D.A. DAVIDSON FIRM BROCHURE

Part 2A of Form ADV Firm Brochure D.A. Davidson & Co. 8 Third Street North Great Falls, MT 59401 800-332-5915 dadavidson.com July 30, 2026 This Firm brochure provides information about the qualifications and business practices of D.A. Davidson & Co. If clients have any questions about the contents of this brochure, please contact us at 406-727-4200 or 800-332-5915. 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. Registration as an investment adviser with the SEC does not imply a certain level of skill or training. Additional information about D.A. Davidson & Co. is available on the SEC’s website at adviserinfo.sec.gov.  Item 2 Material Changes A summary of the material changes made to the D.A. Davidson & Co. (“D.A. Davidson”) ADV Part 2A Firm Brochure (the “Brochure”) will be published in a separate document that will be distributed to clients who received the previous version of the Brochure and continue to receive the advisory services described in this brochure. 1  Item 3 Table of Contents Item 2 Material Changes ................................................................................................................................... 1 Item 3 Table of Contents ................................................................................................................................... 2 Item 4 Advisory Business ................................................................................................................................. 3 SCOPE OF SERVICES AND APPLICABLE STANDARDS OF CARE ............................................................... 3 DESCRIPTION OF SERVICES ........................................................................................................................... 5 Retirement Plan Services ................................................................................................................................ 5 Financial Planning Services ............................................................................................................................ 6 Davidson Private Wealth Services .................................................................................................................. 7 Assets Under Management ................................................................................................................................. 8 Item 5 Fees and Compensation........................................................................................................................ 8 Retirement Plan Services ................................................................................................................................ 8 Financial Planning Services ............................................................................................................................ 8 Item 6 Performance-Based Fees and Side-By-Side Management ................................................................ 9 Item 7 Types of Clients ..................................................................................................................................... 9 Retirement Plan Services ................................................................................................................................ 9 Financial Planning Services ............................................................................................................................ 9 Davidson Private Wealth Services .................................................................................................................. 9 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 9 RETIREMENT PLAN SERVICES ...................................................................................................................... 10 Methods of Analysis....................................................................................................................................... 10 Material Risks ................................................................................................................................................ 10 FINANCIAL PLANNING SERVICES AND DAVIDSON PRIVATE WEALTH SERVICES ................................. 12 Methods of Analysis....................................................................................................................................... 12 Material Risks ................................................................................................................................................ 12 Item 9 Disciplinary Information ...................................................................................................................... 12 Item 10 Other Financial Industry Activities and Affiliations ........................................................................ 13 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............. 14 Code of Ethics and Personal Trading ............................................................................................................ 14 Item 12 Brokerage Practices ........................................................................................................................... 15 Retirement Plan Services .................................................................................................................................. 15 Financial Planning Services and Davidson Private Wealth ............................................................................... 15 Item 13 Review of Accounts ............................................................................................................................ 15 Item 14 Client Referrals and Other Compensation ....................................................................................... 16 Item 15 Custody ................................................................................................................................................ 18 Item 16 Investment Discretion ......................................................................................................................... 18 Item 17 Voting Client Securities ...................................................................................................................... 19 Item 18 Financial Information .......................................................................................................................... 19 2  Item 4 Advisory Business D.A. Davidson & Co. ("D.A. Davidson", the “Firm,” or “we”), established in 1935, is a dually registered investment adviser and broker-dealer with its principal place of business located in Great Falls, Montana. The firm is a wholly owned subsidiary of D.A. Davidson Companies, a financial services holding company. D.A. Davidson offers the following investment advisory services: • Wrap Fee Programs where we act as a portfolio manager and/or sponsors of several wrap fee programs and services. Details are available in D.A. Davidson’s Form ADV 2A Wrap Fee Program Brochure. • Equity Research Services where we offer equities-based research reports and other research-related communications to institutional clients. Details are available in D.A. Davidson’s Form ADV 2A Equity Research Services Brochure. The Wrap Fee Program Brochure or Equity Research Services Brochure are available upon request from your Financial Advisor or online at dadavidson.com/Disclosures. • Retirement Plan Services where we provide advice services to plan sponsors and participants, which are described further in this ADV 2A Firm Brochure (this “Brochure”). • Financial Planning Services where we provide financial plans both for a fee and for no additional cost, which are described further in this Brochure. • Davidson Private Wealth Services, where we provide financial plans and other related services for no additional cost to clients with more than $20 million in stated net worth, which are described further in this Brochure. The information contained in this Brochure concerns the fees, conflicts of interest and other information clients should consider about Financial Planning Services, Retirement Plan Services, and Davidson Private Wealth Services. It is current as of the cover date and is subject to change at D.A. Davidson’s discretion. Clients should retain this Brochure for their records. Clients are encouraged to carefully consider the differences between brokerage and investment advisory services including D.A. Davidson’s obligations, costs, and the clients need for the services provided. For additional information, please review the Firm’s Client Relationship Summary (“Form CRS”), which provides information about the differences between brokerage accounts and advisory accounts. Generally, the Firm and its Financial Advisors have an incentive to recommend investment advisory accounts over brokerage accounts because the Firm and its Financial Advisor receive higher fees for advisory accounts than brokerage accounts. Financial Advisors consider a number of factors when recommending an account type, or change in account type, including, but not limited to, the client’s Investment Profile (as defined below); whether client is tax-sensitive and needs professional tax-management solutions; client’s investment experience and/or engagement level (i.e., desire and availability to be involved and informed on investment decisions); and client’s anticipated frequency of trading. This is intended to help ensure that the Firm’s account type recommendations are reasonably expected to be cost-effective choices in light of client investment needs. Additionally, the Firm does not impose requirements on how many accounts a financial professional must have that are brokerage accounts or advisory accounts, nor incentivize the decision through its compensation. SCOPE OF SERVICES AND APPLICABLE STANDARDS OF CARE Advisers Act Fiduciary Duty. As a registered investment adviser, D.A. Davidson is subject to a fiduciary duty under the Investment Advisers Act of 1940 (the “Advisers Act”), which includes both a duty of care and a duty of loyalty (referred to in this Brochure as the “Advisers Act Fiduciary Duty”). This means D.A. Davidson and D.A. Davidson’s registered investment advisor representatives (each, a “Financial Advisor,” and collectively, “Financial Advisors”) are required to act in the client’s best interest when providing advisory services, including those described in this Brochure. The duty of care requires, among other things, D.A. Davidson, and its Financial Advisors to seek best execution and to provide advice that is in the client’s best interest based on the client’s investment objectives, risk level, investment time horizon, financial information, and other circumstances (collectively, client’s “Investment Profile”) or mandate. The duty of loyalty requires D.A. Davidson to provide full and fair disclosure of, and obtain client’s consent to, conflicts of interest. The duties also require D.A. Davidson to monitor accounts when providing certain advisory services based on the terms of the agreement for that service between D.A. Davidson and a client. Special Rules for Retirement Accounts. For retirement and other qualified accounts, including employer- sponsored plans (“plans”), individual retirement accounts (“IRAs”), SEP IRAs, SIMPLE IRAs, Keogh plans, 3  Coverdell educational savings accounts, and other similar accounts (collectively, “retirement accounts”) D.A. Davidson is a “fiduciary” under Title I of the Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (the “Code”), when providing investment advice or managing a client’s account. ERISA and the Code limit the types of products and services D.A. Davidson can offer and provide with respect to retirement accounts. When making recommendations that clients open, roll over or transfer retirement account assets to an advisory account or change account types, the Firm relies on Prohibited Transaction Exemption (“PTE”) 2020-02, which allows D.A. Davidson, its Financial Advisors, and affiliates to earn variable compensation for such recommendations subject to certain conditions. PTE 2020-02 requires D.A. Davidson to act in client’s best interest and not put their interest ahead of clients’ interests when providing these recommendations (“fiduciary acknowledgement”). Under PTE 2020-02, D.A. Davidson and its Financial Advisors must also: • Meet a professional standard of care (give prudent advice); • Not put the Firm’s financial interests ahead of client’s (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that the Firm and its Financial Advisors give advice that is in client’s best interest; • Charge no more than is reasonable for the Firm’s services; and • Give the client basic information about conflicts of interest. This fiduciary acknowledgment does not create or modify a contractual obligation, or fiduciary status or obligations under state law. This fiduciary acknowledgement does not apply to federal, state, local, non-US or other types of workplace employee benefit plans that are subject to laws other than ERISA or Section 4975 of the Code. The above acknowledgement applies solely with respect to the following recommendations (“Covered Recommendations”), as may be applicable: • Roll Out Recommendations. From time to time, the Firm in coordination with client’s Financial Advisor and a centralized review team will provide a written recommendation that client roll out assets from a plan to an IRA. • Account Type Recommendations at the Firm. From time to time, the Firm and the client’s Financial Advisor will recommend that a client open a brokerage or advisory retirement account transfer money between brokerage and advisory retirement accounts, or transfer money from one wrap fee program or portfolio to another within an advisory retirement account. Under the Firm’s wrap fee programs, the Financial Advisor may recommend a client engage the services of an investment manager for their advisory retirement account, which may include one of D.A. Davidson’s affiliates. The above acknowledgement does not apply to other suggestions, recommendations, and services the Firm and its Financial Advisors provide and that are governed exclusively by the terms of clients’ other agreements with, and disclosures from, the Firm, as may be applicable. D.A. Davidson refers to these as “Excluded Recommendations and Transactions.” Excluded Recommendations and Transactions refer to communications that are not reasonably intended to be viewed or construed as an individualized/personalized suggestion for a client to take a particular course of action with respect to their retirement accounts (“General Information and Education”) or that are otherwise not to be treated as Covered Recommendations under this disclosure, including, but not limited to: • General Information and Education about the financial markets, asset allocations, financial planning illustrations and the advantages and risks of particular investments; • General Information and Education materials about issues and alternatives that should be considered when deciding whether to roll out or transfer retirement account assets to the Firm; • General Information and Education about rollovers from a 529 account to a Roth IRA; • Transfers of retirement account assets held at a financial service company other than the Firm (including directly with an investment product sponsor); • Recommendations about investments in accounts that are not retirement accounts (i.e., taxable accounts) that clients maintain with D.A. Davidson or accounts held at other financial institutions; • Transactions clients enter into without a recommendation from D.A. Davidson or its financial professionals, or that are contrary to, or inconsistent with, their recommendation; 4  • Ongoing recommendations of securities or other transactions or discretionary investment advice through a wrap fee program (other than Account Type Recommendations), except as otherwise agreed to in writing in such wrap fee program’s applicable agreements or disclosures; • Recommendations or investment advice that the Firm provides to clients with respect to an account that they have at the Firm, which clients choose to implement in another account or at another financial services company; and • Recommendations that are not fiduciary “investment advice” as defined in Department of Labor regulation section 2510.3-21 (i.e., investment advice for a fee or other compensation rendered on a regular basis pursuant to a mutual understanding that such advice will serve as a primary basis for client’s investment decision, and that will be individualized to the particular needs of client’s retirement account). The Best Interest Standard and Reasonable Compensation. The best interest standard under both the Advisers Act Fiduciary Duty and PTE 2020-02 does not require that D.A. Davidson guarantee the performance of any investment or that client’s investment objectives will be achieved. In addition, D.A. Davidson and its Financial Advisors may provide recommendations and take actions in connection with the accounts of other clients that may differ from the recommendations and services provided to client. There may be times when D.A. Davidson is legally prohibited from making a recommendation that may be otherwise considered to be in client’s best interest, such as due to insider trading restrictions. Client understands any recommendations D.A. Davidson, or its Financial Advisors make will reflect the information client provides to the Firm about their Investment Profile and D.A. Davidson will not be responsible for any information client omits or fails to provide, including changes thereto. D.A. Davidson and its financial professional’s recommendations and advice will also reflect any reasonable limitations client imposes, including through applicable investment restrictions and guidelines. Clients are responsible for notifying D.A. Davidson and their Financial Advisors if their investment objectives, risk tolerance, or financial circumstances change. D.A. Davidson and its Financial Advisors will not be responsible for clients’ decision to invest or transfer their retirement account assets in a manner that is different from, or inconsistent with, D.A. Davidson’s recommendations or other advice and guidance, and clients assume the risk of such decision, nor will D.A. Davidson or its Financial Advisors be responsible for clients’ delay in implementing a recommendation. Reasonable compensation under the retirement laws has generally been determined based on the compensation paid or received in an arm’s-length transaction considering the nature and extent of all services (including products, features, and benefits) provided. This standard does not require D.A. Davidson to offer its services at the lowest cost, or for the least compensation, in the marketplace, nor that it offer its services to clients at the same or lower cost or compensation levels than it offers them to other clients, including similarly situated clients. Certain clients may have negotiated lower fees and compensation for their advisory services than others. By entering into an agreement with D.A. Davidson, clients agree that they believe the fees and other compensation payable for the Firm’s services are reasonable in light of the totality of the services provided. If clients decide not to use all or some of the services made available, clients agree the Firm has no obligation or responsibility to reduce or lower its fees and compensation during the period those services are available. If clients want to change the services the Firm makes available to them or has any concerns regarding the level of fees their retirement account pays or D.A. Davidson’s compensation, client should contact their Financial Advisor immediately. DESCRIPTION OF SERVICES Retirement Plan Services ERISA 3(21) and 3(38) Services to Plans. D.A. Davidson’s Financial Advisors provide services to employer sponsored retirement plans that can be held at a separate recordkeeper or Plan platform provider or, in limited circumstances, with D.A. Davidson. Retirement Plan Services are subject to the Employee Retirement Income Security Act (“ERISA”), (“ERISA covered plans” or “Plans”) and can include all or a subset of the following depending on the agreement between D.A. Davidson and the Plan sponsor or trustee (the “Plan Fiduciary”) or Adopting Employer: • Assist with preparing and monitoring investment policy statements (“IPS”) for compliance with ERISA requirements; • Assist with establishing procedures and preparing documentation for Plan operations; • Recommend plan investments, including a Qualified Default Investment Alternative (“QDIA”), in accordance with the Plan’s IPS, or investment mandate; • Conduct plan meetings to review the Plan; • Review quarterly/annual fund management and performance versus benchmarks; • Provide non-discretionary recommendations to participants about their Plan investments; • Provide education and/or non-discretionary advice to Plan participants; • Conduct Plan expense and comparative analysis to industry averages; and 5  • Assist with vendor search including requests for proposal (“RFP”). Services are typically provided pursuant to ERISA Rule 3(21) or from time to time pursuant to ERISA Rule 3(38) and are typically memorialized in a written agreement with the Plan Fiduciary. Investment recommendations made to the Plan Fiduciary are based on the investment options available with the recordkeeper or Plan platform provider and can include varying investments, such as stocks, bonds, open end mutual funds, exchange traded funds, and collective investment trusts. The Plan Fiduciary may also impose reasonable restrictions on certain types of investments or limit the number of investments available to Plan participants. As an ERISA 3(21) Investment Advisor, D.A. Davidson is a co-fiduciary to the Plan and provides non-discretionary investment recommendations to the Plan Fiduciary. The Plan Fiduciary, however, retains final decision-making authority for the investments and may accept or reject D.A. Davidson’s investment recommendations. As an ERISA 3(38) investment adviser, D.A. Davidson can provide all or a subset of these services (in addition to the services listed above): • Discretionary selection, removal, or replacement of investment alternatives in accordance with the Plan’s IPS; • Selection of a Plan’s QDIA; • On a limited basis, discretionary management of risk-based model portfolios. When providing 3(38) services, D.A. Davidson has discretionary authority and is responsible for the selection, monitoring, and replacement of investment options. In this case, D.A. Davidson is authorized to implement and effect investment advice without the Plan Fiduciary’s prior authorization. When an ERISA 3(38) investment adviser is appointed, the Plan Fiduciary is relieved of its fiduciary responsibility for the investment decisions but retains the duty to monitor the ERISA 3(38) activities to assure D.A. Davidson is properly performing the agreed upon tasks using the agreed upon criteria. Self-Directed Brokerage and Advisory Accounts for Plan Participants. Brokerage and advisory accounts are offered to Plan participants that wish to add a brokerage or investment advisory option for their Plan accounts (when permitted by their Plan’s rules). Such accounts are provided to Plan participants in the same manner as other brokerage or advisory accounts at D.A. Davidson, pursuant to either D.A. Davidson’s Brokerage Agreement and D.A. Davidson’s Regulation Best Interest Disclosures for brokerage accounts or D.A. Davidson’s Single Advisory Agreement and this Brochure for advisory accounts, respectively. Financial Planning Services D.A. Davidson offers customized Financial Planning Services (specifically, the On Course Report and the Holistiplan Report described below) that are designed to help clients or prospective clients assess their financial situation and pursue their objectives. Financial Planning Services are meant to be a collaborative experience tailored to each client’s personal goals and customized to the complexity of their financial circumstances. The Financial Planning Services may be comprised of a modular plan, addressing targeted financial areas, or a comprehensive plan, based on the scope and complexity of the client’s planning needs. When D.A. Davidson clients with brokerage accounts (“brokerage clients”), investment advisory accounts (“advisory clients”) or prospective clients engage D.A. Davidson for Financial Planning Services at no additional cost, they enter into a verbal agreement to engage in the financial planning process, which terminates with the delivery of the financial plan or 90 days after the start of the financial planning relationship, whichever is earlier. These clients may also request and engage in a subsequent plan review or update, which is considered a new Financial Planning Services engagement subject to a new process and timeline. When brokerage clients, advisory clients or prospective clients engage D.A. Davidson for Financial Planning Services for a fee, they enter into a written service agreement (the “Agreement”), which outlines the services client will receive, the duration of the engagement (typically one year), and the applicable fees. On or about February 27, 2026, all brokerage clients and prospective clients, whether they engage D.A. Davidson for Financial Planning Services for a fee or at no additional cost, will enter into the Agreement, which will operate as described above. Brokerage clients may also request and engage in a subsequent plan review or update, and if such updates occur at least a year after the initial engagement, such reviews or updates will be considered a new Financial Planning Services engagement subject to a new process and timeline. Financial Planning Services will be available to all advisory clients at no additional cost and subject to the Single Advisory Agreement entered into by all advisory clients. As described in the D.A. Davidson Form ADV 2A Wrap Fee Program Brochure, available at dadavidson.com/Disclosure, and delivered to advisory clients upon enrollment in an advisory account, Financial Planning Services are separate and apart from the services provided with advisory clients’ accounts, are not monitored, and are not part of the asset-based fee advisory clients pay for advisory accounts. Advisory clients 6  will not receive a subsequent plan review or update unless requested and deemed appropriate by their Financial Advisor. The Financial Planning Services engagement will start with a discovery interview between clients or prospective clients and their Financial Advisor, where they will be asked to provide certain information and supporting documentation about their financial situation. The details requested will vary based on the complexity of the plan. The Financial Advisor will review the information provided by the client and prepare an analysis that, depending on the specific needs and circumstances of the client, and whether they have selected a modular or comprehensive plan, may integrate multiple financial planning topics. After this evaluation, clients will receive a financial plan (“On Course Report”), which will be created based upon the needs and requests of the client. The financial plan generally includes one or more of the following areas: Current Plan (a summary of current assets and their assignment to specific goals), Net Worth, Investment Profile, Asset Allocation Results, What If Comparison (a summary comparison of the Current Plan to an Alternative Plan), Plan Summary, Life Insurance Needs Analysis, Disability Needs Analysis, and Long Term Care Needs Analysis. The financial plan will then set forth recommendations intended to assist the client in reaching their financial goals, needs, and objectives as understood by D.A. Davidson during the particular point in time when it is prepared. Any recommendations made are general in nature and do not include any specific investments or insurance products. Clients can request as an additional Financial Planning Service a specific tax planning analysis (“Holistiplan Report”), which is based primarily upon client’s most recent tax return. This service is provided at no additional cost to the client. The analysis offers planning considerations and observations to the client based on their tax return information. Tax analysis should not be considered tax or legal advice, and clients are urged to consult their tax and legal professionals about the consequences of taking action on any of the considerations and observations. Davidson Private Wealth Services D.A. Davidson offers customized Davidson Private Wealth Services to D.A. Davidson brokerage clients, advisory clients, or prospective clients with more than $20 million in stated net worth. These services are designed to help clients assess their financial situation and pursue their objective utilizing a collaborative experience tailored to each client’s personal goals and customized to the complexity of their financial circumstances. When clients engage D.A. Davidson for Davidson Private Wealth Services, the client enters into a written service agreement outlining the services client will receive, the ongoing nature of the engagement, and the scope and complexity of client’s planning needs (the “Engagement Letter”). Clients who engage D.A. Davidson for Davidson Private Wealth Services will start by engaging in a discovery interview with a member of the Wealth Planning Group (the “Planning Provider”), where they provide certain information about their financial situation, and supporting documentation. The Planning Provider will review the information provided by the client and prepare an analysis that, depending on the specific needs and circumstances of the client, may integrate multiple financial planning topics. After this evaluation, clients will typically receive a comprehensive financial plan designed for clients receiving Davidson Private Wealth Services (the “Wealth Plan”). The Wealth Plan will set forth recommendations intended to assist the client in reaching their financial goals, needs, and objectives as understood by D.A. Davidson during the particular point in time when it is prepared. Any recommendations made are general in nature and do not include any specific investments or insurance products. Estate and Tax analysis should not be considered tax or legal advice, and clients are urged to consult their tax and legal professionals about the consequences of any specific strategy. D.A. Davidson may also provide referrals to lawyers, CPAs, or other providers. These referrals are ancillary to Davidson Private Wealth Services and are not a fiduciary service. The providers are minimally vetted based on certain pre-determined criteria. The Firm does not receive direct or indirect compensation as part of the referral. Scope and Limitations of Financial Planning Services and Davidson Private Wealth Services Financial Planning Services and Davidson Private Wealth Services do not include implementation of the financial plan, or initial or ongoing advice regarding specific securities or other investments or insurance products. Clients are not required to establish accounts at D.A. Davidson, purchase products that D.A. Davidson distributes, or otherwise transact business through D.A. Davidson or any of our affiliates in order to put into action any aspect of the financial plan. If client decides to separately engage D.A. Davidson for securities or investment products and services, the capacity in which D.A. Davidson is acting when helping client implement an investment strategy will depend on, and vary by, the nature of client’s account (i.e., brokerage or advisory) used for such implementation and is not impacted by the Financial Planning Services or Davidson Private Wealth Services provided. 7  D.A. Davidson’s Financial Advisors, Planning Providers, and its associates are not legal or tax experts and will not provide any legal or tax advice to a client as part of the Financial Planning Services or Davidson Private Wealth Services. While Financial Planning Services may include legal or tax information and/or analysis, such information is not deemed to be legal or tax advice and should not be relied upon as such. Clients are urged to consult with their personal legal and accounting professionals before taking any action that may have legal or tax consequences. Assets Under Management As of September 30, 2025, D.A. Davidson has approximately $41,839,300,000 in regulatory assets under management for its wrap fee programs, approximately $38,297,500,000 of which was managed on a discretionary basis and $3,541,800,000 of which is managed on a non-discretionary basis. Further information concerning D.A. Davidson’s wrap fee programs is included in the Firm’s Wrap Fee Program Brochure and is available upon request. Item 5 Fees and Compensation Retirement Plan Services ERISA 3(21) and 3(38) Services to Plans. The fees for 3(21) and 3(38) services to Plans are negotiable, depending on the operational, investment-related, and educational services selected by the Plan Fiduciary and are either equal to a percentage of the Plan assets or offered for a flat rate. Depending on the terms in the service agreement with the Plan Fiduciary, fees are billed on a monthly, quarterly, or annual schedule, in advance or arrears. Fees are generally remitted by the recordkeeper out of Plan assets, although a Plan Fiduciary may elect for D.A. Davidson to invoice the employer directly. Fees for Plan services that commence or end during the middle of a billing period, and are calculated by D.A. Davidson, are prorated based on the number of days the Plan is serviced during the quarter. In instances where the recordkeeper is the custodian for plan assets, the recordkeeper calculates the fees and is responsible for prorating the fees in accordance with their terms of service. All fees paid to D.A. Davidson for the 3(21) and 3(38) services are separate and distinct from the transaction fees and other expenses charged by broker-dealers, custodians, investment companies, record-keepers, and other third-party vendors for products and services selected by the Plan Fiduciary. D.A. Davidson and its Financial Advisors primarily recommend investments and share classes (if applicable) designed for ERISA covered plans. Investments can include sales charges, management fees, and a 12b-1 fee or other marketing expenses. D.A. Davidson does not typically receive any of this additional compensation from the investment company or any other third party. For more information about different types of investments and their fees, please see D.A. Davidson’s Regulation Best Interest Disclosures. Any education or advice provided to the Plan participants under the 3(21) or 3(38) services to the Plan are provided at no additional cost to the Plan participants. Self-Directed Brokerage and Advisory Accounts for Plan Participants. As previously noted, D.A. Davidson can provide brokerage or advisory accounts to Plan participants that wish to add a brokerage or investment advisory option for their Plan accounts (when permitted by their Plan’s rules) either through a broker-dealer or wrap fee program agreement. The fees, expenses, and related conflicts of interest for brokerage and advisory accounts are further described in D.A. Davidson’s Regulation Best Interest Disclosures and Wrap Fee Program Brochure, respectively, which clients receive upon opening of these accounts. Financial Planning Services As described under Item 4 above, Financial Planning Services can be provided at no additional cost to D.A. Davidson clients and on or about February 27, 2026, Financial Planning Services are available to all advisory clients. If a fee is assessed for Financial Planning Services, such fee will be determined by a client’s Financial Advisor based on local market considerations and the complexity of the financial planning needs involved. Fees for Financial Planning Services are negotiable and generally range from $1,500 to $15,000 or more depending on the nature of the services and complexity of the client’s circumstances. The fees charged for Financial Planning Services are paid to D.A. Davidson, a portion of which is paid to the Financial Advisor providing the services. Financial professionals who do not meet licensing, tenure, or other requirements set forth in the fee for planning policy may still charge a fee for a financial plan prepared by D.A. Davidson’s Wealth Planning Group or another D.A. Davidson Financial Advisor with the necessary credentials and receive a portion of such fee in the form of a revenue sharing arrangement, depending on the Financial Advisor’s seniority and involvement in the planning process. All fees are agreed upon in writing and will be due upon entering into the Agreement. In certain circumstances, 8  50% of the fee will be payable upon entering into the Agreement with the remainder due upon completion of the agreed upon services and delivery of the financial plan. D.A. Davidson may waive and/or refund part or all fees for Financial Planning Services in its sole discretion. However, in the event the client cancels the services prior to the completion of the plan, any portion of the fee paid in advance is not reimbursable. Davidson Private Wealth Services Davidson Private Wealth Services are available to clients with a stated net worth of $20 million at no additional cost. If clients decide to separately open accounts with D.A. Davidson, such accounts generate brokerage and advisory fees. Please see D.A. Davidson’s Form CRS for a description of our services overall, D.A. Davidson’s Wrap Fee Program Brochure for details about our advisory services, fees and conflicts of interest and Regulation Best Interest Disclosures for details about our brokerage services, fees, and conflicts of interest. Item 6 Performance-Based Fees and Side-By-Side Management D.A. Davidson does not charge performance-based fees (i.e., fees based on a share of capital gains or capital appreciation of the client's account assets) in any of the Wrap Fee Programs, Retirement Plan Services, Financial Planning Services, or Davidson Private Wealth Services. Item 7 Types of Clients Retirement Plan Services D.A. Davidson provides 3(21) and 3(38) Retirement Plan Services to ERISA and non-ERISA employer sponsored plans and their employees. ERISA and non-ERISA covered plans generally include defined benefit plans, such as employee pension plans, and defined contribution plans, such as 401(k), 403(b), profit sharing, and employee stock ownership plans, Keogh, or non-qualified deferred compensation plans. Education and non-discretionary advice is also offered to individual Plan participants. There are no minimum asset requirements for Retirement Plan Services. Also, D.A. Davidson provides self-directed brokerage and advisory accounts to Plan participants. There may be minimum account size requirements based on the type of account chosen. See D.A Davidson’s Regulation Best Interest Disclosures and Wrap Fee Program Brochure, respectively, for information regarding the minimums and fees for these accounts. Financial Planning Services D.A. Davidson offers Financial Planning Services to current or prospective clients, including individuals, high net worth clients, trusts and estates, business owners, and corporate executives. There is no minimum account size, dollar value of assets held at D.A. Davidson, or other conditions required to receive these services. Davidson Private Wealth Services D.A. Davidson offers Davidson Private Wealth Services to current or prospective clients with over $20 million in stated net worth that are individuals, trusts and estates, business owners, and corporate executives. There is no minimum account size, dollar value of assets held at D.A. Davidson, or other conditions required to receive these services. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss This section describes the methods of analysis and investment strategies utilized in formulating investment advice or managing assets for the programs and services covered in this Brochure. This includes important information concerning the material risks involved in each method. Clients should understand investing in any security, including mutual funds, involves a risk of loss of both income and principal. Risk is inherent in any investment and D.A. Davidson does not guarantee any level of return on a client’s investments. The methods of analysis, investment strategies and risks specific to D.A. Davidson’s wrap fee program are provided in the Wrap Fee Program Brochure. The Wrap Fee Program Brochure and specific product and transaction risks disclosures are also available under D.A. Davidson’s Important Disclosures page, located online at dadavidson.com/Disclosures, or upon request through a Financial Advisor. 9  RETIREMENT PLAN SERVICES Methods of Analysis As noted under Item 4 – Description of Services, D.A. Davidson’s Retirement Plan Services include 3(21) and 3(38) services to Plans and self-directed brokerage and advisory accounts for Plan participants. When providing 3(21) and 3(38) services to Plans by recommending/determining and monitoring Plan investments, D.A. Davidson’s Financial Advisor does so in accordance with the Plan’s IPS, if available or investment mandate and utilizes third-party applications to assist with analysis. D.A. Davidson’s Financial Advisors use both qualitative and quantitative analysis of investment vehicles for inclusion in a Plan’s investment options. This applies to both the initial recommendations and periodically to determine whether to add or replace investment vehicles available within the Plan. In general, a quantitative screening process includes statistical factors such average performance versus peers and benchmarks, volatility, fees and other expenses, and an investment vehicle’s portfolio composition (allocation of investments). Qualitative analysis generally includes an evaluation of an investment vehicle’s objective and strategy, as well as the portfolio manager’s investment philosophy, staffing, and investment process. When providing self-directed brokerage and advisory accounts for Plan participants by recommending investments available on D.A. Davidson’s brokerage and advisory platform, D.A. Davidson’s Financial Advisors do so as described in D.A. Davidson’s Regulation Best Interest Disclosures and Wrap Fee Program Disclosure Brochure. These accounts operate in the same manner as D.A. Davidson’s brokerage and advisory accounts. Material Risks The following describes the material risks in the methods of analysis for the 3(21) and 3(38) services to Plans. The material risks for self-directed brokerage and advisory accounts for Plan participants are described in D.A. Davidson’s Regulation Best Interest Disclosures and Wrap Fee Program Disclosure Brochure. Accuracy of Data. Securities analysis methods assume the companies whose securities trade in the markets, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we attempt to remain alert to indications that data may be incorrect, there is always a risk that D.A. Davidson’s analysis is compromised by inaccurate or misleading information. Mutual Fund, Collective Investment Trust (“CIT”), Exchange Traded Funds (“ETF”), and/or Exchange Traded Notes (“ETN”) Analysis. A common risk of the analysis for mutual funds, CITs, ETFs and ETNs is that, as with other securities investments, past performance does not guarantee future results. A manager who has been successful in identifying profitable opportunities among mutual funds may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in these products, managers of different funds held by the client may purchase the same security, creating concentrated exposure for the client to that security and increasing the risk to the client if that security were to fall in value. There is also a risk of a manager deviating from the stated investment mandate or strategy of the product, which could make the holding(s) less suitable for the client’s portfolio. Stable Value Fund Risk. A stable value fund is a fixed income fund with a “wrap” contract issued by a bank or insurance company. While contracts may provide for a stabilized book value (i.e., principal plus accumulated interest minus any withdrawals or expenses) for participant-initiated events, the contract typically will not provide for the stabilized book value for certain employer-initiated events (e.g., plan terminations, change of recordkeepers, or employer merger/acquisition). Although designed to be low-risk investments, these funds fluctuate and could be worth more or less than their original cost. Clients should consider investment objectives, risks and charges of stable value funds carefully before investing. This information is available in the fund prospectus. Interest Rate Risk. Fluctuations in interest rates cause the prices of securities to fluctuate. For example, bond market values have an inverse relationship to changes in interest rates. Generally, the longer a bond’s maturity, the greater the interest rate risk and the higher its yield. Similarly, equities may also suffer from rising interest rates. Market Risk. Market risk is the risk of investment losses due in a client’s account due to a variety of reasons outside of D.A. Davidson’s control, including, but not limited to, changes in the macroeconomic environment, unpredictable market sentiment, forecasted or unforeseen economic developments, interest rates, regulatory changes, and domestic or foreign political, demographic, epidemic, pandemic, or social events, independent of the intrinsic valuation of one or more securities in the client’s account. Inflation Risk. When any type of inflation is present, a dollar today will not buy as much as a dollar next year, 10  because purchasing power is eroding at the rate of inflation. Inflation risk is therefore the risk of inflation exceeding the return of an investment in the client’s account. Reinvestment Risk. This is the risk that future proceeds from investments have to be reinvested at a potentially lower rate of return (e.g., due to reductions in interest rates). This risk primarily relates to client account investments in fixed income securities. Business Risk. These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on cost-effectively finding oil, extracting it, and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of potential profitability than an electric company, which generates its income from a steady stream of customers who buy electricity regardless of the prevailing macroeconomic environment. Liquidity Risk. Liquidity is the ability to readily convert a security into cash. Generally, securities in a client’s account are more liquid if many individuals are interested in buying or selling them. For example, Treasury Bills are highly liquid, while real estate properties are relatively illiquid. Liquidity risk is therefore the risk that a client will not be able to promptly sell a security due to a limited market for that instrument. Financial Risk. Excessive borrowing to finance a business’ operations may create a degree of stress on the firm to the point of jeopardizing its profitability and potentially triggering a default on one or more outstanding loans. Depending on the circumstances, such a development could lead to a declining value in the company’s securities, or even its bankruptcy. Insurance Carrier Risk (specific to variable annuity and insurance products). This is the risk associated with an insurance carrier’s financial strength in meeting current, ongoing, and senior financial obligations, which are obligations to policy/contract holders. An insurance carrier’s balance sheet strength, operating performance and financial profile are major factors that quantify an insurance carrier’s financial strength. Global Economic Risk. National and regional economies and financial markets are becoming increasingly interconnected, which increases the possibility that conditions in one country, region or market might adversely impact issuers in a different country, region, or market. Changes in legal, political, regulatory, tax and economic conditions may cause fluctuations in markets and securities prices around the world, which could negatively impact the value of an account’s investments. Major economic or political disruptions, particularly in large economies, may have global negative economic and market repercussions. Additionally, events such as war, terrorism, natural and environmental disasters and the spread of infectious illnesses or other public health emergencies may adversely affect the global economy and the markets and issuers in which an account invests. These events could reduce consumer demand or economic output, result in market closure, travel restrictions or quarantines, and generally have a significant impact on the economy. Such events could materially increase risks, including market and liquidity risk, and significantly reduce account values. Cybersecurity Risk. Client portfolios are susceptible to operational, information security and related risks. In general, cyber incidents can result from deliberate attacks or unintentional events that include, but are not limited to, gaining unauthorized access to digital systems, misappropriating assets or sensitive information, corrupting data, or causing operational disruption, including the denial-of-service attacks on websites. Cyber security failures or breaches by a third party service provider and the issuers of securities in which the portfolio invests, have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, the inability to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, and/or additional compliance costs, including the cost to prevent cyber incidents. Technology Risk. The offerings are dependent upon various computer and telecommunication technologies, many of which are provided by or are dependent on third parties. The successful operation could be severely compromised by system or component failure, telecommunication failure, power loss, a software-related system crash, unauthorized system access or use (such as “hacking”), computer viruses and similar programs, fire or water damage, human errors in using or accessing relevant systems, or various other events or circumstances. It is not possible to provide comprehensive and foolproof protection against all such events, and no assurance can be given about the ability of applicable third parties to continue providing their services. Any event that interrupts such computer and/or telecommunication systems or operations could have a material adverse effect on the services. Such a material adverse effect may have a heightened impact on some of the services given the automated nature of the services provided. Specific Security Risks. In addition to the above risks, each security type has certain characteristics and is subject to a risk of loss that clients should be prepared to bear. For more information about risks associated with stocks, bonds, mutual funds (including alternative strategy mutual funds), ETFs, ETNs, options, alternatives, structured products, UITs (including buffered UITs), options, private equity, and advisory variable annuities speak 11  with a Financial Advisor. For risks associated with mutual funds and ETFs in client’s account, see the fund’s current prospectus. FINANCIAL PLANNING SERVICES AND DAVIDSON PRIVATE WEALTH SERVICES Methods of Analysis D.A. Davidson’s Financial Advisors conduct an analysis of a client’s Investment Profile and wealth and financial planning needs through an informational gathering process, which could include discovery interviews, financial and other Investment Profile information, account statements and reports, and tax records. Third party financial planning software applications are utilized to assist with analysis, the creation of the financial plan, and in recommending strategies to meet the client’s wealth or financial planning goals. This includes analysis tools that estimate the likelihood of the client reaching the financial goals if certain strategies are implemented or decisions are made. Although D.A. Davidson Financial Advisors use information and tools that D.A. Davidson deems reliable, D.A. Davidson does not independently verify or guarantee the accuracy of the information or tools used. Material Risks Accuracy of Client Information. In preparing a financial plan, D.A. Davidson relies on the accuracy and completeness of the information provided by the client, without independent verification. D.A. Davidson is not responsible for any inadequacies or errors contained in the financial plan resulting from a client’s failure to provide D.A. Davidson with accurate or complete information. Financial Planning Assumptions. Numerous assumptions are made during the financial planning process, which may turn out to be incorrect. As a result, the accuracy of any projections used for analysis and in turn any recommendations are limited. Clients should carefully review the assumptions, facts and related disclosures in any reports and presentations for accuracy and understanding. Clients are also encouraged to make appropriate adjustments to the assumptions used (e.g., “what if” scenarios”) as part of an interactive process to help assess the likelihood of reaching financial goals. Projected Performance Information. Projected valuations are based on indices assigned for various assets classes and their historical rates of return. The projected returns and valuations are hypothetical in nature and are based on past performance of the indices. Consequently, the accuracy of any projections are limited by the assumed rates of return. The projections, therefore, are utilized for illustrative purposes only, are not indicative of future results and should not be relied on as such. Monte Carlo Analysis. Financial plans that include Monte Carlo Analysis rely on a mathematical process to implement complex statistical methods that chart the probability of certain financial outcomes at certain times in the future. Analysis tools such as a Monte Carlo simulation will yield different results depending on the variables inputted, and the assumptions underlying the calculation. As with other projected performance figures, assumed rates of return are based on the historical rates of returns and standard deviations, for the indices comprising the asset classes that represent the client’s portfolio. Since past performance and market conditions may not be repeated in the future, the Monte Carlo Analysis is provided for illustrative purposes and is limited to the accuracy of the assumptions used in the analysis. In addition to the material risks described above, please review the assumptions and limitations provided in client’s financial plan. Item 9 Disciplinary Information The following is a summary of disciplinary events relating to D.A. Davidson, its management, and Affiliates that the Firm believes may be material to a prospective client's decision of whether to retain the Firm to provide investment advisory services. Further information regarding these settlements and other disciplinary matters relating to D.A. Davidson and its Affiliates is available on the SEC’s website at adviserinfo.sec.gov. Disciplinary Information Relating to D.A. Davidson’s Advisory Business The SEC issued an Order dated March 11, 2019 (SEC Administrative Proceeding File No. 3-19094) (the “SCSD Order”), relating to the resolution of a matter under the Division of Enforcement’s Share Class Selection Disclosure Initiative (the “SCSD Initiative”). The violations referred to in the SCSD Order were self-reported by D.A. Davidson. Pursuant to the SCSD Order, the SEC deemed it appropriate and in the public interest that public administrative and cease-and-desist proceedings be instituted against D.A. Davidson alleging that the Firm willfully violated Sections 206(2) and 207 of the Advisers Act in connection with its mutual fund share class selection practices and the fees it received pursuant to Rule 12b-1 under the Company Act. In connection with the SCSD Order, D.A. Davidson consented to: (a) cease and desist from committing or causing any violations and any future violation of sections 206(2) and 207 of the Advisers Act; (b) be censured; (c) pay disgorgement and prejudgment interest in 12  the amount of $654,276.41; and (d) comply with certain undertakings. As noted in the SCSD Order, in determining the settlement offer the SEC considered that D.A. Davidson self-reported its conduct to the SEC pursuant to the SCSD Initiative. Disciplinary Information Relating to D.A. Davidson’s Broker-Dealer Business In October 2018, D.A. Davidson, without admitting or denying the allegations, consented to findings and sanctions by FINRA that it failed to apply available mutual fund share class sales charge waivers to eligible retirement and charitable organization Brokerage Accounts, and to implement proper supervisory system and training procedures (NASD Rule 3010 and FINRA Rule 3110 violations). The matter was previously self-reported to FINRA by D.A. Davidson in May 2016. As part of the settlement, D.A. Davidson paid $447,000 in restitution, including interest, to approximately 303 customer accounts. D.A. Davidson was not fined as a result of its self-reporting of the matter and its cooperation with FINRA. D.A. Davidson also updated its training, policies and procedures, and other controls intended to ensure that an appropriate mutual fund share class is selected for clients, and that mutual fund sales charge waivers are applied in commission-based account transactions. In February 2016, a regulatory action disclosure relating to the SEC’s Order dated February 2, 2016 (SEC Admin Releases 33-10019; 34-77021) (the “MCDC Order”) was issued. The SEC MCDC Order was issued under the Division of Enforcement’s Municipalities Continuing Disclosure Cooperation Initiative, and the violations referred to therein were self-reported by D.A. Davidson. This included allegations of anti-fraud provision, due diligence, and continuing disclosure failures for the underwriting of certain municipal securities offerings, and the offering of municipal securities on the basis of materially misleading disclosure documents (SEC Rules 15c2-12 violations). During the relevant period, the SEC found the official statements for six securities offerings, between the period of 2012 – 2014, failed to disclose that the municipal issuers had either failed to file annual audited financial statements, or to file notices of late filings. Pursuant to the MCDC Order, the SEC deemed it appropriate and in the public interest that public administrative and cease-and-desist proceedings be instituted against D.A. Davidson, arising for willfully violating Section 17(a)(2) of the Securities Act (an antifraud provision of the federal securities laws) related to the underwriting of certain municipal securities offerings. In connection with the MCDC order, D.A. Davidson paid a $500,000 fine to the SEC. In addition, D.A. Davidson engaged an independent consultant to review and update the Firm’s policies, procedures, and other controls to help ensure compliance with the Firm’s regulatory requirements. Item 10 Other Financial Industry Activities and Affiliations D.A. Davidson, a dually registered investment adviser and broker-dealer, is a wholly owned subsidiary of D.A. Davidson Companies, a financial services holding company. D.A. Davidson Companies’ other subsidiaries, known as “Related Persons,” are D.A. Davidson Trust Services, Inc., a non-depository trust company, Davidson Investment Advisors, Inc., a federally registered investment adviser, and D.A. Davidson Trust Company, a federally chartered savings association. Broker-Dealer Services. D.A. Davidson is registered as both a broker-dealer and investment adviser. Financial Advisors engaged in providing advisory services are registered as investment adviser representatives in each state where such registration is required. Many D.A. Davidson Financial Advisors are also registered representatives of D.A. Davidson in its capacity as a broker-dealer. When acting as a broker-dealer, Financial Advisors provide brokerage and related services to clients, including in relation to the purchase and sale of individual stocks, fixed income securities, mutual funds, private investment funds, life insurance policies and annuities, and other products. These broker-dealer recommendations and any subsequent implementation are separate and distinct from the advisory services. See the D.A. Davidson Regulation Best Interest Disclosures at dadavidson.com/Disclosures for more information about D.A. Davidson’s brokerage services. D.A. Davidson Trust Services, Inc. ("DADTS"). DADTS is a non-depository trust company chartered in New Hampshire which acts as the custodian for D.A. Davidson client assets maintained in IRA and 403(b) accounts. D.A. Davidson provides DADTS with supporting administrative, recordkeeping and reporting services as the client’s broker-dealer. Davidson Investment Advisors (“DIA”). Financial Advisors may refer clients that meet certain minimum account size requirements to DIA in its capacity as an investment adviser. When D.A. Davidson Financial Advisors refer clients to DIA to manage assets in its capacity as an independent investment adviser, a portion of the fees that clients pay to DIA (typically, 20%-60%, with the average being 43%) are taken into account when determining the Financial Advisor’s compensation. Clients do not pay more for our affiliates’ services as a result of the referral from client’s Financial Advisor. Financial Advisors may also recommend DIA as an investment manager in certain wrap fee programs, as described in the D.A. Davidson Wrap Fee Brochure. DIA also creates certain model portfolios for D.A. Davidson’s use in certain wrap fee programs, as described in the D.A. Davidson Wrap Fee Brochure. 13  In addition, D.A. Davidson serves as the broker-dealer for some DIA clients. D.A. Davidson or its affiliate also serve as custodian for some DIA clients. Davidson Mutual Funds. DIA is the investment adviser to Davidson Mutual Funds, an investment company registered under the Investment Company Act. U.S. Bank Global Fund Services acts as Davidson Mutual Funds’ administrator and provides fund accounting and transfer agency services. D.A. Davidson offers the funds to its brokerage and certain advisory clients, however, Financial Advisors may not recommend the purchase of Davidson Mutual Funds in retirement accounts. See D.A. Davidson’s Regulation Best Interest Disclosures at dadavidson.com/Disclosures for conflict of interest information when recommending Davidson Mutual Funds as a broker-dealer. See D.A. Davidson’s Wrap Program Brochure at dadavidson.com/Disclosures for conflict of interest information when recommending Davidson Mutual Funds in a wrap fee program. DIA receives fees for advising the Davidson Mutual Funds. Those fees are based on the amount of assets held in the Davidson Mutual Funds, which increases with any new purchases of fund shares. The fees charged by DIA for managing the Davidson Mutual Funds are disclosed in the relevant fund’s prospectus. As mutual fund shareholders, investors indirectly pay a portion of the ongoing expenses of the fund. These expenses include the management fee charged by DIA, and all other ongoing fees and expenses incurred in the administration of the Davidson Mutual Funds. Further information regarding the Davidson Mutual Funds, including a copy of the Prospectus and Statement of Additional Information for the funds, is available at: davidsonmutualfunds.com/. Prospective investors in the Davidson Mutual Funds should review these documents carefully before making any investment in a fund. Davidson Trust Company (“DTC”). Financial Advisors may also refer clients to DTC to provide professional trust administration services, including recordkeeping, income distribution, bill paying, and general account administration. For making the referral, a portion of the fees that clients pay to DTC (50%) are taken into account when determining the Financial Advisor’s compensation and those funds also generate payment at a 50% rate on their compensation grid, which may be higher than the rate for which they otherwise may have qualified. This fee sharing arrangement will not result in any increased charges to the client. Neither D.A. Davidson nor any Financial Advisor will provide trust support services for DTC as a result of the referral. In addition, DTC may elect to hire DIA or a D.A. Davidson Financial Advisor as the investment adviser for certain client accounts over which DTC has investment discretion. DTC shares a portion of its investment management fee with DIA for providing investment advisory services. D.A. Davidson Paragon Managers are paid at a 50% rate on their compensation grid as outlined above. This fee sharing arrangement creates a conflict of interest for D.A. Davidson, its Financial Advisors, and DTC because the total account administration and investment management fee is divided among DTC, the referring Financial Advisor, the investment adviser (i.e., D.A. Davidson or DIA), and D.A. Davidson Companies. However, when D.A. Davidson or DIA serve as the investment adviser for a DTC account, the total account fee for administrative and investment advisory services will be equal to or less than the total fees if the services were provided separately. DTC may also administer accounts over which it does not have investment discretion. In such instances, the client may independently choose to hire a D.A. Davidson-related Paragon Manager to provide investment advisory services to the account. In these arrangements, the total fee to the client will include separate charges by DTC for account administration and by D.A. Davidson for investment advisory services. Outside Business Activities. Some D.A. Davidson Financial Advisors have been approved to conduct business activities that compete for their time, outside the scope of their duties with D.A. Davidson. If a client’s Financial Advisor engages in any outside business activities, these activities can create an incentive for the Financial Advisor to spend more time on the outside business activity rather than on their relationships with clients. All employees are required to obtain approval from their supervisor prior to engaging in such activities to help ensure the activity does not conflict with their D.A. Davidson duties. In addition, any investment related activities or activities that provide a substantial source of the Financial Advisor’s income or involve a substantial amount of the Financial Advisor’s time must be disclosed in their Form ADV 2B Supplemental Brochure. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics and Personal Trading Code of Ethics. D.A. Davidson has adopted a Code of Ethics (the “Code”), which sets forth the standards of business conduct required of its employees, including compliance with applicable federal securities laws. The Code applies to D.A. Davidson officers, directors and employees involved in the Firm’s investment advisory business (“supervised persons”) and employees providing, or supporting the provision of, investment advice to clients (“access persons.”) Among other provisions, the Code outlines the Firm’s fiduciary responsibilities when 14  interacting with clients, governs personal securities trading by supervised persons and designated access persons, and strictly prohibits insider trading and other forms of unethical business conduct. The Code is based upon the principle that D.A. Davidson owes fiduciary duties of loyalty and care to D.A. Davidson’s advisory clients. These duties require the Firm, and certain of its supervised persons (“access persons”), to: provide investment advice in the client’s best interest; seek to obtain best execution of securities transactions in client accounts; and have a reasonable, independent basis for investment recommendations. D.A. Davidson access persons must also conduct their affairs, including when purchasing and selling securities in their personal securities accounts, in such a manner as to avoid: (i) placing their own personal interests ahead of client interests; (ii) taking inappropriate advantage of their position with the Firm; and (iii) creating any potential or actual conflicts of interest, or otherwise abusing their position of trust and responsibility. The Code prohibits Financial Advisors from placing personal transactions ahead of client transactions in the same security on the same day as they are placing a trade in a client’s account. An exception to this policy is permitted when the access person’s account is managed in the same manner as other client accounts and does not result in a more favorable price to the access person. Clients may request a copy of the Code of Ethics by calling D.A. Davidson’s Compliance Department at 406-727- 4200 or 800-332-5915. Item 12 Brokerage Practices Retirement Plan Services D.A. Davidson and its Financial Advisors generally do not offer Brokerage Services to plans custodied outside of D.A. Davidson. Brokerage services to SIMPLE IRA, SEPS, and Keogh Plans may be held at custodians other than D.A. Davidson. When providing self-directed brokerage and advisory accounts for Plans or plan participants they are D.A. Davidson’s brokerage and advisory accounts. As a result, the brokerage and advisory practices are as described in D.A. Davidson’s Regulation Best Interest Disclosures and Wrap Fee Program Disclosure Brochure, respectively. Financial Planning Services and Davidson Private Wealth As previously noted, the scope of the Financial Planning Services and Davidson Private Wealth Services described in this Brochure includes recommendations that are general in nature and does not include any specific securities or broker-dealer recommendations to implement a financial plan. Clients have the option but are not required to transact business through D.A. Davidson to implement the financial plan. Please see D.A. Davidson’s Regulation Best Interest Disclosures and the Wrap Fee Program Brochure, for further information regarding the broker-dealer and wrap fee programs offered by D.A. Davidson and the related brokerage practices. Item 13 Review of Accounts Retirement Plan Services. When providing 3(21) and 3(38) services to Plans, the Financial Advisor reviews the Plan in the manner and frequency specified by the written agreement between D.A. Davidson and the Plan Fiduciary and or Adopting Employer. Additionally, the Financial Advisor provides reporting to monitor the independent managers’ performance relative to the IPS, if provided, in the manner and frequency specified by the written agreement between D.A. Davidson and the Plan Fiduciary and or Adopting Employer. When providing self-directed brokerage and advisory accounts for Plan participants, the brokerage and advisory review and reporting practices are as described in D.A. Davidson’s Regulation Best Interest Disclosures and Wrap Fee Program Disclosure Brochure, respectively. There is no monitoring of brokerage accounts. Financial Planning Services. The Financial Planning Services are episodic in nature and do not include ongoing financial planning advice. As such, D.A. Davidson does not have an ongoing obligation to monitor client’s financial circumstances or to periodically evaluate whether the advice set forth in the financial plan continues to be appropriate nor to provide review or reporting. Davidson Private Wealth Services. Davidson Private Wealth Services include ongoing financial planning advice and, as such, D.A. Davidson has an ongoing obligation to monitor client’s financial circumstances and to periodically evaluate whether the advice set forth in the financial plan continues to be appropriate. This is done through calls and meetings between the Financial Advisor and clients who receive Davidson Private Wealth Services, which are conducted at least annually. Clients do not receive any regular written report in connection with this service, besides a financial plan that is periodically updated. 15  Item 14 Client Referrals and Other Compensation Client Referrals. D.A. Davidson pays referral fees to independent third parties and firms (each, a “Promoter,” and collectively, "Promoters") for introducing clients to D.A. Davidson for the wrap fee programs. See D.A. Davidson’s Wrap Fee Program Brochure for more information. Davidson Trust also refers clients to D.A. Davidson. However, Davidson Trust is not compensated for such client referrals. Further information regarding the conflicts of interest associated with referrals and other business terms among D.A. Davidson and its Affiliates, and how D.A. Davidson addresses those conflicts, is included in the Other Financial Industry Activities and Affiliations section above. Revenue Sharing Arrangements. Some issuers and sponsors of investments recommended by D.A. Davidson share a portion of their revenue. These payments, sometimes called “revenue sharing” payments, are usually based on the total amount of sales we make of their investments, the total amount of client assets invested with them, or certain of D.A. Davidson’s proprietary investment data related to its advisory business (excluding any client specific personally identifiable information). This creates a financial incentive for our Firm to include and retain, or feature and promote, investments on our platform whose issuers or sponsors provide revenue-sharing arrangements, particularly those that offer higher levels of compensation. To mitigate this conflict of interest, revenue sharing arrangements are not considered in determining whether a product is added to, retained, or removed from D.A. Davidson’s platform. All products are evaluated based on documented investment and operational criteria applied consistently across issuers and sponsors of investments. Revenue sharing arrangements could also create an incentive for Financial Advisors to recommend or select certain investments over others, particularly those that offer higher levels of compensation. We mitigate this conflict by not sharing these payments with our Financial Advisors and not publishing lists identifying specific revenue sharing funds or share classes. ‑ A list of the investment product issuers and sponsors who provide D.A. Davidson with revenue sharing payments is included in the Exhibit of D.A. Davidson’s Regulation Best Interest Disclosures and is available upon request. Recordkeeping/Shareholder Servicing Fees. For some investment products, such as mutual funds, alternative investments, and advisory variable annuities, D.A. Davidson receives ongoing fees for recordkeeping and other shareholder or administrative services. For example, D.A. Davidson receive fees in connection with mutual fund investments for sub-accounting and sub-transfer agent services in respect of our clients (but does not retain those fees for qualified advisory accounts). The Firm receives these fees for tracking fund ownership among our client accounts, distributing prospectuses, processing transactions on an omnibus basis and similar services. These fees create an incentive for D.A. Davidson to make available on our platform, and encourage the purchase of, investments who pay the Firm for such services, and pay the Firm more than others. As a percentage of client assets held in investment products for which D.A. Davidson receives these types of fees, the total such fees the Firm would receive in most years is approximately 0.05-0.07%. Because D.A. Davidson generally provides these types of services on an omnibus (across-the-board) basis, the fee rates the Firm receives typically do not vary materially within categories of products (for example, from one mutual fund to another mutual fund). D.A. Davidson does not share these recordkeeping or other shareholder service fees with our Financial Advisors. Education and Marketing Support. Some investment product sponsors, including those with whom D.A. Davidson has revenue sharing arrangements, contribute to or reimburse D.A. Davidson for the cost of educational and marketing events. Invitations to educational events could include payment for costs associated with the event, including travel and lodging for our Financial Advisors. Marketing events include client and/or employee events where some or all of the costs are covered by a product sponsor. Some of these events, which are hosted by D.A. Davidson, are offered in multiple tiers – this means that product sponsors pay different amounts and as a result receive different levels of benefits. For example, these different benefits might include having their speaker at a main session versus a breakout session, a more prominent display in the materials used in connection with the event, etc. These payments provide an incentive for D.A. Davidson and our Financial Advisors to recommend investment products whose sponsors provide these additional support payments to us, and those who make higher support payments, than others. D.A. Davidson imposes an internal review and approval process to ensure that these payments are not unreasonable (or otherwise inappropriate) under the circumstances. Additionally, we do not permit payments for educational and marketing events to be made directly to our Financial Advisors. A list of the investment product sponsors who provide our Firm with payments and reimbursements in support of our 16  education and marketing efforts is included in the Exhibit to the Regulation Best Interest Disclosures and is available upon request. Gifts from Sponsors. D.A. Davidson Financial Advisors sometimes receive additional non-cash compensation from investment product sponsors including such items as gifts valued at less than $100 annually or an occasional dinner or ticket to a sporting or entertainment event. These gifts provide an incentive for our Financial Advisors to recommend investment products whose sponsors provide these forms of compensation. To mitigate these incentives, our Firm imposes an internal review process for gifts received by our Financial Advisors. Production/Compensation Grid. The single most important factor affecting a D.A. Davidson Financial Advisor’s cash compensation is the total amount of revenue they generate for the Firm, which is sometimes referred to as their “production.” Specifically, the primary cash compensation paid to Financial Advisors (which is determined and paid monthly) is a percentage share of production, generally between 25% and 51%. For each Financial Advisor, the exact percentage received for a given month is determined primarily according to production over the previous six (6) month period, and industry tenure, as set forth in our base compensation grid. D.A. Davidson’s compensation grid has thresholds or bands that enable the Financial Advisor to increase compensation through an incremental increase in production. Financial Advisors are incentivized to maximize their ongoing production. The higher their production over the previous six (6) month period, the greater the potential share they can earn for the current month. Stated simply, increasing production can lead to a larger percentage and a larger overall payout. This structure creates an incentive for Financial Advisors to recommend advisory programs – particularly those that generate higher revenues – because doing so can increase production-eligible revenue over time. D.A. Davidson has policies and procedures designed to help ensure the Firm and its Financial Advisors meet fiduciary obligations. Under our compensation grid, the percentage of production a Financial Advisor receives as cash compensation is determined monthly using a 6-month lookback period and includes several incremental rate steps. These features help manage the incremental compensation increases Financial Advisors can achieve for discrete sales or for sales over a short period. Also, certain revenues we receive as a Firm do not count toward the Financial Advisors’ production, such as margin interest and payments from third-party banks that participate in our cash management program, recordkeeping, sub-accounting and other administrative service fees from mutual funds, and certain revenue sharing payments. Other Bonuses and Awards. Financial Advisors can earn deferred performance awards of up to 5.5% of annual production, which are payable in cash or stock of D.A. Davidson’s parent company and are subject to five-year cliff vesting. Financial Advisors with over seven (7) years’ tenure with the Firm can also earn additional loyalty bonuses of up to 4.5% of annual production. These awards and bonuses are based largely on each Financial Advisor’s tenure with our Firm and production as of the end of a performance measurement period (typically September 30, the end of D.A. Davidson’s fiscal year). Typically, each Financial Advisor is eligible to receive bonuses and awards with respect to any single year that totals up to 10% of production. Based on production and other factors, Financial Advisors can also earn awards in the form of non-cash compensation (i.e., rewards trips), larger expense allowances (up to 1.5% of production) and additional “concierge” support services. Upon qualified retirement, Financial Advisors can receive compensation through the sharing of gross production generated from their transitioned book of business, generally over the course of four years after the end of their employment. In addition, Financial Advisors can get an additional gross production premium of 5.0% to 12.5%, depending on firm tenure, reoccurring revenue mix, and productivity. The conflicts created by these other bonuses and awards are particularly acute toward the end of a performance measurement period (typically September 30, the end of D.A. Davidson’s fiscal year). To mitigate this conflict, the Firm conducts specific surveillance of Financial Advisor activity levels during this period. Additionally, to earn certain bonuses and awards, Financial Advisors must be in good standing with the Firm’s policies and procedures. Team Formation. The Firm supports a team formation process with minimum production requirements that permit a Financial Advisor to earn compensation based on both their own production and that of their teammates. This creates the same conflicts of interest identified under Production/Compensation Grids and Other Bonuses and Awards. Recruitment Incentives. When some Financial Advisors join D.A. Davidson from another firm, we grant them expense allowances and forgivable loans that can be repaid through bonus payments earned by remaining with 17  our Firm over a set period (typically nine (9) years). In many cases, new Financial Advisors receive a fixed compensation grid for their first year, which may be higher than the standard grid. Additionally, some new Financial Advisors may be offered one of the following incentives: (i) an increased compensation grid on future advisory fees and commissions if certain production goals are met; (ii) additional forgivable loans if certain production goals are met; or (iii) additional forgivable loans if certain asset gathering goals are met. These incentives encourage new Financial Advisors to recommend that clients move additional assets to our Firm and, for (i) and (ii) above, to recommend accounts that generate higher revenues. These additional forms of compensation are typically earned over several years and tied to performance over consecutive twelve (12) month periods, which helps reduce the incentive to achieve larger sales volumes over shorter periods. Clients who have an existing relationship with a financial professional who joins our Firm receive an educational document explaining potential conflicts of interest related to transferring their account to our Firm. Also, while new Financial Advisors may receive expense allowances (as described above under “Other Bonuses and Awards”), they typically are not eligible for deferred performance awards or loyalty bonuses until they have reached Four (4) or seven (7) years’ tenure, respectively. Certain Manager Incentives. The compensation of Branch Office Managers (“BOMs”) is tied to the overall production of the branch(es) they manage, which incentivizes them to focus on growing production more than on their supervisory responsibilities. Our Firm has other management and supervisory personnel who participate in the supervision and oversight of our branches, regions, and Firm generally, who are not compensated based on production levels. However, the BOMs have ultimate supervisory and oversight responsibility for their branches. Mutual Fund 12b-1 Fees. Certain mutual fund share classes pay D.A. Davidson a 12b-1 Fee, which is an annual marketing and distribution fee. D.A. Davidson will also rebate to the client participating in a wrap fee program any 12b-1 Fee received by the Firm in connection with mutual fund shares held in that client’s account. Additionally, D.A. Davidson uses commercially reasonable efforts to convert any existing wrap fee program account mutual fund holdings in a 12b-1 Fee-paying share class to shares of a class that does not pay a 12b-1 Fee, when consistent with the client’s investment objectives, asset allocation, and other circumstances. Item 15 Custody Retirement Plan Services. For the 3(38) and 3(21) services to Plans, D.A. Davidson does not typically custody the assets. In that case, the qualified custodian will provide account statements directly to clients and clients should carefully review those statements. When D.A. Davidson or its affiliate does custody the assets, clients will receive statements from D.A. Davidson and should carefully review those statements. When providing self-directed brokerage and advisory accounts for Plan participants D.A. Davidson or its affiliate has custody over those assets. Clients will receive statements from D.A. Davidson and should carefully review those statements. Financial Planning Services and Davidson Private Wealth Services. The Financial Planning Services and Davidson Private Wealth Services described in this Brochure are separate and distinct from the asset management and other investment advisory services described in D.A. Davidson’s Wrap Fee Program Brochure and does not include the custody of assets. Item 16 Investment Discretion Retirement Plan Services. When providing 3(21) services to a Plan, D.A. Davidson does not have discretionary authority with regard to any Plan assets. When providing 3(38) services to a Plan, D.A. Davidson has discretionary authority pursuant to a written agreement with the Plan Fiduciary to act as an ERISA 3(38) investment adviser. In that case, a Financial Advisor is responsible for the selection, monitoring, and replacement of investment options. Additionally, D.A. Davidson is authorized to implement and effect investment advice without the Plan Fiduciary’s prior authorization. When providing self-directed brokerage and advisory accounts for Plan participants, D.A. Davidson has discretionary authority only for certain discretionary wrap fee programs as described in the D.A. Davidson Wrap Fee Program Brochure. D.A. Davidson does not have discretion over brokerage accounts. Financial Planning Services and Davidson Private Wealth Services. Services include recommendations on general asset allocations but do not include the recommendation of specific securities or products, or execution of transactions. The scope of Financial Planning Services and Davidson Private Wealth Services does not include the execution of transactions, on a discretionary or non-discretionary basis. 18  Item 17 Voting Client Securities D.A. Davidson does not vote client securities in relation to Retirement Plan Services, Financial Planning Services, or Davidson Private Wealth Services. Please see D.A. Davidson’s Wrap Fee Program Brochure for a description of how D.A. Davidson votes securities for its Wrap Fee Programs. Item 18 Financial Information D.A. Davidson is required to disclose any financial condition that is reasonably likely to impair the Firm’s ability to meet its contractual obligations. D.A. Davidson has no such financial circumstance to report. Under no circumstances does D.A. Davidson require or solicit payment of fees in excess of $1,200 more than six (6) months in advance of services rendered. 19