STIFEL FINANCIAL PLANNING DISCLOSURE BROCHURE

SEC Number: 801-1447 FINANCIAL PLANNING SERVICES Disclosure Brochure March 31, 2026 This brochure provides information about the qualifications and business practices of Stifel, Nicolaus & Company, Incorporated. This brochure focuses on our fee-based financial planning services; we also offer other advisory services, including (but not limited to) advisory consulting services and wrap fee programs, which are covered in separate brochures. If you have any questions about the contents of this brochure, please contact us at the address or telephone number provided below. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”), or by any state securities authority. Additional information about Stifel, Nicolaus & Company, Incorporated is available on the SEC’s website at adviserinfo.sec.gov. Registration with the SEC does not imply a certain level of skill or training. Stifel, Nicolaus & Company, Incorporated 501 North Broadway St. Louis, Missouri 63102 (314) 342-2000 Stifel.com INVESTMENT AND INSURANCE PRODUCTS: NOT FDIC INSURED • NOT A BANK DEPOSIT • NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY • NO BANK GUARANTEE • MAY LOSE VALUE Page 1 of 14 SF1602-3/26  MATERIAL CHANGES This section describes the material changes to Stifel, Nicolaus & Company, Incorporated (“Stifel” or the “firm”)’s last annual update of this brochure in March 2025. This Brochure, dated March 31, 2026, has been prepared according to the SEC’s disclosure requirements. There have not been any material changes to this Brochure to report since the last annual amendment. Due to the short-term nature of most fee-based financial planning engagements, we do not expect to provide another copy of the Form ADV Disclosure Brochure during your Financial Planning engagement unless there are material changes to the document we originally provided to you. In the unlikely event that your Financial Planning engagement of us spans multiple years, instead of providing an updated brochure each year, we generally provide a summary of the material changes by April 30 of each year. Because it is a summary, it does not contain all of the updates that were made to the brochure. Please read the full brochure, which is available to you at no charge at stifel.com/disclosures/investment-advisory-services/program-disclosures under the section “Stifel Form ADV 2A Disclosure Brochures” or by contacting your Financial Advisor. Please retain a copy of this brochure, as it contains important information about our financial planning services. Capitalized terms used in this section have the meanings assigned to them in the main body of this brochure. Page 2 of 14 SF1602-3/26  TABLE OF CONTENTS EXECUTIVE SUMMARY ....................................................................................................................................................................... 4 OUR SERVICES AS AN INVESTMENT ADVISER ........................................................................................................................... 4 ADVISORY BUSINESS – FEE-BASED FINANCIAL PLANNING ................................................................................................... 5 FEES AND COMPENSATION FOR FEE-BASED FINANCIAL PLANNING SERVICES ........................................................... 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ....................................................................................... 8 TYPES OF CLIENTS ............................................................................................................................................................................... 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS ...................................................................... 8 DISCIPLINARY INFORMATION ......................................................................................................................................................... 9 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ....................................................................................... 10 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING ...... 11 BROKERAGE PRACTICES RELATING TO FEE-BASED FINANCIAL PLANNING SERVICES ......................................... 11 REFERRAL PROGRAMS…………………………………………………………………………………………………………….12 REVIEW OF ACCOUNTS .................................................................................................................................................................... 13 CLIENT REFERRALS AND OTHER COMPENSATION ............................................................................................................... 13 CUSTODY ............................................................................................................................................................................................... 14 INVESTMENT DISCRETION .............................................................................................................................................................. 14 VOTING CLIENT SECURITIES ......................................................................................................................................................... 14 FINANCIAL INFORMATION ............................................................................................................................................................. 14 Page 3 of 14 SF1602-3/26  EXECUTIVE SUMMARY investment recommendations are suitable and consistent with each client’s stated objectives and goals, and the duty of loyalty, including the obligation to provide the client with full disclosure of material conflicts of interest. Our duties of care and loyalty differ depending on the authority that a client has granted us and the services that we have agreed to provide – for example, whether we have agreed to provide non-discretionary versus discretionary services or when we provide episodic (e.g., financial planning) versus continuous advice. About Stifel, Nicolaus & Company Stifel, Nicolaus & Company, Incorporated (“Stifel”) is a broker- dealer that has been registered with the SEC since 1936 and an investment adviser that has been registered with the SEC since May 7, 1975. Stifel is owned by Stifel Financial Corp., a publicly held company whose common stock trades under the symbol “SF.” Stifel is a leading full-service wealth management, investment advisory, and broker-dealer and investment banking firm, serving investment and capital needs of clients. Stifel is a member of the Financial Industry Regulatory Authority (“FINRA”), the Securities Investor Protection Corporation (“SIPC”) and various exchanges. Information about Stifel’s qualifications, business practices, portfolio management techniques, and affiliates is accessible on our website at Stifel.com as well as via publicly available filings with the SEC at adviserinfo.sec.gov. In this brochure, the pronouns “we,” “our,” “us,” and similar words will refer to Stifel. The pronouns “you,” “your,” and similar words will refer to you as the Client. References to the singular throughout this brochure include the plural and vice versa. Capitalized terms shall have the meanings assigned to them in this brochure. Our investment advisory agreements with clients define the services we have undertaken to provide and the related duty of care when providing those services. We can limit the duties owed to clients through disclosures (which may be verbal or in writing) – for example, through this disclosure brochure or other disclosures provided to you, we will disclose information about additional activities or compensation arrangements that we have that will impact the services that we provide to you; those disclosures will serve to limit our duty of loyalty to you, and we will take your continued willingness to engage us and your execution of the fee-based Financial Planning Agreement as your consent and authorization to engage in the activities disclosed. Additional information about our fiduciary obligations, including some of the policies and procedures that we undertake to fulfill those obligations, is available throughout this brochure, including under the section entitled “Participation or Interest in Client Transactions.” While we provide investment advisory services to a vast array of clients (including individuals, corporations and other businesses, pension or profit sharing plans, employee benefit plans, trusts, estates, charitable organizations, state and municipal government entities, private funds, educational institutions, insurance companies, and banks and thrift institutions), our fee-based financial planning services are generally provided to individual clients. Services We Provide Our investment advisory representatives (whom we refer to as Financial Advisors) work with their clients to determine appropriate services for each client in consideration of the client’s financial goals and circumstances. Based on the services you request, our firm can provide broker-dealer services, investment advisory services, or both. We offer fee-based financial planning as an investment advisory service. Our role as investment adviser is separate from any role Stifel may play as broker-dealer. Once we deliver a finalized financial plan to you, you can decide whether to implement the recommendations in the plan via brokerage accounts, advisory programs, or a combination, depending on your needs and preferences. Most of our Financial Advisors are qualified and licensed to provide both brokerage and investment advisory services. When we act as an investment adviser in providing financial planning services to you, we will (i) assess a fee to cover those services, (ii) enter into a written Financial Planning Agreement with you expressly acknowledging our investment advisory relationship with you and describing our obligations to you during the engagement, and (iii) give you a copy of this Form ADV Part 2A – Financial Planning Disclosure Brochure, which provides detailed information about our fee-based financial planning services as well as, among other things: the range of fees we charge for those services, our other business activities and financial industry affiliations, and the conflicts between our interests and your interests when providing investment advisory services to you. It is important to understand that brokerage services are separate and distinct from investment advisory services, and different laws, standards of care, and separate contracts with clients govern each. While there are similarities among brokerage and investment advisory services, our firm’s contractual relationship with, and legal duties to, clients are subject to a number of important differences depending on whether we are acting in a brokerage or investment advisory capacity. OUR SERVICES AS AN INVESTMENT ADVISER When we serve as investment adviser to clients, we are considered to have a fiduciary relationship with the client and are therefore held to the legal standards set forth in the Investment Advisers Act of 1940 (the “Advisers Act”), certain state laws, and common law standards applicable to fiduciaries. These standards include the duty of care, including the obligation to have a reasonable basis for believing that our In addition to our fee-based financial planning services, our investment advisory services include discretionary and non- discretionary advisory services, which generally involve account or portfolio management, as well as recommendations of securities or of investment advisers to manage all or a portion of client assets. The investment advisers that our Financial Advisors recommend to clients include both firms that are independent of our firm as well as firms owned (including indirectly or in part) by our parent company, Stifel Financial Corp. These other investment advisory services are covered by and discussed in our Page 4 of 14 SF1602-3/26  • Retirement Analysis Advisory Consulting Services and/or Wrap Fee Programs Disclosure Brochures, which are available on our website at stifel.com/disclosures/investment-advisory-services/program- disclosures. - Goal funding retirement analysis calculating the results of your plan by running one thousand trials, where each trial has a different sequence of returns. The analysis identifies the probability of funding all of your goals without exhausting all your resources over your estimated time horizon. • Net Worth Overview - A snapshot of your current financial position looking at the difference between your assets and liabilities. • Asset Allocation Comparison - Compares the allocation of your current portfolio to a target Please note that although we act as your investment adviser in providing fee-based financial planning services to you, this does not affect any other relationship you may have with us. The nature of existing accounts or accounts you may open in the future, your rights and obligations relating to these accounts, and the terms and conditions of any account agreement in effect now or in the future do not change in any way because you are receiving fee-based financial planning services from us. risk-based portfolio. Identify changes associated with investment strategies and allocation changes you should consider. • Insurance Needs Analysis - Analyzes whether you have adequate investment assets and resources to support your family if you passed away earlier than expected. - Compares your income needs to your income sources across multiple disability periods. - Identifies how an extended Long-Term Care event could Brokerage Financial Planning Services In contrast to the fee-based financial planning services that are covered by this Disclosure Brochure, most of our Financial Advisors offer similar financial planning services without a separate fee or charge. We consider those financial planning services to be brokerage-only services, which are not covered by a fiduciary relationship between our firm and the applicable client. adversely impact your investment portfolio. • General Estate Planning Overview - Reviews your current estate situation and estimate the value of your estate at death. You should review the services that you are contracting for with your Financial Advisor, including whether similar services may be provided as brokerage-only financial planning and, therefore, at no separate charge to you. ADVISORY BUSINESS – FEE-BASED FINANCIAL PLANNING The specific topics covered in each financial plan will be as agreed-up between you and your Financial Advisor. The written financial plan that is ultimately delivered to you may be prepared directly by your Financial Advisor, or may be prepared by members of our Wealth Planning Department on behalf of your Financial Advisor. In general, the written financial plan is intended to assist you in assessing your individual financial goals and to serve as a basis for further analysis and discussion between you and your financial, legal, and tax advisers toward developing a suitable investment strategy for pursuing your financial goals. Scope and Limits of Services Provided As part of our fee-based financial planning services, our Financial Advisors will provide a personalized financial plan designed to help you assess your financial situation and pursue your long-term financial goals and objectives. The financial planning process is meant to be a collaborative experience tailored to your personal goals and customized to the complexity of your financial circumstances. To make the most of the planning services, we recommend that you establish clear and measurable financial goals and provide specific and accurate information. Topics or Areas Not Covered By a Plan. Our financial plans do not address every aspect of a client’s financial life (e.g., areas not covered include analysis of property and casualty, homeowners, and excess liability coverage, etc.). In addition, a topic may not be included in your financial plan for a variety of reasons (for example, because we did not receive sufficient data from you to complete an analysis); unless we explicitly state otherwise, you should not take any such omission as an indication that the topic is not applicable to your particular financial situation. Also, unless otherwise requested and approved by the Wealth Planning Department, our financial planning services will not include an analysis of your estate planning documents and/or income tax returns. You should seek the counsel of your legal and tax advisors for a complete analysis of your estate and death tax liabilities. At the beginning of the planning process, you will be asked to provide information about your individual financial situation, including your investment goals and objectives and your risk tolerance. We rely on the information that you provide to create a personalized financial plan for you, and therefore, it is critical that we gather as complete a picture of your financial situation as possible. For this reason, we may ask for copies of your financial documentation, such as bank and brokerage statements, employee benefits statements, insurance policies, etc., all of which will assist us in understanding your financial situation. We are not obligated to monitor changes in your life or financial circumstances prior to delivery of the plan. You should notify us promptly if you experience any significant changes in your life or financial situation while we are working on your financial plan. We will use the information you provide to prepare our financial planning recommendations and guidance, which may cover a variety of topics, including (for example): No Verification of Outside Assets Analyzed. In developing a financial plan for you, we may consider and analyze information relating to assets that you hold at other financial institutions if you have provided us the relevant information. In considering such Page 5 of 14 SF1602-3/26  We do not include financial planning in our calculation of assets for this purpose. information, we will assume that the information that you have provided is accurate and will not take any steps to verify or ensure the accuracy of information regarding any assets that are held outside of Stifel. FEES AND COMPENSATION FOR FEE-BASED FINANCIAL PLANNING SERVICES How We Charge for Fee-Based Planning Services We generally charge up to $5,000 for our fee-based financial planning services; in limited circumstances, we may allow certain Financial Advisors to charge more in connection with particularly complex client situations and related planning services. No Tax or Legal Advice. Our firm (and our Financial Advisors) do not provide tax or legal advice. You should not consider any information that is presented in a financial plan regarding potential tax considerations as tax or legal advice, and should not use such information for the purpose of avoiding any tax penalties or liabilities. As we do not provide legal or tax advice, we recommend coordinating with your independent legal and tax advisers during the financial planning process so that they may assess any legal and tax issues relating to the strategies we recommend. If you are not comfortable involving those advisers during our financial planning arrangement with you, you should separately consult with your legal or tax advisors to review your personal circumstances. A Financial Advisor’s fees will vary depending on, among other things, the complexity of a client’s financial situation, the scope and range of services to be provided, the amount and type of assets to be taken into consideration, as well as whether the fee is to be paid directly by the client or through employer-sponsored programs. You can negotiate the fee that you will pay with your Financial Advisor. You can select the following payment methods for paying your fee – you will need to indicate the method that you have selected on your Financial Planning Agreement with us: Residency Assumption in Our Plans. Our financial planning services assume that you are a U.S. citizen or resident, and are subject to U.S. taxes. Our financial planning services may therefore not be applicable to or appropriate for you if you are subject to other tax jurisdictions and requirements. Payment By Check You may elect to pay the financial planning fee by issuing a check to us; the fee will be due upon your receipt of the financial plan. The fee amount will be indicated on your agreement with us – we do not typically issue an invoice for the financial planning fee, but may do so upon request. If we do not receive payment from you within a reasonable period after you have acknowledged receipt of a written plan, we reserve the right to automatically debit the amount from any non-retirement accounts that you may hold at Stifel. Implementation of Recommendations. Our fee-based financial planning services will not cover any initial or ongoing advice as to specific securities or investments, or investment strategies in which you should invest. Similarly, we will not analyze the merits of particular investments or securities in the plan that we deliver to you, or at any time as part of our financial planning engagement with you. You are not required to implement any of the recommendations that we provide in a financial plan through our firm. If you decide to let us assist you in implementing the recommendations, you will need to enter into separate agreements with us and open brokerage or investment advisory accounts, as appropriate, to implement the planning recommendations. We generally implement securities transactions in our capacity as a broker-dealer, not as an investment adviser, unless you are participating in one of our investment advisory programs. You will be charged separate fees and/or commissions in connection with services provided to those accounts. No Obligation to Update the Plan. Our fee-based financial planning arrangement with you terminates upon our delivery of a finalized financial plan to you. Our Financial Planning Agreement with you and the fiduciary relationship created under such Agreement will end when a final plan is delivered. We will be under no obligation to update the financial plan to reflect changes in your life events or financial situation that occur after delivery of the plan. Payment By Automatic Debit If you have one or more accounts at Stifel, you can authorize us to deduct the fee from any of your accounts. In such case, the fee will be deducted first from available cash or cash equivalents including money market funds in the account. Under the terms of your Financial Planning Agreement with us, if the cash and cash equivalent in the account is not enough to pay the fee, you will be considered to have authorized us to rebalance or liquidate securities in the account in order to generate sufficient funds to cover the fee in the following order: first, we liquidate mutual fund positions, followed by equities securities (including ETFs), unit investment trusts, corporate bonds, municipal bonds, and any other securities. Your monthly customer account statement will reflect the amount deducted from your account to cover the financial planning fee. You should review your statement carefully and let your Financial Advisor know if you have any questions or concerns. Certain account types, e.g., retirement accounts such as IRAs, may not be used to pay fees for financial planning services. Acknowledgment of Receipt. You will be asked to sign an acknowledgment of receipt upon delivery of a plan to you; the financial planning fee will be due at that time. Additional Information Relating to Fees As discussed above, most of our Financial Advisors provide planning services at no additional charge. You should therefore consider and discuss with your Financial Advisor whether you may be able to get some or all of the financial planning services at no additional charge. As set forth above, the fee that you pay for Assets Under Management As of December 31, 2025, we managed approximately $126,839,531,130 of client assets on a discretionary basis, and advised on $70,692,702,372 on a non-discretionary basis. Page 6 of 14 SF1602-3/26  financial planning services will not cover the costs and charges associated with implementing any of the recommendations that may be contained in the plan. Compensation to Financial Advisors Production. We pay a percentage (“Payout Rate”) of the Stifel Advisory Fee that we receive from you to your Financial Advisor(s). Payout Rates generally range from 25% to 50%; the applicable percentage paid to your Financial Advisor will depend on your Financial Advisor’s employment agreement and arrangements with us and the total amount of revenue your Financial Advisor generates from all clients (including from brokerage clients) (referred to as “Production”). Our compensation to the Financial Advisor can also include a bonus that is also based on the Financial Advisor’s Production. Recruiting Transition Assistance. Some Financial Advisors are eligible for special incentive compensation and other benefits based on client assets in accounts at our firm (including assets held in your retirement accounts) and the Production the Financial Advisor generates for us (including in connection with brokerage accounts). These incentives and benefits can be in the form of recruitment and retention bonuses, and eligibility for repayable loans or loans for which repayment is made under certain conditions, for your Financial Advisor by an entity affiliated with us. These incentives and benefits generally increase as the Financial Advisor brings more client assets to us and generates more revenue. These benefits create an incentive for your Financial Advisor to recommend that you transition accounts held at other financial institutions to our firm, as well as to recommend certain transactions, products, and services over others in order to obtain the benefits. Branch Manager/Supervisory Activities. In addition, we pay compensation to branch managers based on aggregate Production generated by the Financial Advisors operating from the manager’s branch office. In some cases, a portion of a Financial Advisor’s Production can result in compensation to his or her branch manager or another Financial Advisor for supervision and administrative or sales support. When a supervisor is compensated based on the Production of the person he or she is supervising, the supervisor has an incentive for you to make investments that generate greater compensation for the supervisor. The particular compensation arrangements between your Financial Advisor and his or her branch manager also create incentives for your Financial Advisor to recommend transactions, investment products, and services that generate greater amounts of revenue for us, the branch manager, and your Financial Advisor. Your Financial Advisor’s Payout Rate will be the same regardless of the Advisory Program in which your accounts are enrolled. However, as a general matter, your Financial Advisor’s total cash compensation increases as his or her Production increases, and this creates an incentive for your Financial Advisor to recommend certain Programs or Portfolios over others and/or other products or services in order to increase his or her Production. In connection with the Programs covered by this brochure, we mitigate these conflicts by limiting Advisory- related Production compensation to Stifel’s share of the Advisory Account Fees (that is, your Financial Advisor generally does not share in any additional fees and expenses that your account incurs as a result of types of investments made (or transactions effected) in the account). We also seek to mitigate these conflicts by disclosing them to you, and by establishing other risk-based supervision policies and procedures (including, e.g., to review certain new Advisory account enrollments). Outside Business Activities. Your Financial Advisor is permitted to engage in certain business activities approved by us, other than the provision of brokerage and advisory services through Stifel. In certain cases, these outside business activities can cause conflicts with the Advisory services that your Financial Advisor provides to you and your account(s). We mitigate these conflicts by requiring your Financial Advisor to disclose to us and obtain approval for outside business activities by establishing certain other policies and risk-based procedures to the approval of outside business activities. Where such activities are deemed material (as determined by regulation), we disclose them to you through the Financial Advisor’s Form ADV Part 2B. Discount Sharing. Financial Advisors receive less than their standard payout when accounts are priced below the set minimum fee level for the applicable Program. While Financial Advisors may be allowed to set the Stifel Fee for an account below the minimum fee level, doing so typically results in a reduction to the Financial Advisor’s Payout Rate (generally referred to as discount sharing) potentially down to 0%. The fee levels at which discount sharing starts to apply vary by Program and/or style: for example, the discount sharing level for equity strategies is different than for fixed income strategies. In general, discount sharing creates an incentive for Financial Advisors to price accounts above the set minimum fee level in order to receive their standard Payout Rate. Compensation to Members of Wealth Planning Department Members of our Wealth Planning Department may assist your Financial Advisor in creating and/or delivering fee-based financial planning services to you. These professionals do not receive a direct share of the fees that you pay for such financial planning services. Instead, they receive a base salary and are eligible for discretionary incentive compensation based on the performance of the firm in general as well as their individual performance. Compensation From Third Parties. Our financial plans do not include specific securities recommendations, and therefore, we do not receive any compensation from third parties in connection Other Benefits. Equity awards from our parent company, SF, are a standard component of our Financial Advisors’ compensation. Your Financial Advisor is eligible to receive other benefits based on his or her Production. These benefits include recognition events, conferences (e.g., for education, networking, training, and personal and professional development), and other forms of noncash compensation that generally increase in value as the amount of the Production your Financial Advisor generates increases. These benefits create an incentive for your Financial Advisor to recommend certain Programs over others and/or transactions, products, and services that generate additional fees and expenses in order to obtain the most benefits. Page 7 of 14 SF1602-3/26  The team also evaluates the related work of key research providers and other industry experts. The goal is to make sound estimates, and sometimes insights come from experts outside our investment team. with our financial planning recommendations to you. If you decide to implement the planning recommendations through our firm, we can separately recommend specific securities or investments and, depending on our capacity as broker-dealer or investment adviser, and other factors, we will directly receive compensation from third parties in connection with those recommendations. You should refer to the disclosures provided in connection with the brokerage and/or investment advisory accounts that you open with us for information about the different types of compensation that we receive in connection with recommendations of specific securities or investments. The capital market assumptions may change from time to time at Stifel IS’ discretion. The team has changed its risk and return assumptions in the past and may do so in the future. Your Financial Advisor will not provide you with an updated plan automatically based upon changes to these or other underlying assumptions, but (subject to additional fees) you may request an updated plan from your Financial Advisor. Changes in the assumptions may affect your target asset allocation. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Stifel does not charge performance-based fees in connection with its investment advisory services. TYPES OF CLIENTS Please refer to the Executive Summary for a description of the types of clients to whom we generally provide investment advice, including fee-based financial planning services. Our firm may also add or remove asset classes from the allocation methodology at any time. Once our agreement for financial planning services has ended, we are not required to provide you with an updated analysis based upon changes to these capital market assumptions or other assumptions used in the plan, or resulting changes to your target allocation. It is important to note that implementing changes to your target allocation may result in tax consequences to you. Please consult your tax advisor if this occurs. There is no minimum account size or minimum fee requirements for financial planning services. METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS We employ a variety of asset allocation models and tools across our firm. As a result, our modeling in programs outside of financial planning services may vary depending upon the asset allocation model, amount invested, and software program used for analysis. Limitations on Statistical Analysis: Forward-looking analyses are presented based upon various risk and return assumptions developed by the Stifel IS team. In addition, historical statistical data, based on the performance of various market indices, may be provided in the financial planning reports to show relative historic risk and return information regarding the asset allocation strategies presented. Probabilistic modeling (which presents the likelihood that the client may be able to achieve certain goals) may be presented using forward- looking or historical assumptions, is hypothetical in nature, does not reflect actual investments results, and is not a guarantee of future results. These analyses do not analyze specific securities. Rather, the asset allocation presented is analyzed. Actual market conditions may result in outcomes significantly different than those illustrated. With respect to probabilistic modeling, the results may vary over time and with each use if any of the underlying assumptions or profile data is adjusted. In addition, the analysis does not present the results that could occur from an extreme market event, either positive or negative, due to the low probability of such an occurrence. The analyses and reports included in your financial plan will describe the applicable basis, limitations, and potential risks. Please review this information carefully. Our Asset Allocations Our fee-based financial planning services typically include asset allocation recommendations. Our asset allocations are based on a proprietary methodology. In developing those allocations, our Investment Strategy Group (“Stifel IS”) considers asset class risk and return results that are based on estimated forward-looking return and risk (measured by standard deviation) assumptions (“capital market assumptions” or “CMAs”). These CMAs are also based on our proprietary research, with the development process including a review of a variety of factors, such as the return, risk, correlations and historical performance of various asset classes, and inflation. CMAs have multiple uses, including developing strategic asset allocations, custom portfolio analysis, and risk monitoring. The CMAs are used in developing asset allocation models for financial planning purposes, and can be also used under certain circumstances in developing investment portfolios. Stifel IS periodically reviews the economic or market conditions or other general investment considerations that it believes may impact the capital market assumptions. For key asset classes, Stifel IS uses a building block approach by estimating the key components of return. For example, our U.S. Large Cap Equity return assumption includes estimates for inflation, real earnings growth, and dividend yield. Our fixed income return assumption includes an estimate for cash yield, a term premium for investing in longer bonds, and a credit premium for investing in bonds not guaranteed by the U.S. government. Importantly, Stifel IS utilizes a survey process for this work, and seeks input from colleagues across our organization, based on areas of expertise. Those analyses and/or reports will be developed based on information that you provide. The accuracy of the analysis is dependent upon your providing accurate and complete data. The results presented in any analysis or report are not guarantees of future results. Page 8 of 14 SF1602-3/26  and WSPs regarding the cited supervisory deficiencies prior to the entry of the AWC. 3. In March 2019, Stifel, along with 78 other investment Our personnel make a number of assumptions during the financial planning process. These assumptions may turn out to be wrong, and as a result, your returns may be less than anticipated. While we attempt to provide recommendations that are designed to assist you in meeting your stated goals and objectives, we cannot and do not guarantee that you will meet all of your goals and objectives by following our recommendations. The economic environment (including, the rate of inflation, prevailing tax rates, etc.) that you experience as you implement the recommendations may vary from the assumptions made in creating the plan. Similarly, the rate of return that your investments are able to achieve will likely also vary from the assumptions in the plan, all of which will impact your ability to reach your financial planning goals. While our financial plans do not include specific investment recommendations, in evaluating the recommendations covered by the plan, you should understand that all investments involve risks. These risks include (but are not limited to) the risk that an investment’s value will decline because of downturns in the general securities markets. You should consider each investment’s risks and expenses carefully before investing in any security. Please refer to our Advisory Consulting Services and/or our Wrap Fee Programs Disclosure Brochures for detailed discussions of our investment strategies and methods of analysis used in connection with the investment advisory services provided under those brochures. advisers who voluntarily participated in the SEC’s Share Class Selection Disclosure Initiative, consented to the entry of an Order Instituting Administrative and Cease-and-Desist Proceedings Pursuant to Sections 203(e) and 203(k) of the Investment Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order (the “Order”) by the SEC instituted pursuant to Sections 203(e) and 203(k) of the Advisers Act without admitting or denying the findings therein except those related to jurisdiction and the subject matter of the proceedings. The Order entered against Stifel alleged that Stifel willfully violated Sections 206(2) and 207 of the Advisers Act as a result of its inadequate disclosure of conflicts of interest related to (a) the selection of mutual fund share classes that charged 12b-1 fees, which are recurring fees deducted from fund’s assets, when an alternative share class was available that did not charge a 12b-1 fee, and (b) the receipt of 12b-1 fees in connection with these investments. The SEC did not impose a civil penalty against Stifel in recognition of the fact that Stifel self-reported the issue to the SEC. However, Stifel was censured and ordered to cease-and-desist from committing or causing any violations and future violations of Sections 206(2) and 207 of the Advisers Act, pay disgorgement and pre-judgment interest in the amount of $6,037,175.98 to affected investors, and comply with several undertakings related to notifying affected investors of the terms of the Order. DISCIPLINARY INFORMATION 4. On January 26, 2018, Stifel entered into a Letter of 1. On September 24, 2024, in connection with the industry- wide sweep into off-channel communications, the SEC entered an administrative order against Stifel, Nicolaus & Company, Incorporated (“Stifel” or the “Firm”). The SEC found that the Firm willfully violated Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder, as well as Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder, due to recordkeeping failures related to electronic communications. The Firm also failed to reasonably supervise its personnel to prevent or detect aiding and abetting violations of these sections. The SEC ordered Stifel to cease and desist from committing or causing any violations, censured the Firm, and imposed undertakings including retaining an independent compliance consultant. Additionally, a civil money penalty of $35,000,000 was imposed. 2. On September 1, 2020, Stifel entered into a Letter of Acceptance, Waiver, and Consent (“AWC”) with FINRA to settle allegations that the firm (i) traded ahead of certain customer orders at prices that would have satisfied the customer orders; (ii) did not maintain adequate supervisory controls that were reasonably designed to achieve compliance with FINRA Rule 5320 and Supplementary Material .02 of FINRA Rule 5320; and failed to report an information barrier identifier with its order audit trail system (OATS) submission for certain orders. These allegations were considered to be violations of FINRA Rules 2010, 3110, 7440(b)(19), and NASD Rule 3010. While not admitting or denying the allegations, the firm consented to a censure, monetary fine of $37,500, plus interest of $318.25, restitution payments to affected investors, and an undertaking to revise its written supervisory procedures relating to Rule 5320 and Supplementary Material .02 of FINRA to settle these allegations. 5. On January 26, 2018, Stifel entered into an AWC with FINRA to settle allegations that the firm failed to report to the Trade Reporting and Compliance Engine (“TRACE”) transactions in TRACE-eligible securitized products within the time required by FINRA Rule 6730. While not admitting or denying these allegations, the firm agreed to a censure and a fine of $17,500. 6. On November 3, 2017, Stifel entered into a consent Acceptance, Waiver, and Consent (“AWC”) with FINRA to settle allegations that, during the period of October 31, 2017 through February 27, 2020, the firm lacked a supervisory system, including written supervisory procedures (WSPs), reasonably designed to detect and prevent Stifel and its registered representatives from executing pre-arranged transactions in violation of Municipal Securities Rulemaking Board (MSRB) Rule G-27. While not admitting or denying the allegations, the firm consented to a censure and monetary fine of $40,000 to settle the allegations. As indicated in the AWC, Stifel updated its supervisory system agreement with the State of North Carolina, as part of a multi-state task force agreement, regarding the sale of Page 9 of 14 SF1602-3/26  directing Stifel to cease and desist from violating Rule 5.15 of the Mississippi Securities Act of 2010, a books and records rule, and to pay the Division $49,500 on its behalf as well as $500 on behalf of the former registered representative. 10. On December 6, 2016, a final judgment (“Judgment”) was securities commonly known as Auction Rate Securities (“ARS”). The state regulatory authority claimed that Stifel failed to reasonably supervise the sales of ARS by failing to provide sufficient information and training to its registered representatives and sales and marketing staff regarding ARS and the mechanics of the auction process applicable to ARS. As part of the consent agreement, Stifel agreed to pay the state $18,088.80, to cease and desist from violating securities laws and regulations, to retain at Stifel’s expense a consultant to review the firm’s supervisory and compliance policies and procedures relating to product review of nonconventional investments, and repurchase certain auction rate securities from the firm’s clients. 7. In June 2017, Stifel entered into an AWC with FINRA to entered against Stifel by the United States District Court for the Eastern District of Wisconsin (Civil Action No. 2:11-cv- 00755) resolving a civil lawsuit filed by the SEC in 2011 involving violations of several antifraud provisions of the federal securities laws in connection with the sale of synthetic collateralized debt obligations (“CDOs”) to five Wisconsin school districts in 2006. As a result of the Order, Stifel is required to cease and desist from committing or causing any violations and any future violations of Section 17(a)(2) and 17(a)(3) of the Securities Act, and Stifel and a former employee are jointly liable to pay disgorgement and prejudgment interest of $2.5 million. Stifel was also required to pay a civil penalty of $22 million. The Judgment also required Stifel to distribute $12.5 million of the ordered disgorgement and civil penalty to the school districts involved in this matter. settle allegations that Stifel did not provide timely disclosures to a municipal issuer in connection with its role as placement agent in a placement of bonds issued by the municipal issuer in accordance with interpretive guidance issued by the Municipal Securities Rulemaking Board (“MSRB”) regarding MSRB Rule G-23. In May 2012, Stifel recommended that the issuer do a placement, in lieu of a public offering, in order to save on debt service costs. The issuer accepted Stifel’s recommendation and agreed that Stifel would serve as placement agent. However, Stifel did not provide the disclosures regarding its role in a timely manner. As a result, the firm was alleged to have violated MSRB Rule G-23 by serving as both financial advisor and placement agent on the same issue. While not admitting or denying the allegations, Stifel agreed to a regulatory censure and a monetary fine of $125,000. 11. On April 8, 2016, Stifel entered into an AWC with FINRA to settle allegations that the firm used permissible customer- owned securities as collateral for bank loans procured by the firm. However, on several occasions over a period of years, prior to performing its customer reserve calculation, Stifel substituted those loans with loans secured with firm-owned collateral. The substitution thereby reduced the amount that Stifel was required to deposit into the Customer Reserve Account. FINRA found the practice to be a violation of applicable rules, including Section 15I of the Securities Exchange Act of 1934 and Rule 15c3-3(e)(2) thereunder. Throughout the relevant period, the firm had sufficient resources to fund the Customer Reserve Account even if the substitutions had not occurred. While not admitting or denying the allegations, the firm consented to a censure and fine of $750,000. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS 8. In March 2017, Stifel consented to the entry of a Cease and Desist Order (“Order”) by the SEC in which Stifel was found to have violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder by failing to adopt or implement adequate policies and procedures to track and disclose the trading away practices of certain Investment Managers in several of Stifel’s discretionary wrap fee programs, including information about additional costs incurred by clients as a result of the Investment Manager’s use of another broker to execute transactions away from Stifel. Stifel neither admitted nor denied the findings contained in the Order, except those related to jurisdiction and the subject matter of the proceeding. Stifel made several undertakings enumerated in the Order related to the trading away practices of third-party managers, including a review and update of its policies and procedures, providing information to financial advisors and clients, and training financial advisors. Stifel was ordered to pay a civil penalty of $300,000 and ordered to cease and desist from violating Section 206(4) and Rule 206(4)-7 thereunder. 9. On January 4, 2017, an Administrative Consent Order As set forth above, our firm is dual registered as an investment adviser and a broker-dealer, and is also a licensed insurance agency with various states. We have a number of affiliates that are registered as investment advisers or broker-dealers (or both). A number of our affiliated investment advisers serve as fund manager to various registered investment companies (mutual funds). None of these affiliates provide services to our clients in connection with the fee-based financial planning services covered by this brochure. In addition to being registered representatives of Stifel, some of our management persons may be registered representatives of these affiliated broker-dealers. Similarly, some of our management persons may be management persons of our affiliates, included affiliates that are registered investment advisers. Finally, some of our management persons may be licensed to practice law in various states. These individuals do not provide legal services to advisory clients, including clients to whom we provide fee-based financial planning. (“Order”) was entered against Stifel and a former registered representative associated with Stifel by the Securities Division of the Mississippi Secretary of State (“Division”) resolving an investigation into certain activities occurring in two branch offices during the period of September 2000 through November 2013. Without admitting or denying the findings in the Order, Stifel agreed to the entry of the Order Page 10 of 14 SF1602-3/26  periodically review securities holdings in the accounts of persons who may have access to advisory recommendations. You should refer to our Advisory Consulting Services and/or Wrap Fee Programs Disclosure Brochures for a more detailed discussion of our firm’s other industry activities and affiliations applicable to our other investment advisory services. Since our financial planning recommendations do not include recommendations of specific securities, we do not anticipate any conflicts between the financial planning recommendations and the personal trading by our associated persons. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING BROKERAGE PRACTICES RELATING TO FEE-BASED FINANCIAL PLANNING SERVICES Code of Ethics In addition to Stifel Financial Corp.’s Code of Ethics Policy, which is applicable to all Stifel personnel, our Advisory personnel are also subject to our Investment Advisory Code of Ethics (“IA Code of Ethics”). A copy of the IA Code of Ethics is available upon request. Set forth in the IA Code of Ethics are standards reasonably designed to promote honest and ethical conduct, comply with federal securities laws and governmental rules and regulations, maintain privacy of Client information, protect nonpublic information, and encourage associates to report any known violations. Such standards include placing Client interests first, avoiding any material or potential conflicts of interest, and ensuring that personal securities transactions are conducted appropriately. Compliance periodically reviews the IA Code of Ethics to ensure adequacy and effectiveness in complying with applicable regulations. About Our Broker-Dealer Our firm’s principal business in terms of revenue and personnel is that of a securities broker-dealer. As a broker-dealer, we execute securities transactions per client instructions. As an integral part of the services offered, when providing brokerage services, Financial Advisors may assist clients in identifying investment goals, creating strategies that are reasonably designed to meet those goals, and making suitable buy, hold, and sell recommendations based on risk tolerance and financial circumstances. However, Financial Advisors do not make investment decisions on behalf of clients and do not charge any fees for any incidental advice given when providing brokerage services. Absent special circumstances, Financial Advisors are not held to fiduciary standards when providing brokerage services. Legal obligations to disclose detailed information about the nature and scope of our business, personnel, commissions charged, material or potential conflicts of interest, and other matters, are limited when acting as a broker-dealer Our Responsibilities as a Broker-Dealer As a broker-dealer, our firm is held to the legal standards of the Securities Act of 1933, the Securities Exchange Act of 1934, FINRA rules, and state laws where applicable. Such standards include fair dealings with Clients, reasonable and fair execution prices in light of prevailing market conditions, reasonable commissions and other charges, and reasonable basis for believing that securities recommendations are suitable. Brokerage clients generally pay commission charges for transactions executed in their brokerage accounts. Participation or Interest in Client Transactions We do not execute transactions as part of our fee-based financial planning services. If you implement our financial planning recommendations by opening an account with us, we will execute transactions for your account pursuant to the terms of agreements that you enter into with us to open that account. Those agreements (and the disclosure documents provided with the agreements) will, among other things, address how and in what capacity we execute transactions for the accounts you open. In general, we offer a wide variety of investment products and services that provide different levels of compensation to our firm and Financial Advisors. As a result, our Financial Advisors have an incentive to favor those investment products and services that generate a higher level of compensation than those that generate a lower level of compensation. For more information about the other investment products and services, the terms and conditions that apply when we provide those products and services, as well as the conflicts that we face in connection with our recommendations and execution of client transactions, you should refer to the agreement(s) and disclosure documents that you receive relating to the accounts that you open with us. Application of Brokerage Services to Fee-Based Financial Planning Clients We do not recommend broker-dealer firms as part of our financial planning services. If you choose to engage Stifel in its capacity as a broker-dealer to implement the recommendations in your financial plan, you will need to sign a separate agreement that will cover the type of brokerage services that our firm is to provide to that account. You should pay particular attention to the disclosures provided with such agreement, as they will also cover the type of fees and charges that could apply to those services. REFERRAL PROGRAMS We generally do not act as investment adviser when making the referrals described in this section. You should consider the referral compensation Stifel and/or your Stifel Financial Advisor may be eligible to receive when evaluating your relationship with us and the reasonability of any fees or other charges you pay us. Personal Trading Our written supervisory procedures are designed to detect and prevent the misuse of material, non-public information by employees. We prohibit transactions in our firm account(s) and accounts of associated persons in any security that is the subject of a recommendation of our Research department until the recommendation has been disseminated to Clients and a reasonable time has elapsed following the dissemination. Our directors, officers, and employees are prohibited from buying or selling securities for their personal accounts if the decision to do so is substantially derived, in whole or in part, by reason of their employment, unless the information is also available to the investing public or through reasonable inquiry. We maintain and Page 11 of 14 SF1602-3/26  Referrals for Trust Services Our parent company, Stifel Financial Corp., along with the Firm (together the “Service Providers”), have entered into Referral, Operating, and Service agreements with our affiliated trust companies – Stifel Trust Company, National Association (“STC”) and Stifel Trust Company Delaware, National Association (“STCD”) (STC and STCD, individually and collectively, sometimes referred to hereafter as the “trust companies”). Pursuant to these agreements, STC and STCD pay the Service Providers for providing services, referral services, and client services. The Service Providers receive, on a quarterly basis, 20% of the net fiduciary fees received by STC and STCD. Specifically, the Firm pays its Financial Advisors a portion of net fees on a monthly basis for the life of the account. Fees shall not be payable with respect to those accounts for which the Service Providers do not provide the referral services or the client services. These payments create an incentive for Financial Advisors to refer you to STC or STCD. There may be an interim period between the time a referral is made and the time the trust companies begin to provide services. Credit Line Loans extended by an Affiliated Bank are typically demand which allows an Affiliated Bank to demand repayment at any time, and are subject to collateral maintenance requirements. If the required collateral value is not maintained, an Affiliated Bank may require additional collateral, or partial or entire repayment of any Credit Line Loans extended. Clients may need to deposit additional cash or securities as collateral on short notice or repay a partial or entire amount of the funds borrowed if the value of their portfolio declines below the required loan-to-value ratio. An Affiliated Bank may refuse to fund any advance request due to insufficient collateral. An Affiliated Bank may increase your collateral maintenance requirement at any time without notice, and may call your Credit Line Loan at any time and for any reason. Because an Affiliated Bank assigns different release rates to different asset types, in some cases, Clients may also be able to satisfy such requirements by selling securities with a low release rate and investing and/or holding the proceeds in assets that have a higher release rate for the loan. In each case, failure to promptly meet requests for additional collateral or repayment, or other circumstances including a rapidly declining market, may cause our banking affiliate to instruct us to liquidate some or all of the collateral supporting any Credit Line Loan in order to meet collateral maintenance requirements without needing your prior approval. You will not be entitled to choose the securities that will be sold. Depending on market circumstances, the prices obtained for the securities may be less than favorable. Any required liquidations may interrupt the account’s investment strategy and may result in adverse tax consequences or additional fees being assessed. Credit Line Loans In some circumstances, Clients are able to use Advisory account assets as collateral for variable or fixed rate credit lines (“Credit Line Loans”) offered by an Affiliated Bank. An example of a Credit Line Loan is the Stifel Pledged Asset (“SPA”) Loan, which is offered by Stifel Bank & Trust. The SPA loan account is subject to application and credit approval by Stifel Bank & Trust. Please refer to the terms and conditions outlined in the Stifel Pledged Asset Loan Account Agreement, which is provided separately to applicants by Stifel Bank & Trust. The Affiliated Banks typically pay us a fee of up to 0.25% per annum, on a quarterly basis, of the outstanding SPA Loan balance, a portion of which is paid to your Financial Advisor. In addition, the Affiliated Banks pay Stifel up to $50 for each newly booked loan, which Stifel will then pay to the Financial Advisor’s Client Service Associate (“CSA”) for the CSA’s assistance to the borrower in completing the related application. Neither we nor Stifel financial advisors currently receive payment on other credit line loans, which is subject to change. Clients repay the principal balance and interest on outstanding balances on Credit Line Loans to Stifel Bank & Trust and/or other Affiliated Bank(s). For variable-rate loans, clients have the option to repay the principal at any time without prepayment fees. If interest rates rise, your borrowing cost will also rise. For fixed-rate loans, clients may be subject to prepayment fees (as described in the loan documents) if the loan is repaid before the end of the fixed-rate contract. The proceeds of certain loans may not be used for the purpose of (a) purchasing, carrying, or trading in securities, (b) repaying or retiring any indebtedness incurred to purchase, carry, or trade in securities, or (c) repaying or retiring any debt, and/or otherwise purchase any product or service, unless consent is provided by the lending Affiliated Bank. These payments are in addition to any Advisory Account Fees charged with respect to the Advisory assets used to collateralize the Credit Line Loan. As such, these payments present a conflict of interest for us in that they create a financial incentive for your Stifel Financial Advisor to make recommendations based on the additional compensation to be received rather than solely based on your financial needs. For example, a Financial Advisor may recommend that you open a Credit Line Loan rather than withdraw money from your Advisory accounts in order to retain the Advisory Account Fee that such assets are otherwise generating and to receive the additional compensation from the banking affiliate with respect to any outstanding Credit Line Loan balance that you maintain. If Advisory account assets are used to collateralize Credit Line Loans, clients are not permitted to withdraw funds or other assets unless sufficient amounts of collateral remain to continue supporting the Credit Line Loans (as determined by the applicable Affiliated Bank, in its sole discretion). Clients may still terminate their Advisory relationship with Stifel at any time, at which time these funds or assets will be maintained in a brokerage account at Stifel. Clients pay interest to the Affiliated Bank on Credit Line Loans at customary interest rates. Certain eligibility requirements must be met and loan documentation must be completed prior to applying for Credit Line Loans. Similarly, a Financial Advisor may recommend the continued maintenance of such Credit Line Loan to retain such payments. Finally, a Financial Advisor may recommend that you invest or hold your Advisory account assets in positions that have been assigned high release rates and/or lower release rates by the applicable Affiliated Bank for the Credit Line Loan (but which positions ultimately generate low investment returns for your Page 12 of 14 SF1602-3/26  the Financial Advisor making the original introduction would be paid a portion of the fees earned on each transaction. Mortgage Lending Residential mortgage loans are loans that are used to purchase a home, refinance an existing mortgage, or to take cash out for other purposes. These loans are secured by residential real estate, and, in certain cases, brokerage or advisory account assets are used to provide additional collateral support for the mortgage loans. Clients repay the principal amount borrowed to Stifel Bank & Trust, plus interest. These loans may have origination fees, application fees, and certain other fees and costs, including closing costs, which are disclosed before the loan is made. Mortgage loans are originated by Stifel Bank & Trust, Equal Housing Lender, NMLS #375103. Your Stifel Financial Advisor, however, does not offer residential mortgage products and is unable to accept any residential mortgage loan applications or to offer or negotiate terms of any such loan. Financial Advisors may refer current clients of Stifel to Stifel Bank & Trust for a mortgage loan. Where permissible by law, the Firm compensates Stifel Financial Advisors in connection with the origination of any mortgage loan. Compensation is paid after the loan is fully closed and funded. Advisory account) in order to avoid maintenance calls on the Credit Line Loan which would require loan repayment and/or the liquidation of Advisory assets. Depending on your specific circumstances, including the intended use of the proceeds from the Credit Line Loan and the return on your Advisory account, over the long term, it may cost you more to take out the Credit Line Loan than if you had withdrawn the money from your Advisory account. Clients are therefore encouraged to carefully consider the total cost of taking out any Credit Line Loan, and any additional compensation that the Financial Advisor will receive, when determining to take out and/or maintain Credit Line Loans. Finally, to the extent that a maintenance call is triggered in connection with a Credit Line Loan and we are obligated to liquidate assets in your Advisory account that have been used as collateral for such Credit Line Loan, we will act solely in our capacity as a broker-dealer (and not as an investment adviser or other fiduciary), even where such collateral is held in an Advisory account. Moreover, if selling such assets, we will seek to maximize our interest (and/or those of our Affiliated Banks),and will not prioritize a Client’s interest. For more information, please refer to the applicable Affiliated Bank credit line agreement. Other Important Considerations Relating to the Use of Margin or Credit Line Loans in Connection With Advisory Accounts. REVIEW OF ACCOUNTS Our Financial Planning engagement with you will terminate when we have delivered a final plan to you. In addition to your Financial Advisor, a member of our Wealth Planning Department will review the plan prior to its delivery for adherence to our standards for fee-based financial plans. Once a plan has been delivered and you have acknowledged receipt of the plan, we do not undertake, in any way, to provide any monitoring or ongoing advisory services to you in connection with the plan. For example, we will not be under any obligation to revise a plan that was previously delivered because you subsequently make us aware of changes to your life or financial circumstances that occur after the plan was delivered. Margin and Credit Line Loans involve risk and may not be appropriate for all borrowers. The return on your Advisory accounts must be higher than your financing cost in order for you to generate a positive return in your Advisory account. The market value of your Advisory account may decline, which may result in the value of that collateral no longer covering an outstanding loan amount. None of the Stifel, our Affiliated Banks, or our Financial Advisors provide legal or tax advice. Clients should consult legal counsel and tax advisors before using borrowed funds as collateral for loans. Neither our firm nor our affiliates act as investment adviser with respect to the liquidation of securities held in Advisory accounts to meet margin calls or Credit Line Loan demands, and as creditors, our firm and our affiliates may have interests that are adverse to Clients. There are substantial risks associated with the use of borrowed funds for investment purposes and the use of securities as collateral for loans. Additional limitations and availability may vary by state. Privacy Policy We will deliver our Private Notice to you as part of the disclosures that are delivered to you in connection with your fee- based financial planning agreement with us. We will not deliver amended or annual Privacy Notices to you, unless you decide to implement the financial planning recommendations with us, in which case you will receive periodic ongoing notices as an account holder and continuing client of the firm. CLIENT REFERRALS AND OTHER COMPENSATION Investment Banking Financial Advisors are able to introduce clients and others to Stifel’s Investment Banking area. Investment Banking helps corporations with raising capital, structuring mergers and acquisitions, and navigating other complex financial issues. If Investment Banking receives any investment banking business resulting from such introductions, on the first three transactions with the client, Stifel’s Private Client Group currently receives a portion of the net fees earned by Investment Banking, a percentage of which will then be paid to the Financial Advisor. It is a benefit to your Financial Advisor, and a potential conflict, to make these introductions. Where appropriate to meet the needs of a client who may not meet the minimum threshold required, Stifel’s Investment Banking department may make an introduction to an unaffiliated partner firm. In these instances, Stifel Alliance Program In general, we require that all solicitation or referral arrangements comply with applicable regulatory requirements, including, but not limited to, disclosures to clients about the referral arrangement as well as any fees received (or paid) in connection with such referral, at the time of the referral or, in any case, prior to the execution of an advisory agreement (including, to the extent applicable, a fee-based financial planning agreement). We have policies and procedures designed to assure that proper disclosures are provided to clients at the time of solicitation Page 13 of 14 SF1602-3/26  CUSTODY and/or account opening, as well as that all clients sign appropriate disclosure delivery receipts. Each affected client will receive disclosures from the applicable solicitor disclosing the solicitation arrangement, as well as the fee that Stifel will pay the solicitor in respect of the solicitation. Our firm will not maintain custody or otherwise require fee-based financial planning clients to maintain their assets at Stifel. To the extent that you implement planning recommendations through our firm, you should note that we generally maintain custody of client assets. If you open investment advisory accounts with us, you should refer to our Advisory Consulting Services and/or Wrap Fee Programs Disclosure Brochures for more detailed discussion of our firm’s custodial practices for investment advisory clients. INVESTMENT DISCRETION Arrangements with solicitors to refer investment advisory clients to our firm are made under our Stifel Alliance Program (“Alliance”). In such arrangements, we compensate individuals or companies for referring investment advisory clients to our firm by sharing a portion of the investment advisory fees that we receive from the referred client(s). Our policies prohibit our Financial Advisors from up-charging any Client to make up for the portion paid to or otherwise expended in connection with an Alliance solicitor. We and/or our associated persons may pay for registration costs (if any) relating to the solicitor to facilitate the solicitor’s state registration (if required). As a result, such solicitors would have incentive to refer clients to Stifel over other firms. Our firm will not exercise investment discretion in connection with our fee-based financial planning services as outlined in this brochure. As set forth above, you are responsible for implementing the recommendations provided in any financial plan, and may elect to implement such recommendations at Stifel or at an unaffiliated financial services company. You should refer to the appropriate Disclosure Brochures for a detailed discussion of the terms and conditions specific to the program(s) in which you decide to enroll. VOTING CLIENT SECURITIES Compensation From Third Parties for Client Referrals We may refer fee-based financial planning clients to third parties for investment advisory services and, therefore, will receive referral fees for such activities. Our disclosure brochures for non-fee-based investment advisory services contain information about these arrangements – you should refer to those disclosures for more details. We do not accept proxy voting authority from clients in connection with our fee-based planning services. We accept proxy voting delegation from clients that receive other investment advisory services from our firm. You should refer to the appropriate disclosure brochure for more details about our proxy voting policies and practices applicable to any other advisory program in which you decide to enroll. FINANCIAL INFORMATION Stifel does not have any adverse financial conditions to disclose. Page 14 of 14 SF1602-3/26