WRAP FEE PROGRAM BROCHURE

OneSeven 24400 Chagrin Blvd Suite 200 Beachwood, OH 44122 Telephone: 216-771-4242 Facsimile: 216-771-4274 www.weareoneseven.com www.mgo-inc.com April 21, 2026 PART 2A - APPENDIX 1 WRAP FEE PROGRAM BROCHURE OneSeven is no longer accepting new clients into the Wrap Fee Program unless prior approval is received from the Chief Compliance Officer. Typically an exception will only be granted to clients that are currently in a wrap fee account /program at another firm and are transferring their assets to OneSeven. This is effective April 1, 2024. This Form ADV 2A ("Disclosure Brochure") provides information about the qualifications and business practices of ne Seven ("OneSeven" or the "Advisor"). Certain Advisory Persons of One Seven may also conduct business under other business names. If you have any questions about the contents of this Disclosure Brochure, please contact us at (216) 771-4242. OneSeven is a registered investment advisor with the U.S. Securities and Exchange Commission ("SEC"). The information in this Wrap Fee Program Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Wrap Fee Program Brochure provides information through OneSeven to assist you in determining whether to retain the Advisor. Additional information about OneSeven and its Advisory Persons are available on the SEC's website at www.adviserinfo.sec.gov by searching for our firm name or by our CRD # 283087. 1  Item 2 Summary of Material Changes Form ADV 2 Appendix 1 provides information about a variety of topics relating to an Advisor's business practices and conflicts of interest. In particular, this Brochure discusses wrap fee programs offering by OneSeven. Material Changes OneSeven is no longer accepting new clients into the Wrap Fee Program unless prior approval is received from the Chief Compliance Officer. Typically an exception will only be granted to clients that are currently in a wrap fee account /program at another firm and are transferring their assets to OneSeven. This is effective April 1, 2024. o Since our last annual amendment on March 31, 2026, there have been no material changes. At any time, you may view the current Disclosure Brochure on-line at the SEC's Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 283087. You may also request a copy of this Wrap Brochure at any time, by contacting us at (216) 865-1700. 2  Item 3 Table of Contents Item 2 Summary of 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 ....................................................................... 11 Item 8 Client Contact with Portfolio Managers ........................................................................................ 12 Item 9 Additional Information ................................................................................................................... 12 3  Item 4 Services, Fees, and Compensation OneSeven ("OneSeven" or the "Adviser") is a registered investment adviser with the U.S. Securities and Exchange Commission ("SEC"), which is organized as a Limited Liability Company ("LLC") under the laws of the State of Delaware and is owned 100% by MGO/OS Holdings, LLC. OneSeven was originally founded in June 2016 as We Are One Seven, LLC. On May 4, 2022, we changed our name to MGO One Seven LLC and merged with a local firm operating under the names MGO Securities Corp., a registered broker/dealer and member FINRA/SIPC and MGO Investment Advisors Inc., formerly a registered investment adviser. On April 1, 2024, we changed our primary marketing name I to OneSeven. Our executive officers are Ronald S. Gross, Chairman and Managing Member, Todd M. Resnick, Chief Executive Officer and Richard J. Gross, President, and John Keeley Carey, Chief Compliance Officer. OneSeven is no longer accepting new clients into the Wrap Fee Program unless prior approval is received from the Chief Compliance Officer. Typically an exception will only be granted to clients that are currently in a wrap fee account /program at another firm and are transferring their assets to OneSeven. This is effective April 1, 2024. A. Advisory Services OneSeven ("OneSeven" or the "Advisor") provides customized wealth advisory services for its Clients. The OneSeven Wrap Fee Program Brochure (the "Wrap Fee Program" or "Program") is an investment advisory program sponsored by OneSeven, whereby OneSeven includes commissions ("securities transaction fees") with its investment advisory fees to provide Clients with a single overall fee. Prior to becoming a client under the Program, you will be required to enter into a separate written agreement with us that sets forth the terms and conditions of the engagement and describes the scope of the services to be provided, and the fees to be paid. The OneSeven Wrap Fee Program Brochure is provided solely as a disclosure when OneSeven includes securities transaction fees as part of its overall investment advisory fee (as detailed in Item 5 of the Disclosure Brochure) and shall always be provided in connection with the Disclosure Brochure. Clients may be offered a fee structure that includes, as a single fee, the securities transaction costs for trading in Client accounts along with the investment advisory fees earned by OneSeven. The securities regulations often refer to such a structure as a "Wrap Fee Program." While traditional Wrap Fee Programs are often rigid, pre-packaged investment programs, OneSeven customizes its investment strategies individually for its Clients. The purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of securities transaction fees with investment advisory fees. This Wrap Fee Program Brochure will reference back to the OneSeven Disclosure Brochure in which this Wrap Fee Program Brochure is an Appendix. In most cases, OneSeven does not charge clients higher advisory fees for their participation in a wrap program than if they chose to participate in a non-wrap program. The difference is whether or not your selected custodian imposes transaction fees (sometimes referred to as "commissions") on the investments in accounts, whether wrap or non-wrap. The days of charging transaction fees by custodians on every investment trade continue to change and most custodians offer zero (or low) commission trades for at least US stocks, ETFs and mutual funds. To move our clients in and out of wrap accounts and require new client agreements simply because a custodian charges or doesn't charge commissions on certain trades would be confusing to clients and increase our expenses to provide the same service. The custodians could suddenly start charging commissions again just as quickly as they stopped charging them a few years ago. 4  It is important to note that OneSeven does not select investments for its clients in wrap accounts based on whether or not the custodian charges OneSeven a commission or transaction charge. We select investments that we feel are in the best interest of you, our clients, and that will help you achieve your financial goals. This creates a conflict of interest since we earn more of your advisory fee if we do not pay commissions on the investments we select but again, we take our fiduciary responsibility seriously and select only what we feel is in your best interest. If you have any questions or concerns about being in a wrap program, you should speak with your financial advisor about moving to a non-wrap account. SMArtX Third party Asset Management Program We have entered into a contractual relationship with SMArtX Advisory Solutions, LLC ("SMArtX"), which provides us access to the SMArtX Platforms through which SMArtX offers its advisory services. Through the Platforms, we can establish and manage a unified managed account ("UMA") for a Client, which is managed by OneSeven's IAR, or you may choose one or more models managed by independent third-party managers. SMArtX provides access to investment strategies or models (each a "Model") through the SMArtX Platform. Each Model is provided by either SMArtX, a traditional asset manager, a hedge fund or alternative investment manager, or an index provider (each a "Model Manager"). OneSeven participates as a Model Manager on the SMArtX platform. A Model Manager provides SMArtX with securities and weights and transactional history associated with the Model in order for SMArtX to create and maintain the Model Portfolio. Each Model Manager provides additional content ("Model Manager Content"), including but not limited to commentaries on the Model and the underlying investment strategy, also including general commentaries on the markets and the economy, historical performance, biographical information on relevant members of the Model Manager's team, and descriptions of the investment strategy or strategies utilized in the Model. We review the information available and direct SMArtX to implement one or more Models in the Client’s UMA. When we select a Model for a UMA, we will provide SMArtX with the amount of funds, either in terms of dollars or as a percent of the account's value, in the UMA to be invested in the Model. When we invest in a Model on SMArtX, SMArtX will implement the positions and trading activity of the Model in proportion to the amount of assets invested. The SMArtX platform automatically rebalances securities within individual sleeves based on drift parameters to maintain alignment with the selected model(s). However, the platform does not automatically rebalance allocations between sleeves at the overall UMA level.We are responsible for determining whether any Model or any combination of Models are appropriate and suitable for the UMA account holder. We consider the financial situation, investment goals and objectives, time horizon, liquidity, and risk tolerance ("Investment Considerations") of the UMA account holder to determine if the select Model(s) are appropriate. We are responsible for reviewing any changes to the Investment Considerations of the UMA account holder and making appropriate changes to the selected Model(s). We may choose to direct SMArtX to buy or sell individual securities in the UMA directly rather than through a Model. This functionality is called Advisor as a Portfolio Manager ("APM") and allows us to direct a portion of the UMA's assets rather than opening a separate account with a custodian. We may choose to buy or sell stocks, ETFs, or Mutual Funds. Clients may provide us instructions to restrict the purchase or sale of certain securities from the UMA. Clients can provide instructions to harvest taxable gains or losses in the UMA. We may add or decrease leverage for any selected Model, provided that SMArtX will limit the leverage utilized to the UMA's specified account configuration. Certain Models may inherently apply leverage. When a Model invests in a security or other asset that does not fit with a UMA's account configuration, SMArtX will exclude that investment from the UMA. Customizations that are specific to a UMA may cause material performance differences between the selected Model(s) and the UMA. 5  SMArtX maintains a limited power of attorney to direct trading of each UMA ("Trading Discretion") in order to purchase and sell securities in the UMA's selected custodian. Trading Discretion is either granted to SMArtX through a Sub-Advisory or Co-Advisory Agreement with OneSeven ("Advisor Sub- Advisory Agreement"). We may choose to terminate the relationship with SMArtX and revoke Trading Discretion of SMArtX at any time. Our discretionary authority allows us to invest and reinvest the assets in your Accounts, potentially including the engagement, retention and replacement of third-party portfolio managers without your prior approval. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your reasonable restrictions and guidelines in writing. We have the option of refusing your restrictions if they are deemed too restrictive to manage a client's account effectively. Flourish Cash Flourish Cash is an online cash management solution designed to provide Clients with access to competitive annual percentage yields (“APY”) and enhanced FDIC insurance coverage through deposits placed at participating program banks. Flourish Cash is offered by Flourish Financial LLC, a registered broker-dealer and member of FINRA. OneSeven is not affiliated with Flourish Financial LLC or any participating program bank. OneSeven does not provide investment advisory services or exercise discretion, with respect to Client participation in Flourish Cash. Any introduction or invitation for a Client to utilize Flourish Cash is made only with the Client’s consent. If cash is maintained within an advisory account, it is generally subject to OneSeven’s advisory fee. If a client elects to utilize the Flourish Cash program, those assets are not subject to OneSeven’s advisory fee; however, OneSeven will receive compensation of up to 0.10% annually from Flourish Financial LLC. Accordingly, OneSeven has a financial incentive to recommend either option, as the firm’s compensation differs depending on whether assets are maintained within the advisory account or placed with Flourish Cash. Clients should consider these factors when evaluating cash management recommendations. Please see Item 4 of the Disclosure Brochure for details regarding OneSeven's other non-wrap investment management services. B. Program Costs Advisory Services provided by OneSeven pursuant to a wrap fee structure may cost the Client more or less than purchasing these types of investment management services separately. When OneSeven absorbs normal securities transactions fees, OneSeven may have a financial incentive to limit the transactions in Client accounts, as each trade will increase costs to OneSeven. The costs of the Wrap Fee Program vary depending on services to be provided to each Client. Investment advisory fees are paid quarterly, in advance each calendar quarter, pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment advisory fees range from 0.00%1 to 2.00% annually or a flat fee up to $100,000 per year. Fees depend on the size and complexity of the Client relationship and the services to be provided. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions, inclusion of securities transaction fees and other complexities may be charged a higher fee. The investment advisory fee in the first quarter of service is prorated from the inception date of the 1 For Models with a 0.00% Model Fee, the Model Manager is typically receiving compensation from the individual securities held by the Model. 6  account(s) to the end of the first quarter. Fees are negotiable at the sole discretion of the Advisor. The Client's fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by OneSeven are independently valued by the designated Custodian. OneSeven does not have the authority or responsibility to value portfolio securities. OneSeven provides this Wrap Fee Program Brochure as OneSeven pays typical securities transactions costs associated with OneSeven investment strategies. Clients should read this Wrap Fee Program Brochure in connection with OneSeven's Disclosure Brochure. C. Fees The OneSeven Wrap Fee Program includes typical securities trading costs incurred in connection with the discretionary investment management services provided by OneSeven. Securities transaction fees for Client-directed trades may be charged to the Client. Clients engaging OneSeven under this Wrap Fee Program will typically pay a higher overall investment advisory fee, but will not be responsible for securities transaction fees for their accounts. Clients should discuss the expected level of trading in the Client's account(s) to determine whether to engage OneSeven under this Wrap Fee Program or pay for securities transaction fees separately. Fees are negotiable at the sole discretion of OneSeven. Clients may also incur certain fees or charges imposed by third parties, which are not included as part of the Wrap Fee. Such other fees, which may include wire transfer fees, small account fees and other fees charged by the Custodian are not included in OneSeven's Wrap Fee. OneSeven does not receive any portion of such fees. In addition, all fees paid to OneSeven for investment advisory services are separate and distinct from the expenses charged by mutual funds and exchange-traded funds to their shareholders, if applicable. These fees and expenses are described in each fund's prospectus. These fees and expenses are generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee as a shareholder in a fund. Please see Item 5.C. of the Disclosure Brochure. SMArtX Fees In addition to the advisory fee paid to OneSeven, Clients utilizing SMArtX pay a fee to SMArtX ("Client Fee"). SMArtX will pay, in cases where clients utilize Model Managers, a portion of the Client Fee to the selected Model Manager(s), including OneSeven as applicable. Each Client should also review SMArtX's Disclosure Brochure for a more detailed description of SMArtX's Fee. When using the SMArtX platform, clients pay a SMArtX platform fee based on the program selected. Depending on the program selected, OneSeven will receive a share of the platform fee you pay, which could be as high as 0.15%. Typically OneSeven shares in the platform fees charged for accounts using OneSeven models and the platform fees charged for accounts managed by an IAR of OneSeven. Platform fees are as follows: • Accounts outsourced to other money managers will pay a platform fee not to exceed 0.15%. These accounts will also pay a Model Fee as outlined below. • Accounts managed by the IAR and using OneSeven models for management of the account will pay a platform fee of 0.25%. This includes the Model Fee (payable to OneSeven) and the platform fee. • Accounts managed by the IAR that do not use the OneSeven models will pay a platform fee not to exceed 0.10%. These fees are negotiable at the discretion of OneSeven. The Platform Fee is calculated on the net account value of the assets held in the UMA. The Platform Fee will be set forth in either the Client Investment Management Agreement or the Adviser Sub- 7  Advisory Agreement. Model Managers other than OneSeven may have a different model fee. The Model Fee is calculated on the net value of the assets held in the UMA attributable to a particular Model ("Net Model Sleeve Value"). The Model Fee will vary from Model to Model based on the Model Manager and the type of the Model. Model Fees are negotiable by Advisors and Model Managers in conjunction with SMArtX. Clients should review the SMArtX disclosure brochure for additional details about the SMArtX fees and how they are calculated. Flourish Cash Assets held in the Flourish Cash program are not included in OneSeven’s portfolio management services and are therefore not charged an advisory fee by OneSeven. However, clients who elect to participate in the Flourish Cash program will pay an administrative and/or service fee of up to 0.10% annually for assets in the program. This fee is paid to OneSeven and is deducted directly from the annual percentage yield (“APY”) otherwise credited to the Client’s account. The fee is not negotiable. Additional Fees Not Included in Your Wrap Fee OneSeven has established procedures to ensure client assets are held at a qualified custodian in the name of the client and OneSeven does not have possession of client assets. To participate in the Wrap Program, the client assets must be maintained in an account under the Client's name with a Custodian designated for the particular Wrap Program. The Custodial account will be governed by a separate agreement (each a "Custodial Agreement") between the Client and each Custodian, and Client will be solely responsible for negotiating the terms of such agreement. The Custodial account will bear all fees and expenses of its Custodian and of transactions for such account, according to Client's agreement with the Custodian, all of which will be separate from and in addition to the Advisory Fees, Adviser Platform Fees, and Sponsor Program Fees payable pursuant to the Advisory Agreement or Wrap Program Agreement. Clients must pay the cost of services provided by the Custodian for: (1) arranging for the receipt and delivery of securities that are purchased, sold, borrowed or loaned for the Custodial account; (2) making and receiving payments with respect to Custodial account transactions and securities; (3) maintaining custody of Custodial account securities; and (4) maintaining custody of cash, receiving dividends, and processing exchanges, distributions, and rights accruing to the Custodial account. The specific fees and terms of each Custodian's services are described in the Client's separate Custodial Agreement(s). Please refer to Item 9, under the Compensation from Custodians' subsection for additional information. Additional fees not typically included in your wrap fee can include: • Brokerage commissions • Stock loan fees • Interest charges • Exchange fees • SEC fees • Early redemption fees and penalties • Deferred sales charges • Transfer fees, including wire fees and electronic fund processing fees • Taxes • Markups or markdowns on securities transactions • Processing fees and other fees charged by custodians • Step out or trade-away fees (see Item 9 for additional details) • Other additional fees charged by the custodian 8  D. Compensation OneSeven is the sponsor and a possible portfolio manager of this Wrap Fee Program. As such, OneSeven receives investment advisory and portfolio management fees paid by Clients for investment advisory services covered under this Wrap Fee Program. A portion of OneSeven's fees will be shared with your Investment Adviser Representative (“IAR”). If other Model Managers are selected by clients, OneSeven serves as the sponsor of the wrap program and the Client Fee is shared with OneSeven and the Model Manager. A portion of the Client Fee received by OneSeven is also shared with your IAR. SMArtX Fee Calculations SMArtX typically calculates fees on a monthly basis in arrears and sends an invoice to the custodian of the client's account. Each custodian will debit the accounts directly and remit payment to SMArtX automatically. SMArtX uses an average daily balance calculation in order to calculate the Platform Fee, Model Fee 2. SMArtX will sum the daily Net Account Values or the Net Model Sleeve Values over the specified period of time ("Measurement Period"). The sum is subsequently divided by the number of days in the Measurement Period to get the average daily balance ("Average Daily Balance"). The Average Daily Balance is multiplied by the appropriate fee which is adjusted for the number of trading days in the Measurement Period and the number of trading days in the calendar year. SMArtX uses the New York Stock Exchange's schedule to determine trading days. Fee Processing SMArtX typically calculates fees on a monthly basis in arrears. SMArtX sends an invoice to the UMA's custodian. Each custodian will typically debit the UMA directly and remit payment to SMArtX automatically. If the relationship with SMArtX is terminated by the Client or the Advisor and the Client Fees were paid in advance, SMArtX will use its standard method of calculating Client Fees to calculate the overpaid portion of the Client Fee. SMArtX will calculate and process the refund to the Client based on the direction of the Client's Advisor. Other Compensation Available to IARs IARs of OneSeven have the opportunity to receive additional individual compensation and benefits either upon joining OneSeven or when the opportunity is offered to current IARs who have already joined OneSeven. These benefits include a combination of firm equity ownership with the potential for significant appreciation, substantial capital advances or cash payments. The value of benefits is negotiated between OneSeven and the IAR and is related to the amount of revenue expected to be received by the IAR and OneSeven based on the IAR's current and future business projections. Future liquidity events for OneSeven also allow another opportunity for increased participation by the IARs. Assets Under Management As of December 31, 2025, we provide continuous management services for $7,717,771,462 in client assets. $7,676,862,163 in assets are managed on a discretionary basis while $40,909,299 in assets are managed on a non-discretionary basis. Of these assets, $ 28,364,678 are included in our Wrap Program. OneSeven serves as the sponsor and portfolio manager for the Wrap Program. Item 5 Account Requirements and Types of Clients OneSeven offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, retirement plans and other types of investors. 2 For Models with a 0.00% Model Fee, the Model Manager is typically receiving compensation from the individual securities held by the Model. 9  In general, we do not require a minimum dollar amount to open and maintain an advisory account; however, we have the right to terminate your account if it falls below a minimum size, and we determine in our sole opinion, it is too small to manage effectively. We may also combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum. Item 6 Portfolio Manager Selection and Evaluation A. Portfolio Manager Selection OneSeven serves as the sponsor and possibly the portfolio manager for the OneSeven Wrap Fee Program. IARs of OneSeven sometimes serve as the portfolio manager for the client's wrap program and in other cases, independent third-party managers are selected through the SMArtX platform. OneSeven reviews our portfolio manager performance but it is not reviewed by an independent third- party review. B. Investment Adviser Representatives as Portfolio Manager OneSeven personnel or Investment Adviser Representatives (IARs) have the option of serving as portfolio manager for services offered to their clients under this Wrap Fee Program. OneSeven does not act as portfolio manager for any other third-party wrap fee programs. Not every IAR has the same experience when managing investment portfolios, and you should carefully consider this when choosing the Wrap Program. Your IAR's Form ADV Part 2B Supplemental Brochure provides additional background on your IAR's experience. OneSeven and your IAR rely on the information you provide to us, and it is important that you keep your information current. You have an ongoing obligation to notify your IAR if there are any changes to your financial situation or the information provided, including information relevant to your investment objectives or risk tolerance. All information disclosed in this Wrap Brochure is applicable to your IAR when serving as portfolio manager. C. Supervised Persons as Portfolio Manager OneSeven Supervised Persons (i.e., certain employees of OneSeven) may serve as portfolio managers for the OneSeven Wrap Fee Program described in this Wrap Fee Program Brochure. Please refer to the Items 4 and 8 of the Disclosure Brochure for details on the services provided by OneSeven. For additional information related to the background of OneSeven supervised persons and investment adviser representatives, please see Items 9 and 11 of the Disclosure Brochure. Items 8 and 17 of the Disclosure Brochure provide information on Methods of Analysis, Investment Strategies and Risk of Loss as well as Voting Client Securities. Performance-Based Fees OneSeven does not charge performance-based fees for its investment advisory services. The fees charged by OneSeven are as described in Item 5 - Fees and Compensation above and are not based upon the capital appreciation of the funds or securities held by any Client. OneSeven does not manage proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend particular investment options to its Clients. Methods of Analysis OneSeven primarily employs the fundamental research method in developing investment strategies for its Clients. Research and analysis from OneSeven is derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. 10  As noted above, OneSeven generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. OneSeven will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. OneSeven may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. Please see Item 8 of the Disclosure Brochure for additional details on our research methods. Risk of Loss Investing in securities involves certain investment risks. Securities do fluctuate in value and can lose value. Clients should be prepared to bear the potential risk of loss. OneSeven will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Please see Item 8.B of the Disclosure Brochure. Voting Client Securities OneSeven does not accept proxy voting responsibility for any Client. Clients have the option of receiving proxy statements directly from the Custodian so the Client may vote or clients may have proxy materials sent to OneSeven. Proxy materials received by OneSeven will be destroyed and not forwarded to the Client. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Class Actions, Fair Funds And Similar Actions OneSeven has engaged a third party service provider, 11thEstate, Inc., to monitor and, at its option, to file, claim paperwork for class action settlements, fair funds, shareholder compensation, and other similar proceeds, on behalf of firm clients who have not opted out of this service. The firm provides 11thEstate with aggregated information about securities held by firm clients. When 11thEstate identifies a settled or otherwise resolved action relating to a security held by one or more firm clients, as to which 11thEstate determines to file claims paperwork, 11thEstate will request, and OneSeven will provide, the names, account numbers and holdings data of the clients who hold the security that is subject to the action (except for any clients who have opted out of this service). 11thEstate will then prepare and file the claims with the administrator of the class action settlement, Fair Fund, etc., and will follow up as needed to ensure that the claims are processed. 11thEstate's fee for this service is deducted from the proceeds recovered. If permitted by law, this fee will be deducted directly from the client's gross settlement/ judgment proceeds and the net settlement/ judgment proceeds for each client are deposited into the client's brokerage account or other designated account. For Fair Funds and in other circumstances in which the payout must be distributed in its entirety to the client, there is no fee to the client. OneSeven does not receive any compensation or payment from 11thEstate or from the client in connection with this service. One Seven is not involved in monitoring or processing these claims and is not responsible for 11thEstate's performance of its services except as required by law. Clients may "opt out" of this service by providing written notice to the Advisor. Client opting out assume responsibility for filing or otherwise pursuing the Client's share of any securities settlements or judgments. Item 7 Client Information Provided to Portfolio Managers OneSeven is required to describe the type and frequency of the information it communicates to external managers that may be involved in managing its Clients' investment portfolios. OneSeven provides only the information required by the external manager (i.e., Model Manager) to manage clients' accounts and updates to that information, if applicable. 11  Item 8 Client Contact with Portfolio Managers There is no restriction on the Client's ability to contact OneSeven. Without restriction, you should contact our firm or your investment advisory representative directly with any questions regarding your Program account. You should contact your investment advisory representative with respect to changes in your investment objectives, risk tolerance, or requested restrictions placed on the management of your Program assets. Item 9 Additional Information A. Disciplinary Information and Other Financial Industry Activities and Affiliations Disciplinary Information There are no legal, regulatory or disciplinary events involving OneSeven. OneSeven and its Supervised Persons value the trust you place in us. As we advise all Clients, we encourage you to perform the requisite due diligence on any advisor or service provider with whom you engage. Our backgrounds are on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. You may search with our firm name or our CRD# 283087. Other Financial Activities and Affiliations Other Investment Adviser Affiliations - Certain investment adviser representatives ("IARs") of OneSeven also conduct business under the names of: • Alta Vera Global Capital Advisors • Beacon Way Wealth Management • Callahan Financial • Carey Dittoe Wealth Management • Chen Wealth Services • ClientFirst Financial Strategies • Community Financial Advisors • Created Wealth Advisory • DWT Wealth • Everglades Parkland Advisors • Feldmeyer Financial Group • Fulshear Wealth • Giltner & Associates • Hemlock Wealth Management • Hope Financial Group • HTR Wealth Management • Hyperion Wealth Group • Ironclad Wealth Management • JP Investments Group LLC • JTM Williams Capital Management • Lake House Private Wealth Management • Life Transitions Planning • Magnetic North Financial • Managed Wealth Solutions • Martz Financial, LLC • MB Wealth Management Group 12  • MGO, Inc. • OneSeven / We Are One Seven • OnPoint Wealth Partners • Paceline Advisors • Palm Coast Wealth Management • Park City Wealth Advisors • R J Campbell Investments, LLC • Resolute Wealth Management • RISE Capital • Romero Wealth Management • Rosehaven Family Office • S3 Retirement Planning • Shintani Wealth Management Services • Stone Creek Advisors • Stratos Investments of OneSeven • Structure Wealth Management • The Hamilton Group • Valentine Wealth Advisors • Wealth Planning and Design • WealthCreate Financial • Wolfe Wealth Management Broker-Dealer Affiliations - Certain IARs of OneSeven are also registered representatives of Fortune Financial Services, Inc. ("FFS"), MGO Securities Corp. ("MGO"), Purse Kaplan Sterling ("PKS") or International Assets Advisory, LLC ("IAA"). In their capacity as registered representatives, these persons receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by these persons in their capacities as registered representatives is separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are registered representatives have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on your needs. You are under no obligation, contractually or otherwise, to purchase securities products through persons affiliated with our firm. Under supervision by FFS, MGO Securities, PKS or IAA, these parties have access to certain confidential information of the Client, including, but not limited to financial information, investment objectives, transactions and holdings information. Please see our Privacy Policy, which has been or will be provided to you. MGO Securities is also under common control with OneSeven. Certain owners of OneSeven are also owners of MGO Securities. Insurance Recommendations - Commissions will be received from the sale of insurance products. All commissions are paid to MGO Inc. for former IARs of MGOIA. Insurance products utilized are based on the client objectives determined during initial and subsequent client meetings. MGO Inc. will receive insurance commissions from legacy holdings when a client retains OneSeven. IARs of the former entity We Are One Seven, LLC are typically paid their insurance commissions directly; the commissions do not flow through OneSeven or one of our affiliates.. Clients are under no obligation to implement any recommendations made by OneSeven or any of its Advisory Persons. Private Investment Funds - Some of OneSeven's IARs also serve in investment-related positions with 13  various private investment funds (the "Funds"): Mr. Kenneth Arnoldserves as a portfolio manager and principal officer of the Everglades Global Opportunities Fund LP, Everglades Digital Assets Fund LP and OA Digital Fund LP . Akseli Derzon serves as portfolio manager and general partner of the Lodging Fund One LLC. IARs of OneSeven may recommend that Clients and prospective clients of OneSeven invest in the Funds. Clients and prospective clients that are offered to invest in the Funds shall be provided with the Funds' private placement memorandum and related documents that provide a full description of the investment approach, business practices, fees and risks associated with an investment in the Funds. Clients are not obligated to invest in the Funds. To mitigate the conflict of interest associated with this outside activity, no additional ongoing investment advisory fees are charged on assets that are invested in the Funds. B. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading, Review of Accounts, Client Referrals and Other Compensation and Financial Information Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics OneSeven has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of Ethics applies to all Supervised Persons associated with OneSeven (our "Supervised Persons"). The Code of Ethics was developed to provide general ethical guidelines and specific instructions regarding our duties to you, our Client. OneSeven and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of OneSeven Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code of Ethics covers a range of topics that address employee ethics and conflicts of interest. To request a copy of our complete Code of Ethics, please contact us at (216) 865- 1700. A copy will be provided to you at no charge. Personal Trading and Conflicts of Interest OneSeven allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities, we recommend (purchase or sell) to you presents a conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, we have adopted a Code of Ethics, which addresses insider trading (material non-public information controls) and personal securities reporting procedures. We have also adopted written policies and procedures to detect the misuse of material, non-public information. We may have an interest or position in certain securities, which may also be recommended to you. At no time, will OneSeven or any Supervised Person of OneSeven, transact in any security to the detriment of any Client. Please see Private Investment Funds above for additional details. Review of Accounts Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of OneSeven. Formal reviews are the responsibility of the Investment Adviser Representative assigned to the Client and are conducted at least annually or more or less frequently depending on the needs of the Client. The Client is encouraged to notify OneSeven if changes occur in his/her personal financial situation that might adversely affect his/her investment plan. Additional reviews may be triggered by material market, economic or political events. Client Referrals and Other Compensation As noted throughout this Disclosure Brochure, Advisory Persons may also be registered representatives and/or licensed insurance professionals. For information on the conflicts of interest this presents and how we address these conflicts, please refer to other disclosures throughout this Wrap Brochure. 14  Other Compensation Available to IARs IARs of OneSeven have the opportunity to receive additional individual compensation and benefits either upon joining OneSeven or when the opportunity is offered to current IARs who have already joined OneSeven. These benefits include a combination of firm equity ownership with the potential for significant appreciation, substantial capital advances or cash payments. The value of benefits is negotiated between OneSeven and the IAR and is related to the amount of revenue expected to be received by the IAR and OneSeven based on the IAR's current and future business projections. Future liquidity events for OneSeven also allow another opportunity for increased participation by the IARs. Economic and Non-Economic Benefits from Custodians OneSeven will recommend one of three entities to serve as the qualified custodian for clients' advisory accounts. These are Goldman Sachs, Axos, Fidelity, Raymond James & Associates, Inc. ("Raymond James"), member New York Stock Exchange/SIPC and Charles Schwab & Co., Inc. ("Schwab"), member FINRA/SIPC. Raymond James & Associates, Inc., RIA & Custody Services Division MGO One Seven has established an institutional relationship with Raymond James & Associates, Inc. ("Raymond James") to assist the MGO One Seven in managing Client accounts. Access to the Raymond James RIA & Custody Services Division is provided at no charge to the Adviser. The Adviser receives access to software and related support with minimal cost because the Adviser renders investment management services to Clients that maintain assets at Raymond James. The software and related systems support may benefit the Adviser, but not its Clients directly. In fulfilling its duties to its Clients, the Adviser endeavors at all times to put the interests of its Clients first. Additionally, the Adviser may receive the following benefits from the Raymond James platform: receipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts; access to research; and access to an electronic communication network for Client order entry and account information. Schwab Advisor Services Schwab Advisor Services serves independent investment advisory firms like us. They provide us and our clients with access to its institutional brokerage platform - 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. Effective October 7, 2019, Schwab eliminated commissions for online trades of U.S. equities, ETFs and options (subject to $0.65 per contract fee). We encourage you to review Schwab's pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap arrangement. You will still incur commissions and fees for certain types of transactions in a non-wrap fee arrangement. 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. Services that Benefit You. Schwab's institutional brokerage services include access to a broad range of investment products, execution of securities 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. 15  Services that May Not Directly Benefit You. Schwab also makes available to us other products and services 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. They include investment research, both Schwab's own and that of third parties. We may use this research to service all or some substantial number of our clients' accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; • • provide pricing and other market data; facilitate payment of our fees from our clients' accounts; and • assist 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; technology, compliance, legal, and business consulting; publications and conferences on practice management and business succession; access to employee benefits providers, human capital consultants and insurance providers; and a discount of up to $4,250 on PortfolioCenter Reporting Software. 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. Fidelity Brokerage Services LLC OneSeven has an arrangement with National Financial Services LLC, and Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity") through which Fidelity provides OneSeven with Fidelity's "platform" services. The platform services include, among others, brokerage, custodial, administrative support, record keeping and related services that are intended to support intermediaries like OneSeven in conducting business and in serving the best interests of their clients but that may benefit OneSeven. Fidelity charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transactions fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). Fidelity enables OneSeven to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Fidelity's commission rates are generally considered discounted from customary retail commission rates. However, the commissions and transaction fees charged by Fidelity may be higher or lower than those charged by other custodians and broker-dealers. As part of the arrangement, Fidelity also makes available to OneSeven, at no additional charge to OneSeven, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies, as selected by OneSeven (within specified parameters). These research and brokerage services and are used by OneSeven to manage accounts for which OneSeven has investment discretion. Without this arrangement, OneSeven might be compelled to purchase the same or similar services at its own expense. As a result of receiving such services for no additional cost, OneSeven may have an incentive to continue to use or expand the use of Fidelity's services. OneSeven examined this 16  potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined that the relationship is in the best interests of OneSeven's clients and satisfies its client obligations, including its duty to seek best execution. A client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where the OneSeven determines in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broke-dealer's services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although OneSeven will seek competitive rates, to the benefit of all clients, it may not necessarily obtain the lowest possible commission rates for specific client account transactions. Although the investment research products and services that may be obtained by OneSeven will generally be used to service all of OneSeven's clients, a brokerage commission paid by a specific client may be used to pay for research that is not used in managing that specific client's account. OneSeven and Fidelity are not affiliates, and no broker-dealer affiliated with OneSeven is involved in the relationship between OneSeven and Fidelity. Step Out or Trade-Away Trades In most cases, SMArtX will route trades directly to the client's custodian for UMA trades. Occasionally, in order to obtain best execution, SMArtX will route orders to a different broker-dealer than the UMA's custodian for execution. These are called "step out trades" or referred to as "traded-away". In these situations, the selected broker-dealer will often specialize in executing certain types of orders, such as executing large orders for thinly traded securities. Step out trades may include additional commission costs or fees, including markups and markdowns, that could be avoided if the trades were done by the client's custodian. These additional charges are paid by the client and are not included in the wrap fee. Financial Information Neither OneSeven, nor its management, have adverse financial situations that would reasonably impair the ability of OneSeven to meet all obligations to its Clients. OneSeven is not required to deliver a balance sheet along with this Disclosure Brochure, as OneSeven does not collect fees of $1,200 or more for services to be performed six months or more in advance. IRA Rollover Recommendations For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we 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 we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and 17  • Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. 18