economic instability in the foreign country, less public information about issuers of securities, different securities regulation, different accounting, auditing and financial reporting standards and less liquidity than in the U.S. markets. • High Yield Fixed Income Securities Risk: Investments in high-yielding, non-investment grade bonds (often referred to as “Junk Bonds”) involve higher risk than investment grade bonds. Adverse conditions may affect the issuer’s ability to make timely interest and principal. • Inflation Risk: Inflation risk, also called purchasing power risk, is the chance that the cash generated by an investment today won’t be worth as much in the future. Changes in purchasing power due to inflation may cause inflation risk. Conservative investments such as cash, money market funds, and government bonds are examples of investments that are subject to inflation risk. • Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Interval Fund Risks: Interval funds may expose investors to liquidity risk. While an interval fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. Moreover, if an interval fund invests in companies with smaller market capitalizations, derivatives or securities that entail significant market or credit risk, the liquidity risk may be greater. • Liquidity Risk: Liquidity risk arises when an investment is not easy to sell. Illiquid securities (difficult or impossible to sell, or subject to liquidation penalties) should not be purchased with funds you may need for short term needs. Illiquid securities are intended to be held for an extended time (more than 10 years) or indefinite periods. Stocks with limited trading activity are also subject to liquidity risk. Investing in an illiquid (difficult to trade) security may restrict our ability to dispose of such investments in a timely fashion or at an advantageous price, which may limit the ability to take full advantage of market opportunities and result in delays. • Longevity Risk: Longevity risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired or nearing retirement. • Margin Risk: Securities transactions in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan, inherently have more risk than cash purchases. If the value of the shares drops sufficiently, the investor will be required to deposit more cash into the account or sell a portion of the stock to maintain the margin requirements of the account. This is known as a “margin call.” An investor’s overall risk in accounts using margin includes the amount of money invested plus the amount loaned to them. • Market Risk: This is the risk that the stock market will decline, decreasing the value of the securities you own. Investment values may fall for a variety of reasons, including economic, political, social, financial, widespread business continuity events (e. g., natural disasters, pandemics, etc.) and issuer-based factors, causing prices of stocks, bonds, and other investments to fall. • Money Market Fund Risks: An investment in a money market mutual fund, unlike bank deposits, is not insured or guaranteed by the FDIC or any other governmental agency, and it is possible to lose money by investing in a money market mutual fund. Money market mutual funds are covered by SIPC, which protects against the custodial risk (not a decline in market value) when a brokerage firm fails by replacing missing securities and cash up to a limit of $500,000, of which $250,000 may be cash. • Options Risk: This is the risk of the option holder losing the entire amount paid for the option in a relatively short period of time, reflecting the nature of the option as a wasting asset becoming worthless when it expires. If you don’t sell an option in the secondary market or exercise it prior to expiration, you will lose your entire investment in the option. Options and option strategies involve varying degrees of risk and are not suitable for all investors. • Political and Government Risk: This is the risk that the value of your investment will be affected by the introduction of new laws or regulation, particularly with changes in administrations. • Portfolio Turnover Risk: Active and frequent trading of securities and financial instruments in a portfolio can result in increased transaction costs, including potentially substantial brokerage commissions, fees, and other transaction costs. In addition, frequent trading is likely to result in short-term capital gains tax treatment. As a result of portfolio turnover, the performance of a portfolio can be adversely impacted. • Regulatory Risk: This is the risk that changes in law and regulations from any government or governmental agency can change the value of a given company and its securities. Certain industries are more susceptible to government regulation. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (e. g., interest rate). This primarily relates to fixed income securities. AAS 1055 Page 12 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  • Securities Backed Line of Credit/Non-Purpose Loans: Securities Backed Lines of Credit (SBLOCs) are non-purpose loans where you pledge assets in your account as collateral in return for a loan. The loan proceeds can be used for purposes other than to purchase or trade securities. There are risks associated with pledging assets in your portfolio including, but not limited to, 1) you are borrowing money that will need to be repaid to the bank; 2) you will be charged an interest rate on the principal balance of the loan that is subject to change; 3) if the value of the securities pledged as collateral decrease, you will be liable for any deficiency; 4) the lender can force the sale or liquidation of securities held as collateral without contacting you in advance to meet collateral requirements and you are not entitled to choose which securities are liquidated or sold; 5) you are only entitled to draw on the line to the extent there is credit availability; and 5) there may be additional risks when money funds or similar investments may produce less interest income or other yield than the interest you are paying on the loan. You should carefully read all disclosures and agreements prior to entering into an SBLOC or non-purpose loan. • Short Sale Risk: A short sale is generally the sale of a stock not owned by the investor. Investors who sell short believe the price of the stock will fall. If the price drops, the investor can buy the stock at a lower price and make a profit. If the stock price rises and the investor buys it back at a higher price, the investor will incur a loss. Short sales require a margin account and are highly speculative. • Small/Mid Cap Risk: Stocks of small or mid-sized companies may have less liquidity than those of larger, established companies and may be subject to greater price volatility and risk than the overall stock market. • Structured Products Risk: Structured products are securities derived from another asset, such as a security or a basket of securities, an index, a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk associated with that issuer. This credit risk exists whether or not the investment held in the account offers principal protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. An investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon bond, or option. There may be little or no secondary market for the securities and information regarding independent market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. Tax treatment of structured products may be different from other investments held in the account (e.g., income may be taxed as ordinary income even though payment is not received until maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits. • Time Horizon Risk: Time horizon risk is the risk that your investment horizon is shortened because of an unforeseen event (e.g., the loss of your job). This may force you to sell investments that you were expecting to hold for the long term. If you must sell when the markets are down, you may lose money. The above list of risk factors does not purport to be a complete list or explanation of the risks involved in an investment strategy. You are encouraged to consult your financial advisor, legal counsel, and tax professional on an initial and continuous basis in connection with selecting and engaging in the services provided by us. In addition, due to the dynamic nature of investments and markets, strategies may be subject to additional and different risk factors not discussed above. Your investments are not bank deposits, are not insured, or guaranteed by any governmental agency, entity, or person, unless otherwise noted and, as such, may lose value. It is important to note that no methodology or investment strategy is guaranteed to be successful or profitable. You understand that investing in securities involves risk of loss that you should be prepared to bear. Voting Client Securities As an investor in publicly traded companies and other investments, you will have the opportunity to participate in certain actions by the company or the investment. This is often referred to as “proxy voting” or participating in corporate actions. We do not vote proxies. It is your responsibility to vote all proxies for securities held in your account. You will receive proxy materials directly from your transfer agent or directly from NFS. Although AAS and its IARs do not vote proxies, we permit IARs to answer your questions regarding proxy voting materials in an effort to assist you in determining how to vote the proxy. However, the final decision of how to vote the proxy rests solely with you. Not all IARs will consult with their clients on proxy matters. Item 7 – Client Information Provided to Portfolio Managers Your IAR serves as your portfolio manager in the Galaxy Wrap Program. Your IAR will obtain the necessary financial data from you in the form of a Risk Assessment Questionnaire, a Client Data Sheet, and/or a New Account Form. If there are any changes to this information, please notify your IAR immediately. Your IAR will then share this information with us to determine whether the recommendation is consistent with your stated objectives as outlined in the risk assessment questionnaire. If there are any changes to this information, please notify your IAR immediately. Your IAR will review this information annually or more frequently as necessary to determine whether or not your assets should be allocated to a different Strategy due to changes in your financial situation, the market, or other conditions. We maintain a privacy policy and restrict information to those persons with the need to access your information. As a result of the services provided by AAS under the program, AAS and its associated persons may have access to identifying information about your account and selected investment strategies (including non-public information). Non-public information includes your Social Security number, net worth, and annual income. Public information is information about you that is readily accessible to the public such as your name, phone number, and address. AAS 1055 Page 13 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  Item 8 – Client Contact with Portfolio Managers Your IAR serves as your portfolio manager in the Galaxy Wrap Program. Your IAR will review your account annually or more frequently as necessary to determine whether your account should be rebalanced, replaced or if new investments should be recommended for your account due to changes in your financial situation, the market, or other conditions. Item 9 – Additional Information Disciplinary Information The following information regarding legal or disciplinary events is related to AAS and when advisory business was conducted under our predecessor, Ameritas Investment Company, LLC, as well as disciplinary history of our officers, directors, and control persons, that may be material to your evaluation of our firm or the integrity of our management. Materiality is subject to our discretion, and/or as defined by the SEC for purposes of this disclosure document. 1. In February 2022, AAS consented to an SEC Order regarding AAS’s failures to provide full and fair disclosure regarding the conflicts associated with certain third-party compensation received when AAS’s advisory business was part of AIC (collectively, the “Advisory Firm”). Specifically, the Order stated that the Advisory Firm breached its fiduciary duty to advisory clients by failing to provide full and fair disclosure regarding conflicts associated with (1) AIC’s receipt of revenue sharing payments from its unaffiliated clearing broker (“Clearing Broker”) as a result of advisory clients’ investments in certain mutual funds and money market funds that paid revenue sharing to the Clearing Broker; (2) markups on Clearing Broker fees for advisory clients’ transaction fees; (3) revenue received from the Clearing Broker on the rate of margin interest charged to advisory clients; and (4) an annual business development credit from the Clearing Broker based on AIC maintaining, within a range, minimum accounts, asset balances, and trading volumes in certain revenue sharing paying mutual fund programs and margin accounts. The Order further stated that the Advisory Firm breached its duty to seek best execution by causing certain advisory clients to invest in share classes of mutual funds and money market funds when share classes of the same funds were available to clients at a lower cost and breached its duty of care by failing to undertake an analysis to determine whether the particular mutual fund and money market fund share classes it recommended were in the best interests of its advisory clients. Finally, the Order stated that the Advisory Firm failed to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and rules thereunder in connection with its practices regarding mutual fund and money market share class selection, fee markups, margin interest, business development credits, and best execution. AAS consented to evaluate whether clients should be moved to an available lower-cost share class and move clients as necessary; notify affected investors of the settlement terms; pay affected investors disgorgement of $3,334,804, prejudgment interest of $543,490; and pay a civil penalty of $750,000. 2. In October 2020, AIC (doing business as Ameritas Advisory Services), signed a consent agreement with the Commonwealth of Pennsylvania Department of Banking and Securities, Bureau of Securities Compliance and Examinations in which it as was ordered to pay an administrative assessment in the amount of $100,000 for failing to register at least one employee in Pennsylvania as an investment adviser representative from January 2015 through June 2019 in violation of the Pennsylvania Securities Act of 1972. 3. In March 2019, AIC consented to an SEC order stating that AIC willfully violated Section 206(2) and Section 207 of the Advisers Act by failing to explicitly disclose AIC’s conflicts of interest related to receipt of 12b-1 fees and its recommendation or selection of 12b-1 fee paying mutual funds in advisory accounts. AIC self-reported this conduct to the SEC pursuant to the Share Class Selection and Disclosure (“SCSD”) Initiative. AIC was censured, agreed to cease and desist from committing or causing any violations or future violations of Sections 206(2) and 207 of the Advisers Act, ordered to pay disgorgement of $3,056,804 and prejudgment interest of $332,370 to affected investors, and to comply with certain undertakings including reviewing and updating, where necessary, the adequacy of all relevant disclosure documents concerning mutual fund share class selection and 12b-1 fees; evaluating whether existing clients should be moved to lower cost share classes; as well as reviewing its policies and procedures to ensure they are reasonably designed to prevent violations of the Advisers Act in connection with disclosures regarding mutual fund share class selection. The SCSD Initiative was a voluntary initiative in which the SEC encouraged investment advisers to self-report violations involving receipt of 12b-1 fees and adequacy of the disclosures arising from the resulting conflicts of interest. Other Financial Industry Activities and Affiliations We are part of the Ameritas Mutual Holding Company family of companies. The Ameritas Holding Company (AHC) has direct 100% ownership of both AIP and Ameritas Life Insurance Corp. (“ALIC”); ALIC has direct 100% ownership of Ameritas Life Insurance Corp. of New York (“ALIC NY”), Variable Contract Agency, LLC, AIC, our firm, and other subsidiaries. Certain directors and officers of AAS are also directors or officers of AHC, AIC, ALIC, ALIC NY, and Variable Contract Agency, LLC. As a result, a significant percentage of time of our executive personnel is spent on activities other than fee-based investment supervisory and management services. Ameritas Investment Company, LLC AIC is registered as a broker-dealer with the SEC, a member of FINRA and SIPC. Many of our management persons are registered representatives of AIC. Most IARs are also registered representatives of AIC and may be individually licensed as insurance agents or serve as agents of ALIC or their affiliates in the sale of traditional and variable insurance products. AIC offers a variety of approved products and services to serve the needs of investors. AIC is the introducing broker-dealer for all AAS advisory programs where NFS acts as custodian and clearing firm. This introduces significant conflicts of interest which are further described in the Brokerage Practices section of this Item 9. AIC is a municipal securities dealer, municipal securities adviser, and underwriter for municipal securities offerings primarily in the state of Nebraska. Due to the conflicts associated with AIC’s receipt of commissions and receipt of advisory fees by AAS and our IARs, we do not permit the purchase of municipal securities underwritten by AIC in advisory accounts. AIC does not normally act as a dealer in connection with securities that we recommend to our clients other than in the context of underwritings, as described above. AAS 1055 Page 14 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  Some product sponsors pay extra compensation to AIC, referred to as revenue sharing arrangements, in return for increased exposure to AIC registered representatives through conferences and educational opportunities. In some cases, revenue sharing may represent an expense embedded in the investment product that is born by investors. In other cases, the revenue is paid out of the product providers’ assets. These revenue sharing arrangements are an incentive for AIC to give preferential treatment to these sponsors which could influence sales of their products. IARs and registered representatives of AIC do not receive a direct financial benefit from revenue sharing, as such we do not believe AIC’s relationships with these product sponsors compromise the advice our IARs may provide to clients. Additional information regarding AIC’s revenue sharing arrangements can be found at www.ameritas.com/investments/disclosures or by contacting us at 800-335-9858. Ameritas Life Insurance Corp. Ameritas Life Insurance Corp. (“ALIC”) has direct 100% ownership of AIC and AAS. AIC is the distributor and lead underwriter for variable insurance products issued by ALIC. As a result of this ownership, AIC, AAS, and their financial professionals are incentivized to offer ALIC products. In its role as lead underwriter, AIC receives a distributor fee for these services if the variable annuity or variable insurance policy is sold on a commission basis. If you invest in a fee based variable annuity or variable insurance policy, ALIC pays AIC for serving as underwriter from its assets or surpluses in its general account rather than through a premium load deducted from your policy cash value. Additional information regarding distribution of ALIC products may be found in the product prospectus available from ALIC or your IAR. If your IAR is licensed as a registered representative of AIC and appointed as a life insurance agent with ALIC, he or she may recommend the purchase of variable annuities or variable life insurance products (“variable products”) issued by ALIC. If you choose to implement these recommendations, AIC will receive compensation from ALIC for the sale. Your IAR would receive securities commissions from AIC for the sale of ALIC variable products if sold on a commission basis or advisory fees from AAS if you purchase a fee-based variable product. ALIC will also refer potential advisory clients to AAS for free financial planning services. In addition to securities commissions and advisory fees, IARs who are appointed as agents of ALIC are eligible to receive bonus compensation, free or discounted services, and other forms of compensation for the sale of ALIC fixed insurance products as permitted by law. These benefits and compensation present a conflict of interest for our IARs when recommending ALIC insurance products, including insurance products distributed and underwritten by AIC. If you purchase a no-load (fee-based) ALIC variable annuity or life insurance policy your IAR may recommend that you select Calvert Portfolios including those where AIP, an affiliate of AAS, earns sub-advisory fees, as investment options within the contract or policy. In cases where AAS and AIP both receive advisory fees for assets invested in Calvert Portfolios, the advisory fee billed to your account will be reduced by the amount of advisory fees earned by AIP. Additional information about our relationship with AIP can be found below. ALIC and AEI Capital Corporation (AEI) formed NLP Funding LLC (“NLP”) in order to provide a revolving credit facility (“Credit Facility”) to one or more intermediate tier limited liability company depositor entities (each a DST Depositor) which have and shall be formed to acquire commercial real estate properties that will be contributed to and held by one or more Delaware Statutory Trusts (each a DST). NLP’s funding is structured with ALIC and AEI contributing the capital necessary to fund the Credit Facility. Under the Credit Facility, NLP receives principal and interest payments in addition to a repayment fee from each DST Depositor, and in turn, NLP distributes monies to AEI and ALIC. Certain investment products issued and distributed by AEI and its affiliates, including the beneficial interests in the DST’s would, if sold by registered representatives of AIC on a commission basis to clients of AIC, constitute a conflict of interest between AIC, ALIC, and AEI. Variable Contract Agency, LLC To the extent that your IAR is licensed to offer variable insurance products, he or she will be appointed through Variable Contract Agency, LLC, an affiliated insurance agency, for the payment of insurance commissions. Variable insurance products sold by your IAR are issued through our affiliate, ALIC as well as unaffiliated insurance companies. Ameritas Investment Partners, Inc. AIP, an SEC registered investment adviser, provides investment advisory services and manages portfolios for various institutional clients, is a commodity trading adviser, sponsors wrap fee programs, and provides advisory services to us in connection with the Constellation Program. AIP sponsors the Gemini and Mercury Wrap Fee programs that are offered to our clients. For additional information on these wrap fee programs, please refer to the AIP wrap fee brochures which may be provided by your IAR. AIP is subject to conflicts of interest that have the potential to influence its decision making with regard to programs and services AIP offers to us and our clients which may cause them to favor other clients or business activities over our clients or the services they offer to us. As an investment adviser, AIP has a fiduciary duty to act in the best interest of its clients, maintains a code of ethics and compliance program to ensure compliance with its duties under the Investment Advisers Act. AIC provides brokerage services and AIP provides investment advisory services to our clients who invest in wrap fee programs offered by AIP. AIP shares the advisory fees generated through these programs with us and uses AIC as the introducing broker dealer for execution of transactions. We have an incentive and conflict of interest in recommending the programs of AIP over other investment advisers due to the revenue AIC receives as a broker dealer for execution of transactions, fees we receive for assets placed in these programs, and common ownership by our parent company. We do not require IARs to utilize the services of AIP and make multiple advisory programs available such that the IAR may select the program that is most suitable for an individual client. Financial Institutions We offer advisory services on the premises of unaffiliated businesses, including insurance companies and financial institutions, such as banks or credit unions. In some cases, the IAR pays such business entity a fee for the use of the premises and facilities and for administrative support. In the case of financial institutions, we have entered into agreements with financial institutions pursuant to which we share compensation, including a portion of the advisory fee, with the financial institution for the use of the financial institution’s facilities and for client referrals. In such case, instead AAS 1055 Page 15 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  of paying the IAR the portion of the advisory fee as described above, we share a portion of the fee with the financial institution according to the agreement between us and the financial institution. The IAR may or may not be an employee of the financial institution. Unlike investments offered through the financial institution, securities are not insured by the Federal Deposit Insurance Corporation (FDIC), or any other federal or state bank deposit guarantee fund or other government agency; are not deposits or obligations of the bank, credit union, or their affiliates; and are subject to investment risk, including possible loss of principal. Dually Registered Investment Adviser Representatives Certain IARs of AAS are also registered as IARs with unaffiliated registered investment adviser firms. Through such unaffiliated investment adviser firms, IARs may provide asset management services or financial planning and consulting services and earn advisory fees for providing such services on behalf of the unaffiliated firm. Therefore, you could receive advisory services from one individual who can act as an IAR on behalf of two separate registered investment advisers. This dual registration is a conflict of interest because your IAR may receive more or less compensation as a result of his or her registration with AAS and the unaffiliated investment adviser and may have access to different programs and services. If the IAR provides services to you on behalf of AAS, you will be given the Disclosure Brochure of AAS and the IAR’s Form ADV Part 2B. If the services are being provided by the IAR on behalf of the unaffiliated firm, you should receive the Disclosure Brochure of that firm and the IAR’s Form ADV Part 2B of that firm. The disclosure brochures describe the services provided, fees charged, conflicts of interest and other important information. You are encouraged to read and review the disclosure brochures for both AAS and the unaffiliated investment adviser firm as well as client agreements and other disclosure documents provided. If you have questions regarding how these conflicts of interests impact you, you should direct questions to your IAR. Other Affiliations Our IARs may also have other outside business activities separate from AAS for which they also receive compensation. While IARs may be permitted to be employed by, or own, a financial services business entity, including an investment adviser business, separate from AAS, this activity must be disclosed. These activities are not considered a conflict of interest on their own but may be in some cases. However, you should be aware that these situations can exist. For example, an IAR could conduct these activities during normal business hours, which could take away time from servicing your accounts or otherwise affect their obligations to you. An IAR may also receive more compensation from his or her outside business than through his or her relationship with us. Examples of such activities include tax preparation, insurance, real estate sales, and/or attorney services for which they also receive compensation. IARs must obtain prior approval to participate in outside business activities. Information regarding your IAR’s outside business activities are disclosed in the IARs Form ADV Part 2B which is provided to you at the time you engage our IAR for advisory services. Information regarding your IAR’s outside business activities can be found by searching for his or her name on www.adviserinfo.sec.gov. From time to time, we or our supervised persons donate to charitable organizations that are affiliated with clients, are supported by clients, and/ or are supported by an individual employed by one of our clients. In general, such donations are made in response to requests from clients, or their personnel. Because such contributions may result in the recommendation of our firm or our services, such contributions may raise a potential conflict of interest. As a result, we maintain procedures that generally limit the dollar amount and frequency of charitable contributions and require that all contributions are made directly to the charitable organization (normally a 501(c)(3) organization). No contribution will be made if the contribution implies that continued or future business with us or our supervised persons, depends on making such contribution. We require that our supervised persons seeking to make a political contribution to or volunteer for a state or local candidate, political action committee or political party pre-clear their contributions or activity through the firm. We do not require our supervised persons to pre-clear contributions to federal candidates unless the candidate is currently a state or local government official running for federal office. However, we do require supervised persons to notify us of any contributions made to or volunteer activity done on behalf of federal candidates, political action committees or political parties. We and your IAR are also subject to local and state pay-to-play rules in addition to federal securities rules and regulations. We disclose all material conflicts of interest so that existing and prospective clients may evaluate their impact on any relationship. The conflicts identified are addressed through the development, implementation, and monitoring of our compliance program. We have supervisory procedures in place to monitor the suitability of client transactions, adherence to client investment objectives, transactions with affiliates, monitoring third-party programs and the trading practices of our IARs. Code of Ethics Summary We have adopted a Code of Ethics to address our fiduciary relationships with clients; specify or prohibit certain types of transactions deemed to create conflicts of interest (or the potential for or appearance of); establish reporting requirements; and enforcement procedures under federal, state, and all other applicable securities laws. We have developed and adopted the following general principles to guide our employees, officers, and directors deemed to be Covered Persons of our firm (“Supervised Persons”) under the Code of Ethics. Supervised Persons include all investment advisory personnel defined as key officers, home office associates, all IARs and all associates of an IAR’s office, including licensed and non-registered fingerprinted people who have direct contact with our advisory clients, as well as any person deemed a Covered Person under the Code of Ethics by the AAS Chief Compliance Officer (“CCO”) or designee. The interests of clients are paramount, and all Supervised Persons shall strive to conduct themselves in such a manner that the interests of clients take precedence over all others, and to prevent access to non-public information about securities recommendations, and client securities holdings and transactions, except to those associates that need such information to perform their duties. AAS 1055 Page 16 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  Supervised Persons must comply with all federal and state securities laws. Further, no Supervised Persons shall, in connection with the purchase or sale, directly or indirectly, of a security to be held or acquired by a client: • Defraud a client in any manner, • Mislead a client, including by making any statement that omits material facts, • Engage in any act, practice or course of conduct that operates or would operate as a fraud or deceit on a client, • Engage in any manipulative practice with respect to a client, • Favor the interests of one client over another, or • Profit personally, directly, or indirectly, as a result of knowledge about a security or a transaction. All personal securities transactions by Supervised Persons must be accomplished in such a way as to avoid any conflict between the interest of our clients and the interest of any Supervised Persons. Each Supervised Person who is an Access Person (any director, officer or associate of AAS or a Supervised Person that has access to nonpublic information or is involved in making securities recommendations to clients) is required to provide quarterly reports of all transactions in securities in which the person has, or by reason of such transaction acquires, any direct or indirect beneficial ownership to our CCO or designee. Each Supervised Person is also required to submit appropriate holdings reports to our CCO, or his/her designee, which shall be reviewed to determine whether a violation of the Code of Ethics may have occurred. Our Code of Ethics includes specific provisions outlined in the Insider Trading and Gifts and Gratuity sections of our procedure manual. Supervised Persons are required to comply with these policies and procedures. Supervised Persons are further required to report any violation of the Code of Ethics to the CCO, or his/her designee and submit written acknowledgment of receipt of the Code of Ethics and any amendments at least annually. If you want to obtain a complete copy of our Code of Ethics, we will provide it upon request. Participation or Interest in Client Transactions and Personal Trading Officers of our firm may, from time to time, make recommendations to our advisory clients relating to investments in which such officer has an interest. In addition, and as noted above, we are part of a family of companies engaged in the financial services and insurance industries. These companies, some of which may be regarded as “related persons” of ours, may have direct or indirect interests in investments about which we and/or our IARs may provide investment advice. We may buy or sell for our accounts, or individuals associated with us may buy or sell for their personal accounts, investments identical to those recommended to customers. Because we or a related person(s) may have an interest or position in a certain investment which may also be recommended to you, our client, and as these situations may present a conflict of interest, we have established the following restrictions in order to ensure our fiduciary responsibilities: 1. A Supervised Person shall not buy or sell investments for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment, unless the information is also available to the investing public on reasonable inquiry. No Supervised Person shall place his or her own interest above that of the advisory client. 2. When implementing investment recommendations, clients are fully informed that Supervised Persons may receive separate compensation. 3. We emphasize the unrestricted right of the client to decline to implement any advice rendered. 4. We emphasize the unrestricted right of the client to select and choose any broker or dealer and/or insurance company he or she wishes. 5. We require that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisers. Any individual not in observance of the above may be subject to termination. Brokerage Practices Research and Other Soft Dollar Benefits We do not receive research or other products or services other than execution from a broker-dealer or a third-party in connection with client securities transactions (“soft dollar benefits”). Ameritas Investment Partners (“AIP”), a related company, receives brokerage and research services for securities transactions executed for institutional accounts it manages. For additional information regarding AIP’s brokerage practices, please refer to the AIP ADV Part 2A available at www.adviserinfo.sec.gov. Brokerage for Client Referrals When selecting or recommending broker-dealers, we do not consider whether we or a related person receives client referrals from such broker-dealer or third-party. Directed Brokerage You are under no obligation to act on our recommendations and are free to select any broker-dealer or investment adviser you’d like to implement our recommendations. In other words, you are not required to work with us. However, if you want to hire us for our investment management services, we are responsible for executing your account transactions and therefore responsible for attaining the best execution possible under the circumstances. If you contract for our investment management services, we require them to use broker-dealers recommended or approved by us. Please note that not all investment advisers require the use of specific broker-dealers. Some investment advisers permit clients to use any broker-dealer of the client’s own choosing. In very rare cases, we may work with a client that wants to use a broker-dealer that has not been recommended or approved by us. AAS 1055 Page 17 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  In such cases, those clients must understand that we may be unable to effectively negotiate brokerage compensation on the client’s behalf and that clients may not receive the best price for securities executed through that broker-dealer. When directing brokerage business, clients should consider whether the commission expenses and execution, clearance, and settlement capabilities that they obtain through the broker-dealer they select are adequately favorable in comparison to those that we would otherwise obtain for our clients. Clients with client-directed brokerage arrangements should also understand we may be limited in our trading ability and may be required to execute client directed trades after trades are implemented through accounts at our preferred platforms. Clients are encouraged to discuss available alternatives with their IAR. Our recommendation of a specific custodian or broker-dealer is based in part on our existing relationships, the custodian’s financial strength, reputation, breadth of investment products, and the cost and quality of custody and brokerage services provided to you and our other clients. The determining factor in the selection of a custodian to execute transactions for your accounts is not the lowest possible transaction cost, but whether the custodian can provide what is, in our view, the best qualitative execution for investment transactions for your account. Selection of Brokers We permit our IARs to provide a variety of programs when recommending services to you, including different brokerage and custodial platforms. We reserve the right to limit an IARs use of available platforms based on factors such as industry and technical experience, assets under the IARs management, and training requirements. When managing your assets, we require that you maintain your account with a “qualified custodian,” generally a broker-dealer. We require advisory clients to utilize one of our approved broker-dealers if they choose to have us manage their advisory accounts. AIC acts as the broker-dealer and National Financial Services (“NFS”) acts as clearing firm and custodian for certain of our advisory programs. We also have relationships with Charles Schwab & Co. Inc., and Fidelity Brokerage Services, Inc. (“Fidelity”) who act as custodian and provide brokerage platforms for other advisory programs we sponsor. We are independently owned and operated and not affiliated with the custodian we recommend. Our use of a particular custodian is, however, a beneficial business arrangement for us, AIC, and the custodian. Information regarding the benefits of these relationships is described in more detail below. When selecting brokerage platforms and custodians for client accounts, we consider standard benefits that are available without cost to all investment adviser firms using the platform, including our firm. These benefits include, but are not necessarily limited to, the following products and services: receiving duplicate client statements and confirmations; research related products and tools; access to a trading desk servicing our accounts; the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts; the ability to have advisory fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; and access to mutual funds with no transaction fees. Our recommendation of a specific custodian is based in part on our existing relationships, the custodian’s financial strength, reputation, breadth of investment products, and the cost and quality of custody and brokerage services provided to you and our other clients. We are able to negotiate transaction pricing with the custodians we select for our advisory programs. This pricing is based on a number of factors such as expected level of assets placed with the custodian, an expected level of transactions and the types of securities purchased (e.g., no transaction fee mutual funds, transaction fee mutual funds, exchange traded funds, stocks, bonds, etc.). Where we pay transaction, costs based upon these factors, we have an incentive and conflict of interest in selecting the types of investments to be purchased or custodian selected in order to maintain negotiated pricing. While we consider the overall services provided by the brokerage firms, products and services offered by these firms may benefit us but may not benefit our clients. We also have material arrangements with some firms that create an incentive for us to recommend those firms over other brokerage firms. These relationships are further explained below. Ameritas Investment Company, LLC AIC acts as the introducing broker-dealer and utilizes its clearing and custody relationship with NFS for services provided under the following programs: Galaxy, Galaxy Wrap, Constellation, and Ameritas Wealth Platform which are further described in this brochure or a brochure supplement. NFS transmits client orders for execution to various exchanges or market centers based on a number of factors, including size of the order, trading characteristics of the security, favorable execution prices (including opportunity for price improvement), access to reliable market data, availability of efficient automated transaction processing, and reduced execution costs through price concessions from the market centers. Certain market centers may execute orders at prices superior to the publicly quoted market in accordance with their rules or practices. NFS’ order-routing policies, taking into consideration all of the factors listed above, are designed to result in favorable transaction processing for customers. NFS provides the following products and services without cost: receiving duplicate client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving AIC; access to block trading (providing the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); the ability to have advisory fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; and access to mutual funds with no transaction fee. AIC receives compensation from NFS in the form of monthly trading volume discounts, monthly margin interest, reimbursements of costs associated with transfers of assets incurred from other clearing firms, transition assistance, business development credits, and payments to offset costs of AIC’s conferences and events. Revenues and payments may cease if there is a material change in AIC’s business including a significant change in the composition of assets or a decrease in AIC’s average assets or number of accounts. These terms are a conflict of interest for AIC to promote the establishment of accounts at NFS over accounts held in direct sponsor accounts, particularly mutual funds, advisory accounts with third-party investment managers, or clearing firms and custodians that do not pay such revenue payments. Additionally, AIC has a contractual relationship with NFS which limits AIC’s use of other clearing firms and custodians. This contractual relationship is a conflict of interest in that AIC is required to open all brokerage accounts with NFS. AAS 1055 Page 18 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  While AIC can negotiate competitive pricing from NFS that we believe is beneficial to our clients, AIC’s clearing relationship with NFS provides AIC with substantial economic benefits and compensation that would not be received if clients establish accounts with firms other than NFS. The additional compensation received by AIC creates a significant conflict of interest with our clients because we have a substantial economic incentive to use AIC as introducing broker-dealer and NFS as the clearing firm for trade execution and custody over other firms that do not share compensation with AIC. The revenue and compensation AIC receives from NFS is related to both advisory and brokerage accounts custodied on the NFS platform unless AIC forgoes the revenue. NFS discounts the trading fees AIC pays based on the monthly volume of trading activity in brokerage and advisory accounts. The volume discount excludes trading costs in Fidelity retail funds, NTF funds, periodic investment plans, systematic withdrawal plans, mutual fund exchanges, AIC’s trades, average price trades, international trading, and any transactions in which NFS charges no clearance or charges an asset-based fee in lieu of a per trade clearance charge. AIC does not reduce trading fees paid by its financial professionals or customers when these trade volumes qualify for discounted trading fees. This discount is an incentive to AIC to promote trading in customer accounts; however AIC has policies and procedures in place to ensure trading activity is appropriate and in the best interests of its customers. NFS will credit AIC a portion of the fees and costs customers incur from transferring accounts from other clearing firms to NFS. Similarly, NFS will issue credits to AIC for accounts that are already on the NFS platform that transition to AIC. AIC receives a higher payment for assets transitioning from other clearing firms. NFS pays AIC annual business development credits to support AIC’s business operations. NFS provides a sponsorship credit to offset costs of AIC’s conferences and educational events. To further support AIC’s business, NFS waives any user fees to access its trading platform and back-office systems. We offer margin accounts in our fee-based programs where you may borrow funds for the purpose of purchasing additional investments. You may also use a margin account to borrow money to pay for fees associated with your account or to withdraw funds. If you decide to open a margin account, please carefully consider that: (i) if you do not have available cash in your account and use margin, you are borrowing money to purchase investments, pay for fees associated with your account or withdraw funds; and (ii) you are using the investments that you own in the account as collateral. Money borrowed in a margin account is charged an interest rate that is subject to change over time. This interest rate is in addition to other fees associated with your account. AIC retains a portion of the margin interest charged, which is a source of revenue. This compensation represents a conflict of interest as AIC has a financial benefit when you maintain a margin debt balance. We and your IAR have a conflict of interest when recommending that you purchase or sell investments using borrowed money. This conflict occurs because your advisory fee is based on the total market value of your account. If you have a margin debit balance, your margin debit balance does not reduce the total market value of your Account. In fact, since you have borrowed money to purchase additional investments, the total market value of your account will be higher, which results in a higher advisory fee. Please carefully review the margin disclosure document for additional risks involved in opening a margin account. If you participate in the Galaxy, Galaxy Wrap, Constellation, Ameritas Wealth Platform or wrap fee programs offered through our affiliate, AIP, you will open a brokerage account with AIC to hold the investments in your account. Each eligible brokerage account has an associated account to hold cash, including dividends and interest payments, waiting to be invested. This account is called a “sweep” account because cash balances are automatically “swept” into the core account investment vehicle. For eligible accounts, the default core account investment vehicle will be the Bank Deposit Sweep Program (the “Program”). Available cash in your account is deposited through the Program into interest-bearing deposit accounts at one or more FDIC-insured depository institutions (the “Program Banks”). Program deposits may only be accessed through your brokerage account. Program Banks do not have a duty to provide the highest rates available and may instead seek to pay a lower rate. Interest on Program Deposits may be lower than the prevailing market interest rates that have been paid on accounts otherwise opened directly with the Program Bank. Deposits at an individual Program Bank are covered by FDIC insurance up to a maximum of $250,000 for an individual account and $500,000 for joint accounts. The maximum amount of FDIC Insurance coverage for your deposits in the Program is up to $2.5 million for an individual account or up to $5 million for a joint account, subject to the total amount on deposit in an account, applicable FDIC rules and bank availability. Deposits over the limits mentioned here or that cannot otherwise be placed at a Program Bank due to capacity constraints are “Excess Deposits” and will be deposited into one or more “Excess Deposit Banks,” as designated on the Program Bank list, without regard to FDIC-insurance limitations, and thus these Excess Deposits will not be covered by FDIC Insurance. The Bank Deposit Sweep Program is not covered by SIPC. The information provided here should not be relied upon as a full description of the Program. You should rely on disclosure documents provided at the time your account is established and any subsequent information provided by NFS for complete details. Bank Deposit Sweep Program documents including disclosures, interest rates, and a list of participating banks can be found on our website at www.ameritas.com/investments/disclosures. We encourage you to read them carefully. NFS receives revenue from each bank (“Program Bank”) participating in the BDSP based on the average daily deposits held at the Program Banks. This revenue is then shared with AIC and, from this revenue, AIC will pay interest to customers who participate in the BDSP. Although AIC does not accept revenue from NFS for advisory accounts participating in the BDSP, the interest rate paid to customers is the same for all accounts and account types, is determined by AIC, and is subject to change. Program Banks pay a rate for Program Deposits to NFS that is higher than the rate received by you, and the difference is the fee retained by AIC and NFS for administering the BDSP and related services. The fees retained by AIC and NFS can be a higher percentage of the interest than what is credited to customer accounts. Additional disclosures, rates and a list of BDSP Participating banks can be found on our website at www.ameritas.com/investments/disclosures or obtained from your financial professional. We encourage you to review these documents carefully. If your account is not eligible for the Bank Deposit Sweep Program and you do not select another cash sweep account investment vehicle, your cash sweep investment vehicle will be invested in a non-interest bearing cash account. Money market sweep options are available, however they may be subject to transaction fees. If AIC receives 12b-1 fees for money market funds, the 12b-1 fees will be reimbursed to your account. AIC charges fees associated with your brokerage accounts, some of which it marks up, and others are a direct pass through from NFS. AIC marks up NFS’s confirm processing fees when clients opt to have confirmations sent to them by mail. The confirmation and statement processing fee will not be charged for clients that opt for electronic delivery or when disallowed pursuant to state regulations. You will also pay other brokerage account charges and activity fees (“rebillable fees”) such as legal transfer fees, check fees, transfer fees, and cash management fees. AIC publishes its brokerage account activity fees and trading/execution fees in its NFS Brokerage Account Fee Schedule provided by your IAR when you establish a AAS 1055 Page 19 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  brokerage account with AIC and its clearing firm and custodian, NFS, and are subject to change without notice. Current transaction fee and activity fee schedules are also posted at www.ameritas.com/investments/disclosures. AIC retains net profits that result from the correction of trade errors in program accounts custodied at NFS. All losses incurred by clients, due to error, will be removed from either the IAR’s compensation or AIC’s revenues, depending on the cause of the error. Charles Schwab & Co., Inc. We recommend the use of Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as a qualified custodian for our Ameritas Investment Strategies (“AIS”) Program, Ameritas Investment Strategies Wrap (“AIS Wrap”) Program, Adviser Managed Retirement (“AMR”) Program, Adviser Managed Solutions (“AMS”) Program, Galaxy II Program, and Galaxy II Wrap Program. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell investments when we instruct them to. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. We do not open the account for you, although we may assist you in doing so. For our clients’ accounts that Schwab maintains, Schwab generally does not charge separately for custody services but is compensated by charging commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions and transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. Schwab and other custodians have eliminated commissions [or transaction fees] for online trades of U.S. equities, ETFs and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. We encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedules available at www.schwab.com/aspricingguide. Schwab Advisor Services™ is Schwab’s business servicing independent advisory firms. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: • Services that benefit you: Schwab’s institutional brokerage services include access to a broad range of investment products, execution of transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. • Services that may not directly benefit you: Schwab makes other products and services available to us that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. Schwab makes software and other technology available to us that provides access to client account data (such as duplicate trade confirmations and account statements); facilitates trade execution and allocates aggregated trade orders for multiple client accounts; provides pricing and other market data; facilitates payment of our fees from our clients’ accounts; and assists with back-office functions, recordkeeping, and client reporting. • Services that generally benefit only us: Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include educational conferences and events; consulting on technology, compliance, legal and business needs; access to employee benefits providers, human capital consultants, and insurance providers; and marketing and consulting support. Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third-party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of our personnel. The availability of these services from Schwab benefits us because we do not have to produce or purchase them. Services provided by Schwab are at no cost. Schwab’s support services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody, however the fact that these benefits are available creates an incentive for us to recommend that you maintain your account with Schwab. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services and not Schwab’s services that benefit only us. Fidelity Brokerage Services, LLC We recommend the use of Fidelity Brokerage Services, LLC as custodian and broker dealer (“Fidelity”) for our AIS Program, AIS Wrap Program, AMS Program, AMR Program, Galaxy II Program, and Galaxy II Wrap Program. Fidelity is an independent and unaffiliated SEC registered broker/dealer and FINRA member. Fidelity offers services to investment advisers that include custody of securities, trade execution, clearance, and transaction settlement. Fidelity Investments has agreed to reimburse termination fees when clients transition their accounts to Fidelity to utilize their services and products. This agreement is based on an expected level of assets transitioned to Fidelity. Clients should consider other benefits in addition to such reimbursement of fees when making a decision to establish accounts through Fidelity versus other brokerage platforms. Fidelity and other custodians have eliminated commissions [or transaction fees] for online trades of U.S. equities, ETFs and options (subject to a per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Fidelity. We encourage you to review Fidelity’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non-wrap account please refer to Fidelity’s website at www.fidelity.com/trading/commissions-margin-rates. AAS 1055 Page 20 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  We receive some benefits from Fidelity for assets invested in the AIS Program, AIS Wrap Program, AMS Program, AMR Program, Galaxy II Program, and Galaxy II Wrap Program. Although we receive economic benefits that are typically not available to Fidelity’s retail investors, there is no direct link between our use of Fidelity and the investment advice we give to our clients. These benefits include the following products and services (provided without cost or at a discount): receiving duplicate client statements and confirmations; research related products and tools; consulting services; access to a trading desk; access to block trading (providing the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); the ability to have advisory fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; and access to mutual funds with no transaction fees. Fidelity sponsors conferences and events held by AAS for its IARs and may also pay for business consulting and professional services received by AAS and its IARs. Some of the products and services made available by Fidelity may benefit us but may not benefit our client accounts. These services are intended to help us manage and further develop our business enterprise. The benefits we or our personnel receive do not depend on the amount of brokerage transactions directed to Fidelity. As part of our fiduciary duties to clients, we endeavor always to put the interests of clients first. Clients should be aware, however, that receiving economic benefits in and of itself creates a conflict of interest and may indirectly influence our choice of Fidelity for custody and brokerage services. Aggregation of the Purchase or Sale of Securities Client orders executed through the same broker dealer may be aggregated to achieve best execution. Generally, clients will receive the average share price of all orders executed to fill the aggregated order. Clients in the aggregated order will incur the same transaction fee or commission charge regardless if the order was aggregated or executed individually. Aggregation saves time and all accounts receive the same price. We may attempt to aggregate orders when it is determined it is prudent to place orders for the same security, at the same time, in one or more client accounts. IARs may determine not to aggregate transactions based, for example, on the size of the trades, the number of client accounts, the timing of the trades, the liquidity of the securities and discretionary or non-discretionary nature of the trades. If we or our IARs do not aggregate orders, some clients purchasing securities around the same time may receive a less favorable price than other clients. This means that this practice of not aggregating may cost clients more money. Please ask your IAR if you would like more information on the IAR’s practices in this respect. Review of Accounts Your IAR will request information from you regarding your financial situation, investment objectives, risk tolerance, and other factors that might be considered in the management of your account. Your IAR will assist you in setting appropriate investment objectives and recommend investments and advisory programs appropriate for your investment objectives. We make written performance reports available to you and your IAR quarterly which assist you and your IAR in reviewing all transactions and performance of your account. Your IAR will contact you at least annually to review the allocation of your accounts, account performance, your financial situation and investment objectives to determine if changes need to be made to the management of your account. We perform periodic account reviews to verify that transactions effected in client accounts are consistent with the established investment objectives of the client. The IAR may also periodically review client accounts. Triggering factors which could cause such reviews include, but are not limited to, changes in client objectives or circumstances, world events, market movements, interest rate changes or client requests. To the extent clients engage their IAR for financial consulting services, we review this activity and the written financial plans presented to clients. Client Referrals and Other Compensation From time to time, IARs may recommend or select other investment advisers for their clients. In these cases, we and our IARs are compensated for client referrals. When AAS and our IARs receive compensation for such referrals, this is a conflict of interest. When you are referred to another investment adviser, your IAR will disclose their status as a client or non-client of the investment adviser; that they are compensated; and that such compensation is a conflict of interest. Additional conflicts of interest will be provided through a separate disclosure based upon the relationship that AAS and your IAR have with the third-party investment adviser. If AAS compensates individuals or third-party investment advisers (“Promoters”) for referrals, the Promoter must provide clear and prominent disclosure which outlines their relationship to AAS, whether or not compensation is paid, and the incentives such compensation introduces. Additionally, AAS will enter into written agreements with any Promoter who receives compensation from AAS for referral activity. AAS will monitor the activities of these compensated Promoters to ensure they are complying with the requirements outlined in Rule 206(4)-1(b)(1) and (b)(3). AAS may also register Promoters as soliciting advisers if the state(s) where they are located or conduct referral activity requires registration as an investment adviser representative to receive compensation. In these instances, the soliciting advisers are supervised persons of AAS and are subject to our AAS’s Code of Ethics and other requirements. AIC acts as the principal underwriter for variable products offered by its affiliated insurance company ALIC. For qualified accounts, AIC, AAS and our IARs acting as fiduciaries will not receive both advisory fees and commissions or distribution fees unless in compliance with applicable prohibited transaction exemptions. When AIC acts as the principal underwriter and/or distributor of variable products, AIC will receive fees for such underwriting and/or distribution. If the insurance contract is issued by an affiliate, this creates a conflict of interest which is addressed elsewhere in this brochure. To the extent that the insurance contract is sold by an agent of ALIC who is also an IAR with our firm, this also creates a conflict of interest where we and/or ALIC provide additional compensation to the IAR as a result of the sale. AIC also receives distribution fees (12b-1 fees) from mutual funds in your advisory accounts. Receipt of such compensation creates a conflict of interest; therefore, if AIC acts as the introducing broker-dealer we have implemented a policy requiring that to the extent AIC receives 12b-1 fees in advisory accounts held with NFS, such fees will be rebated back to clients. If your account is held with Fidelity or Schwab, 12b-1 fees will not be credited to your account, but rather retained by Fidelity or Schwab. 12b-1 fees are not shared with AAS or your IAR. AAS 1055 Page 21 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  As further described in Item 4-Services, Fees and Compensation and this Item-9, AIC receives compensation from NFS in the form of transition assistance, technology credits, mark-ups to account activity fees, margin interest, credit interest, and volume discounts on trading costs based on the number of trades processed on the NFS platform. We also receive economic benefits through our relationships with Fidelity or Schwab based on a level of assets placed on their platforms. IARs receive production incentives from us, AIC or Ameritas Life Insurance Corp. as a result of reaching certain levels of sales and/or assets under management if an IAR is affiliated with AAS. Production levels and compensation to advisory representatives may vary. Qualifying financial professionals receive incentives such as attendance at our incentive and educational conferences and events, medical, dental, life insurance, HSA plans, 401(k) matches, as well as contributory and non-contributory deferred compensation plans. These benefits create an incentive to recommend certain affiliated programs and proprietary products. IARs may also receive reimbursements for advertising, sales literature and promotions offered by product promoters such as mutual fund companies. Our policy is to permit all IARs who are registered representatives of AIC to accept these reimbursements to the extent that they are usual and customary within the industry, and in compliance with the SEC, FINRA, or state rules, regulations, or guidelines. Because an IAR may receive such incentives, a conflict of interest exists. Please refer to the section “Other Financial Industry Activities and Affiliations” above for additional information regarding compensation we and our IARs receive. Third-Party Investment Advisers Third-party investment advisers must be approved by AAS before their programs are available to our clients. Approval is based on several criteria, including investment strategy, investment performance, transaction reporting capabilities, and training and wholesaling support. In exchange for certain benefits, such as the opportunity to participate in our national conferences and broader access to our IARs via participation in conference calls and contact lists, some third-party investment advisers share a portion of the revenue generated by distributing their products and services with us and/or pay a specified annual dollar amount. It is important to understand that not all third-party investment advisers approved by AAS have revenue sharing agreements with us. Further, our IARs do not receive any compensation as a result of these agreements, and as such, do not have a direct financial incentive to select one investment management firm over another. For additional information regarding our revenue sharing relationships, please visit www.ameritas.com/investments/disclosures. Third-party investment advisers may reduce the fees they charge based on the total assets an IAR places with them. These reductions may not lower the advisory fee you pay and may instead increase the portion of the fee retained by the IAR. This creates a conflict of interest, as an IAR may receive higher compensation by recommending certain third-party advisers over other available programs. As a fiduciary, however, your IAR must recommend investments – including those managed by third-party advisers – based solely on your best interest. IARs may also receive various services and benefits from third-party advisers, including technology tools, marketing resources, business consulting, educational support, and other practice-management assistance. These benefits may be provided at no cost or at discounted rates and can vary based on the IAR’s business volume, participation in business development programs, or the level of assets placed with the adviser. These benefits are intended to support the IAR’s business operations and may not directly benefit you. In some cases, IARs may be eligible to attend conferences or events sponsored by third-party advisers. AAS reviews and approves IAR participation in these events in advance, and reimbursement requests must be supported by receipts and comply with AAS’s reimbursement policies. All reimbursements are paid through AAS. Specific details about any benefits offered by a third-party investment adviser are disclosed in that adviser’s Form ADV Part 2A, which your IAR will provide when you enter into a co-advisory agreement. You should review these disclosures carefully. Custody Custody, as it pertains to an investment adviser, has been defined by the SEC as having access or control over client funds and/or securities, but does not necessarily include the ability to execute transactions in client accounts. Custody is not limited to physically holding client funds or securities. If an investment adviser, or any of its related companies, has the ability to access or control client funds or securities, the investment adviser is deemed to have custody for the purposes of Rule 206(4)-2 of the Investment Advisers Act of 1940 (the “Custody Rule”) and must ensure proper procedures are implemented. AAS is deemed to have custody of client funds and securities over accounts held with NFS because AAS, at the client’s request, has the ability to initiate money/fund distribution requests, including in client accounts that are subject to third-party standing letters of authorization and in rare cases when we accept physical stock certificates from clients. AAS is also deemed to have custody of client funds at Fidelity and Schwab when clients have standing letters of authorization to initiate money/fund distribution requests to third parties. For accounts over which we are deemed to have custody we have established the following procedures to comply with the SEC’s Custody Rule: • All client funds and securities are held at qualified custodians, Fidelity, NFS or Schwab in a separate account for each client under that client’s name. • Clients, or independent representatives of clients, will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. • Account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. Certain reports that may be made available to you either in writing or available on-line are obtained from sources believed to be reliable, however, cannot be guaranteed. You should always rely upon information you receive directly from the custodian(s) of your assets. The consolidated reports made available from AAS and your IARs are created from data obtained from the custodians who hold the data, from technology that obtains the data from your custodians, or from account statements from product sponsors. As such, the report presentations you may see are subject to the accuracy of their source. Reports may not reflect all holdings or transactions, their costs, or proceeds received by you. AAS 1055 Page 22 of 23 03-20-26 Galaxy Wrap Fee Program Brochure  In accordance with SEC regulations, we are subject to an annual surprise verification examination. We must engage an independent, third-party accounting firm to perform an annual, surprise examination verifying the location of client funds and securities and ensuring the accuracy of quarterly statements. When completed, the accounting firm’s report will be available through the SEC’s Investment Adviser Public Disclosure page at www.adviserinfo.sec.gov. You can view our information by searching for “Ameritas Advisory Services, LLC. An internal control report must include an opinion of an independent public accountant as to whether controls are in place as of a specific date, are suitably designed for our business operations and are effectively meeting the control objectives relating to the custodial services of AIC on behalf of our clients. The accounting firm must also verify that funds and securities of which we are deemed to have custody are reconciled to a custodian (i.e., Fidelity, NFS or Schwab). The internal control report is prepared by a third-party accounting firm that is not affiliated in any way with us and that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board (“PCAOB”). Investment Discretion When you invest in our asset management programs, your account will be managed on a discretionary or non-discretionary basis. In a discretionary account we, our IARs, our sub-advisers, or third-party investment advisers have the authority to buy or sell investments without contacting you in advance. Depending on the program selected, discretionary authority will include selection of model portfolios, sub-account selection in variable annuities or variable universal life insurance products, or the selection and purchase or sale of investments in line with your investment objectives and risk tolerance. You must grant this authority in writing before any discretionary trading activity can occur in your account, you may place reasonable restrictions (e.g., limiting the types or amounts of particular investments purchased or sold for your account or limiting the use of margin) on our discretionary authority at any time. Such restrictions must be made via written notice to us and your IAR. Non-discretionary accounts are accounts where your IAR provides recommendations as to the purchase or sale of specific investments or third-party money managers, however your IAR does not place orders to buy or sell investments without first receiving your authorization. If your IAR manages your account on a non-discretionary basis, you must be willing to accept that your IAR cannot buy or sell investments in your account without your prior consent. If you are unavailable, we will not be able to buy or sell any investment (as we would for our discretionary clients) should there be a market correction or if we determine that a particular investment should be bought or sold for our client accounts. Financial Information We will disclose any financial condition that is reasonably likely to impair our ability to meet contractual commitments to you. At this time, we have no financial conditions that would impair our ability to meet contractual commitments to you. AAS 1055 Page 23 of 23 03-20-26 Galaxy Wrap Fee Program Brochure