← Back to Osaic Wealth, Inc. profile
SIGNATOR MANAGED ACCOUNT PLATFORM
Osaic Wealth, Inc. (CRD 23131), brochure dated August 28, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
Part 2A Appendix 1
Program Brochure
Signator
Managed
Account
Platform
Current as of August 31, 2026
© Osaic Wealth, Inc. • 18700 N. Hayden Rd., Suite 255 • Scottsdale, AZ 85255 • 800-821-5100 • osaic.com
This wrap fee program brochure provides information about the qualifications and business practices of Osaic Wealth, Inc. If you have any questions
about the contents of this brochure, please contact us at 800-821-5100. Osaic Wealth, Inc. is registered with the Securities and Exchange Commission
(SEC) as a registered investment adviser. Registration does not imply any level of skill or training. The information in this brochure has not been
approved or verified by the SEC or by any state securities authority.
Additional information about Osaic Wealth, Inc. also available on the SEC’s website at adviserinfo.sec.gov. You can search this site by a unique
identifying number, known as a CRD number. The CRD number for the Firm is 23131.
Item 2 - Material Changes
This item discusses only specific material changes that are made to the Signator Managed Account
Platform Brochure and provides clients with a summary of such changes. Osaic Wealth Inc. filed its last
annual amendment to the Form ADV Part 2A Appendix 1 Program Brochure on March 31, 2026. Since
then, the following material changes have occurred:
• Item 4 – Updated ownership structure
Item 3 - Table of Contents
Item 2
Material Changes
2
Item 3
Table of Contents
3
Item 4
Services, Fees & Compensation
4
Item 5
Account Requirements and Types of Clients
17
Item 6
Portfolio Manager Selection and Evaluation
17
Item 7
Client Information Provided to Portfolio Managers
18
Item 8
Client Contact with Portfolio Managers
18
Item 9
Additional Information
18
Item 4 - Services, Fees & Compensation
Osaic Wealth, Inc. is registered as an investment adviser with the SEC, SEC File No. 801-54859, in order to offer
investment advisory products and services to its advisory clients. Osaic Wealth, Inc. is also a member of the Financial
Industry Regulatory Authority (“FINRA”) as a broker-dealer engaged in the offer and sale of securities products.
Advisory products and services are offered through certain Financial Advisors (“FAs”) who have registered as
Investment Adviser Representatives (“Advisory Representative”). Registration does not imply a certain level of skill
or training. Osaic Wealth, Inc. is a subsidiary of Osaic, Inc., an indirect wholly-owned subsidiary of Osaic Holdings,
Inc., which is indirectly owned primarily by a consortium of investors through investment funds affiliated with Reverence
Capital Partners LLC, including RCP Artemis Co-Invest, L.P. and Reverence Capital Partners Olympus CV LP (“RCP CV”). For
a list of material direct and indirect investors of RCP CV, please refer to the firm’s Form ADV Part 1A, Schedule B.
Osaic Wealth, Inc. the broker-dealer, will henceforth be referred to as “Osaic Wealth”. Osaic Wealth, Inc. the
Registered Investment Adviser, will henceforth be referred to as, “we”, “us”, “our” or the “Firm”.
The Firm, through its affiliated Advisory Representatives, provides a variety of services designed to meet the needs
of retail individual and corporate clients. This brochure contains information about Signator Managed Account
Platform (the “Program”), a wrap fee program sponsored by the Firm.
Advisory Services
The Signator Managed Account Platform (the “Program”) is not being offered to new customers and is only available
to existing owners.
The Firm is the sponsor of the Program, which provides clients with advisory, custody and brokerage execution
services for one all-inclusive fee (the “Fee”). This means that the cost of the Firm’s investment advisory services,
the cost of executing brokerage transactions and custodial fees are “wrapped” into a single annual fee based on the
value of the client’s portfolio. The Firm has clearing relationships with National Financial Services, LLC (“NFS”) and
Pershing, LLC. (“Pershing”).
Both NFS and Pershing are “qualified custodians,” as that term is defined in Rule 206(4)-2(d)(6) of the Investment
Advisers Act of 1940.
The Firms’ clients, with accounts that trade through the Osaic Wealth broker-dealer, pay fees through a “wrap
account” program sponsored by the Firm, which is a program that provides clients with advisory, custody and
brokerage execution services for the Fee. This means that the cost of the Firm’s investment advisory services, the
cost of executing brokerage transactions and custodial fees are “wrapped” into a single annual fee (charged
quarterly in advance) based on the value of the client’s portfolio. Investments offered through the Program include
such securities as equities, mutual funds, Electronically Traded Funds (“ETFs”), and fixed income securities.
The Program offers mutual fund and/or exchange traded fund programs, advisor directed portfolios, separately
managed accounts and a unified managed account program. The Firm is the sponsor and Registered Investment
Adviser.
Envestnet Asset Management, Inc. (“Envestnet”) is also a registered investment adviser to the Program. Envestnet
is located at 35 E. Wacker Dr., Suite 2400, Chicago IL 60601.
Envestnet’s Form ADV Part 2A is given to clients and prospective clients of the Program and contains specific details
about Envestnet and its investment advisory qualifications and services. For additional information about Envestnet,
please see Envestnet’s Form ADV Part 2A.
The Program includes the following services:
a separately managed account based on clients’ specific goals and investment objectives;
•
identification and analysis of the clients’ investment objectives;
•
4
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
continuous management of the client accounts;
•
•
on-going communication with clients about client accounts through calls, meetings, account statements and
performance updates;
brokerage services and commissions through Osaic Wealth’s affiliated registered broker- dealer; and
•
custody services for client accounts through NFS and Pershing.
•
There is no guarantee that the advisory services offered under the Program will result in the clients’ goals and
objectives being met. Nor is there any guarantee of profit or protection from loss. No assumption can be made that
an advisory fee arrangement or portfolio management service of any nature will provide a better return than other
investment vehicles.
Wrap fee programs are not suitable for all investment needs, and any decision to participate in a wrap fee program
should be based on your financial situation, investment objectives, tolerance for risk, and investment time horizon,
among other considerations. The benefits under a wrap fee program depend, in part, upon the size of the account
and the number of transactions likely to be generated.
For example, a wrap fee program is not always suitable for accounts with little trading activity, because the wrap
account fees could be costlier than brokerage trading fees for low volume trading accounts. To determine whether
a wrap fee program is suitable, clients should evaluate the Fee and any other costs of the Program with the amounts
that would be charged by other advisers, broker- dealers, and custodians, for services comparable to those provided
under the program considering their personal circumstances.
Clients should bear in mind that asset-based fee arrangements, when compared with the traditional commission
option, can result in lower costs during periods when trading activity is heavier, such as the year an account is
established. During periods when trading activity is lower, such arrangements result in higher annual costs. Some
clients favor the asset-based fee because it fixes their brokerage cost at a predetermined level; whereas other
clients find such an arrangement does not suit their needs because they anticipate their accounts will have low
turnover.
Depending on the amount of the wrap fee, the frequency (low or high) of transactions, and the nature and value of
the services that are provided under the Program, the Fee can exceed the aggregate cost of obtaining these services
separately. In such case, the fees for a wrap fee program result in higher costs than clients otherwise incur by paying
a management fee and negotiating separate arrangements for brokerage and trade execution, custodial services,
and performance reporting.
If clients choose to use margin, they should be aware that the market value of the account’s assets is not reduced
by the amount of the margin and will therefore increase the Fee. The increased Fee provides an incentive for the
Firm to recommend portfolio strategies or third-party advisers who use margin strategies. The use of margin is not
suitable for all investors, since it increases leverage in the account and therefore increases its risk.
Advisory Representatives can, in their sole discretion and as agreed from time to time with clients, provide financial
planning or financial consulting services to clients in connection with the Program at no additional cost. Advisory
Representatives may also require clients to enter into a separate agreement with an agreed upon fee for financial
planning or financial consulting services.
Fees & Compensation
The Wealth Management Platform – Unified Managed Account Program (“UMA”) provides you with the opportunity
to invest your assets across multiple investment strategies and asset classes by implementing an asset allocation
strategy. UMA is a Wrap Account program that offers these advisory services along with brokerage and custodial
services for a single, annual, asset-based advisory fee.
After you discuss your financial goals and objectives with your Advisory Representative, a recommendation to an
asset allocation model (“UMA Model”) will be made to you which will consist of:
1.
Investment strategies serviced and created by investment managers and/or your Advisory Representative that
generally consist of a selection of mutual funds, exchange traded products, equities, and or bonds;
5
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
2. Mutual funds and ETFs (“Funds”); or
3. A combination of the preceding bundled together in an investment asset allocation model.
Your Advisory Representative will recommend a UMA Model to you based on your responses to a Questionnaire
and discussion that your Advisory Representative and you have together regarding among other things, your
personal investment objectives and goals, time horizon, risk tolerance, account restrictions, needs, personal
circumstances and overall financial situation. In addition, you can place reasonable restrictions on investments held
within your UMA account. All recommendations in the UMA are made on a discretionary basis, which means your
Advisory Representative can act without your prior approval.
For further UMA details, please refer to The Wealth Management Platform – Unified Managed Account Wrap Fee
Program Brochure. We provide this brochure to you prior to or concurrent with your enrollment in UMA. Please
read it thoroughly before investing.
Finally, certain additional brokerage fees and custodian fees may apply to your advisory accounts where Osaic
Wealth is acting as the broker-dealer. In some instances, we apply a markup to these fees. Depending on the
custodial fee, it may be applied annually, per transaction, per month or per CUSIP. Please refer to the Client Fee
Disclosure - Pershing Clearing and Client Fee Disclosure - NFS Clearing located at osaic.com/disclosures to find additional
details regarding custodial fees.
In addition, any and all fees and costs clients incur in addition to the Fee, some of which benefit Osaic Wealth
broker-dealer and therefore represent not just additional costs, but also additional revenue to the Firm.
For specific information regarding the available products offered through the Program and the associated fees,
please see below.
Wrap Fee Program Fee Schedule for accounts custodied at NFS
Market Value
Sponsor Fee
Up to $250K
0.40%
Maximum Annual
Program Fee*
2.00%
$250K-500K
0.21%
2.00%
$500K-750K
0.17%
2.00%
$750K-1M
0.16%
2.00%
$1M-2M
0.14%
2.00%
$2M-5M
0.13%
2.00%
$5M-10M
0.09%
2.00%
Above $10M
0.08%
2.00%
*A minimum annual Program fee of $20 will apply to all accounts. Additionally, an annual $35 fee will be charged for
Registered Daily NAV REITs and alternative investments. These annual fees can cause the total Program fee to exceed
2.00% in certain circumstances.
6
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
The tables below describe the Program Fee Schedules custodied at Pershing, LLC.
Wrap Fee Program Fee Schedule for accounts custodied at Pershing, LLC
Market Value
Sponsor Fee
Up to $250K
0.26%
Maximum Annual
Program Fee*
2.00%
$250K-500K
0.22%
2.00%
$500K-750K
0.20%
2.00%
$750K-1M
0.19%
2.00%
$1M-2M
0.18%
2.00%
$2M-5M
0.18%
2.00%
$5M-10M
0.15%
2.00%
Above $10M
0.14%
2.00%
*A minimum annual Program fee of $20 will apply to all accounts. Additionally, an annual $35 fee will be charged for
Registered Daily NAV REITs and alternative investments. These annual fees can cause the total Program fee to exceed
2.00% in certain circumstances.
Surcharge Fees Imposed on Your Account
A surcharge of up to $10 is assessed to you for transactions in certain mutual funds. The surcharge applies to each
purchase and sale transaction for such mutual funds but excludes exchanges and periodic investments. Upon request,
your Advisory Representative will provide you with a list of mutual funds subject to the surcharge fee.
This list is subject to change from time to time. Please refer to the Client Fee Disclosure - Pershing Clearing and Client
Fee Disclosure - NFS Clearing located at osaic.com/disclosures to find additional details regarding custodial fees.
Strategist Managed Portfolios
Strategist Managed Portfolios (“SMP”) is a model driven program that allows the client to invest in a broad range of
mutual funds and/ or exchange traded funds. These Model Portfolios are managed by third-party investment advisors
(“Model Providers”) and the Firm elects the model portfolios available in the program. The Model Providers are
responsible for all investment selections, and they have sole discretion to add or remove securities from their portfolios.
Envestnet is granted investment discretion and will continuously monitor each client portfolio. When deemed
appropriate, Envestnet will make changes based on updates to the model portfolios. Envestnet will also periodically
rebalance the portfolios.
In the SMP program the client provides the Advisory Representative with information regarding investment objectives,
investment time horizon, risk tolerance and other relevant information.
The Advisory Representative then inputs this information into Envestnet’s proprietary investment allocation system,
which in turn provides the client and the Advisory Representative with investment options that have been determined to
be appropriate choices for the client based on the information provided by the client. After the initial investment
selections have been elected, the Advisory Representative meets with the client no less than annually to discuss any
changes in the client’s financial situation which have an affect the on the client’s investment selections. Clients have a
choice to select model portfolios offered by third-party Model Providers. For additional information about these Model
Providers, please see the respective Form ADV Part 2A.
7
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
Trading
You will approve the initial Model Provider and Model Portfolio presented to you. The Model Portfolios are provided by
Model Providers; therefore, you grant discretion to Model Provider to purchase and sell securities without your prior
consent according to the Model Portfolios stated investment objectives.
We utilize Envestnet, an independent investment adviser, to execute the transactions on your behalf. Envestnet will use
discretionary authority to execute securities transactions that are recommended by the Model Providers. Envestnet acts
to coordinate Model Provider trading activity including whether and how to implement trading instructions received from
the Model Providers.
Best Execution
In placing orders for purchase and sale of securities and directing brokerage to affect these transactions, Envestnet seeks
to obtain prompt execution of orders at the most favorable conditions. In doing so, Envestnet considers a number of
factors, including, without limitation, the overall direct net economic result to the Client, the financial strength, reputation
and stability of the broker, the efficiency with which the transaction is effected, the ability to effect the transaction at all,
the availability of the broker to stand ready to execute possibly difficult transactions in the future and other factors
involved in the receipt of brokerage services. In general, Envestnet routes trades directly to the Pershing or NFS (as
applicable).
“Step-out” Trades
Occasionally, in order to obtain best execution and minimize market impact, certain thinly traded securities, illiquid or
ETF trades, for example, can be ‘stepped-out’ in order to gain best execution and minimize market impact. In some
instances, stepped-out trades are executed by the other firm without any additional commission or markup or markdown,
but in other instances, the executing firm may impose a commission or a markup or markdown on the trade. If trades are
placed with a firm that imposes a commission or equivalent fee on the trade, including a commission that may be
imbedded in the price of the security, the client will incur trading costs in addition to the fee you pay your Advisory
Representative. It is important to know that you may pay a commission in addition to your advisory fee for those stepped-
out trades. Envestnet has procedures in place to monitor these transactions. Envestnet’s Best Execution Committee
meets quarterly to review the results of the documented monitoring conducted during the quarter. We periodically
review Envestnet’s procedures and results and may rely on a third-party review as well.
Transaction Aggregation
Envestnet may aggregate transactions in the same security on behalf of more than one client to facilitate best execution
and to possibly reduce the price per share and other costs. Envestnet effects the aggregated transactions in a manner
designed to ensure that no participating client is favored over any other client. With respect to the aggregated order, you
will participate at the average share price for all Envestnet transactions in that security on that business day. When
possible, securities bought or sold in an aggregated transaction are allocated pro-rata to the participating Client’s
accounts in proportion to the size of the orders placed for each account. When Envestnet is unable to fully execute an
aggregated order, Envestnet will allocate such transactions on a pro-rata basis or in a manner Envestnet determines in
good faith to be a fair and equitable allocation.
Program Fees
Client accounts are structured as a SMP wrap fee Program Account as represented in the Statement of Investment
Selection “SIS.” A SMP wrap fee Program Account is charged an Advisory fee as a percentage of assets under
management; that for one fee includes the management fee, administrative costs of the Adviser and transaction fees for
the securities purchased and sold in the SMP wrap fee Program Account. Investment Manager Fees are waived for an
Investment Manager that is an affiliate of the Firm.
8
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
Please see below for the SMP Program Fee Schedule
Market Value
Maximum Annual Program Fee*
Up to $250K
2.00%
$250K-500K
2.00%
$500K-1M
2.00%
$1M-2M
2.00%
$2M-5M
2.00%
Above $5M
2.00%
* SMP accounts are subject to a $20 minimum annual Program fee and can cause the total Program fee to exceed 2.00%
in certain circumstances.
John Hancock Portfolio Solutions
The Firm manages the John Hancock Portfolio Solutions (“JHPS”) program which offer individual clients actively managed
portfolios comprised of mutual funds and/or ETFs. The Firm is granted investment discretion and will continuously
monitor each client’s portfolio. John Hancock Investment Management, LLC (“JHIM”) provides the Firm with
recommended model portfolios based on specific investment strategies and, from time-to-time, recommends changes
to asset class allocations and
specific mutual fund and ETF selections. JHIM provides research related to the mutual funds and ETFs the Firm includes
in the model portfolios. We will provide monitoring and review of model portfolios provided. We have the discretion to
modify and/or rebalance the portfolios without your consent consistent with your investment objectives and risk
tolerance.
After the investor profile questionnaire is completed, The Firm’s Advisory Representative analyzes the client information
and recommends an appropriate strategy based on the client’s needs and objectives, investment time horizon, risk
tolerance and other pertinent factors. The Firm will then propose an overall strategy that includes asset allocation and
investment style recommendations.
Trading
You will approve the initial Model Portfolio presented to you. The Model Portfolios are provided by JHPS; therefore, you
grant discretion to JHPS to purchase and sell securities without your prior consent according to the Model Portfolios
stated investment objectives.
We utilize Envestnet, an independent investment adviser, to execute the transactions on your behalf. Envestnet will use
discretionary authority to execute securities transactions that are recommended by JHPS. Envestnet acts to coordinate
JHPS trading activity including whether and how to implement trading instructions received from JHPS.
Program Fees
The client account is structured as a wrap fee Program Account as represented in the SIS. A JHPS wrap fee Program
Account is charged an Advisory fee as a percentage of assets under management that for one fee includes the
management fee, administrative costs of the Adviser and transaction fees for the securities purchased and sold in the
JHPS wrap fee Program Account. Investment Manager Fees are waived for an Investment Manager that is an affiliate of
the Firm.
9
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
Please see below for the JHPS Program Fee Schedule
Market Value
Maximum Annual Program Fee*
Up to $250K
2.00%
$250K-500K
2.00%
$500K-1M
2.00%
$1M-2M
2.00%
$2M-5M
2.00%
Above $5M
2.00%
* JHPS accounts are subject to a $20 minimum annual JHPS Program fee that can cause the total JHPS Program fee to
exceed 2.00% in certain circumstances.
Separate Accounts
Separate Accounts (“SA”) is a program that allows the client, through the Advisory Representative, to select style specific
separate account managers pre-screened by Envestnet from a universe of managers who specialize in a particular
investment style. The SA managers choose the general securities, bonds or exchange traded funds (ETFs) for the portfolio
and have trading discretion.
In the SA program the client provides the Advisory Representative with information regarding investment objectives,
investment time horizon, risk tolerance and other relevant information. The Advisory Representative then inputs this
information into Envestnet’s proprietary investment allocation system, which in turn provides the client and the Advisory
Representative with investment options that have been determined to be appropriate choices for the client based on the
information provided by the client. After the initial investment selections have been elected, the Advisory Representative
meets with the client no less than annually to discuss any changes in the client’s financial situation which have an effect
on the client’s investment selections.
Trading
You grant discretion to us. your Advisory Representative, the SA Manager, and/or Envestnet to purchase and sell securities
without your prior consent according to your stated investment objectives.
We utilize Envestnet, an independent investment adviser, to execute the transactions on your behalf. Envestnet will use
discretionary authority to execute securities transactions that are recommended by the SA Managers. Envestnet acts to
coordinate SA program trading activity including whether and how to implement trading instructions received from SA
Managers and/or your Advisory Representative.
Best Execution
In placing orders for purchase and sale of securities and directing brokerage to affect these transactions, Envestnet seeks
to obtain prompt execution of orders at the most favorable conditions.
In doing so, Envestnet considers a number of factors, including, without limitation, the overall direct net economic result
to the Client, the financial strength, reputation and stability of the broker, the efficiency with which the transaction is
effected, the ability to effect the transaction at all, the availability of the broker to stand ready to execute possibly difficult
transactions in the future and other factors involved in the receipt of brokerage services. In general, Envestnet routes
trades directly to the Pershing or NFS (as applicable).
10
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
“Step-out” Trades
Occasionally, in order to obtain best execution and minimize market impact, certain thinly traded securities, illiquid or
ETF trades, for example, can be ‘stepped-out’ in order to gain best execution and minimize market impact. In some
instances, stepped-out trades are executed by the other firm without any additional commission or markup or markdown,
but in other instances, the executing firm may impose a commission or a markup or markdown on the trade. If trades are
placed with a firm that imposes a commission or equivalent fee on the trade, including a commission that may be
imbedded in the price of the security, the client will incur trading costs in addition to the fee you pay your Advisory
Representative. It is important to know that you may pay a commission in addition to your advisory fee for those stepped-
out trades. Envestnet has procedures in place to monitor these transactions. Envestnet’s Best Execution Committee
meets quarterly to review the results of the documented monitoring conducted during the quarter. We periodically
review Envestnet’s procedures and results and may rely on a third-party review as well.
Transaction Aggregation
Envestnet may aggregate transactions in the same security on behalf of more than one client to facilitate best execution
and to possibly reduce the price per share and other costs. Envestnet effects the aggregated transactions in a manner
designed to ensure that no participating client is favored over any other client. With respect to the aggregated order, you
will participate at the average share price for all Envestnet transactions in that security on that business day. When
possible, securities bought or sold
in an aggregated transaction are allocated pro-rata to the participating Client’s accounts in proportion to the size of the
orders placed for each account. When Envestnet is unable to fully execute an aggregated order, Envestnet will allocate
such transactions on a pro-rata basis or in a manner Envestnet determines in good faith to be a fair and equitable
allocation.
Program Fees
The client account is structured as a SA wrap fee Program Account as represented in the SIS. A JHPS wrap fee Program
Account is charged an Advisory fee as a percentage of assets under management that for one fee includes the
management fee, administrative costs of the Adviser and transaction fees for the securities purchased and sold in the SA
wrap fee Program Account. Investment Manager Fees are waived for an Investment Manager that is an affiliate of the
Firm.
Please see below for the SA Program Fee Schedule
Market Value
Maximum Annual Program Fee*
Up to $250K
3.00%
$250K-500K
3.00%
$500K-1M
3.00%
$1M-2M
3.00%
$2M-5M
3.00%
Above $5M
3.00%
*SAs are subject to a $350 minimum annual SA Program fee and minimum annual custodial fees depending on the type
of manager(s) selected that can cause the total SA Program fee to exceed 3.00%.
Unified Managed Account
In the Unified Managed Account (“UMA”) program, the client provides the Advisory Representative with information
regarding investment objectives, financial needs, investment time horizon, risk tolerance and other relevant information.
The Advisory Representative inputs this information into the Envestnet Asset Management platform to build a model
11
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
portfolio for the client, recommend an appropriate asset allocation among the investment options in the UMA program
and select appropriate investment vehicles for the client’s account coinciding with the client’s risk tolerance parameters.
Investment options in the UMA include investment strategies created and managed by:
Third-Party Investment Managers such as SA Managers, Model Providers, JHPS,
•
your Advisory Representative (from a selection of mutual funds, exchange traded products, or equities),
•
fund managers.
•
Unlike other programs, all Investment Manager investments, Funds and ETFs will be held in a single custodial account.
Overlay management is provided to coordinate the trading activities of UMA Investment Managers, rebalancing, and
optional tax management and socially responsible services.
Clients participating in the UMA program will receive investment management services, underlying investment securities
recommendations and rebalancing services. Under the UMA program, Envestnet provides portfolio overlay management
services, including coordinating all trading and keeping client portfolios in balance with clients’ respective asset allocation
strategies. Envestnet maintains trading authority and will provide periodic rebalancing services so that the allocation of
assets remains, within certain parameters, consistent, with the selected Strategy. The UMA program is offered on a
discretionary basis and the Advisory Representative provides rebalancing of the investments, purchasing investments
and/or selling investments from a client’s account, but will instruct Envestnet to make account changes based on such
recommendations.
Reasonable restrictions can be imposed by the client on management of the accounts including the designation of
particular securities or types of securities that should not be purchased for the account or that should not be held in the
account.
Advisory Representatives consult with clients periodically, but no less than annually to determine whether any
information needs to be updated and whether any changes need to be made to the client’s stated risk tolerance
parameters. The client account is structured as a wrap fee Program Account as represented in the SIS. A UMA wrap fee
Program Account is charged an Advisory fee as a percentage
of assets under management that for one fee includes the management fee, administrative costs of the Adviser and
transaction fees for the securities purchased and sold in the wrap fee Program Account.
Trading
You grant discretion to us, your Advisory Representative, Third-Party Investment Managers, and/ or Envestnet to
purchase and sell securities without your prior consent according to your stated investment objectives.
We utilize Envestnet, an independent investment adviser, to execute the transactions on your behalf. Envestnet will use
discretionary authority to execute securities transactions that are recommended by the Third-Party Investment
Managers, and/or your Advisory Representative. Envestnet acts to coordinate UMA program trading activity including
whether and how to implement trading instructions received from Third-Party Investment Managers and/or your
Advisory Representative.
Your Advisory Representative does not exercise investment discretion over your assets allocated to Investment Managers.
Best Execution
In placing orders for purchase and sale of securities and directing brokerage to affect these transactions, Envestnet seeks
to obtain prompt execution of orders at the most favorable conditions. In doing so, Envestnet considers a number of
factors, including, without limitation, the overall direct net economic result to the Client, the financial strength, reputation
and stability of the broker, the efficiency with which the transaction is effected, the ability to effect the transaction at all,
the availability of the broker to stand ready to execute possibly difficult transactions in the future and other factors
involved in the receipt of brokerage services. In general, Envestnet routes trades directly to the Pershing or NFS (as
applicable).
12
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
“Step-out” Trades
Occasionally, in order to obtain best execution and minimize market impact, certain thinly traded securities, illiquid or
ETF trades, for example, can be ‘stepped-out’ in order to gain best execution and minimize market impact. In some
instances, stepped-out trades are executed by the other firm without any additional commission or markup or markdown,
but in other instances, the executing firm may impose a commission or a markup or markdown on the trade. If trades are
placed with a firm that imposes a commission or equivalent fee on the trade, including a commission that may be
imbedded in the price of the security, the client will incur trading costs in addition to the fee you pay your Advisory
Representative. It is important to know that you may pay a commission in addition to your advisory fee for those stepped-
out trades. Envestnet has procedures in place to monitor these transactions. Envestnet’s Best Execution Committee
meets quarterly to review the results of the documented monitoring conducted during the quarter. We periodically
review Envestnet’s procedures and results and may rely on a third-party review as well.
Transaction Aggregation
Envestnet may aggregate transactions in the same security on behalf of more than one client to facilitate best execution
and to possibly reduce the price per share and other costs. Envestnet effects the aggregated transactions in a manner
designed to ensure that no participating client is favored over any other client. With respect to the aggregated order, you
will participate at the average share price for all Envestnet transactions in that security on that business day. When
possible, securities bought or sold in an aggregated transaction are allocated pro-rata to the participating Client’s
accounts in proportion to the size of the orders placed for each account. When Envestnet is unable to fully execute an
aggregated order, Envestnet will allocate such transactions on a pro-rata basis or in a manner Envestnet determines in
good faith to be a fair and equitable allocation.
Program Fees
UMA Program Accounts custodied at Pershing and NFS are allotted one hundred and fifteen (115) purchases or sales in
any twelve (12) month period. Should there be purchases or sales in excess of the allotment then those purchases and
sales will be charged a transaction fee as defined below. At the end of each twelve-month period, the allotment resets to
115. These are subject to a $250 minimum annual program fee and minimum annual custodial fees depending on the
type of manager(s) selected that can cause the total program fee to exceed 3.00%. Investment Manager Fees are waived
for an Investment Manager that is an affiliate of the Firm.
Security Type
Transaction Fee*
Stocks, ETFs and Closed End Funds
Market Orders
$7.00 per transaction
Mutual Funds
No transaction fee (NTF) funds
$0.00
PIP/SWP
$0.00
No load and load waived buys and sells
$0.00 to $7.00 per transaction
Other
Fixed Income
$0.00 to $7.00 per transaction
Unit Investment Trust Redemption Fee (liquidations only)
$0.00 to $7.00 per transaction
Alternative Investments Redemption
$0.00 to $7.00 per transaction
Fee (liquidations only)
$50.00 per transaction
Options – Closing Trades Only (liquidations only)
$0.00 to $7.00 per transaction
*Transaction fees are subject to change
13
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
Please see below for the UMA Program Fee Schedule
Market Value
Maximum Annual Program Fee
Up to $250K
3.00%
$250K-500K
3.00%
$500K-1M
3.00%
$1M-2M
3.00%
$2M-5M
3.00%
Above $5M
3.00%
In addition to the fees discussed above, the below confirmation and prospectus paper fees also apply to your account.
Confirmation Fee
$1.50
Prospectus Fee
$1.50
The Confirmation Fee can be avoided by signing up for electronic delivery. Your Advisory Representative can also choose
to pay this fee on your behalf. Refer to the trade confirmation to determine if this fee applies to you.
The Prospectus Fee can be avoided by signing up for electronic delivery. The Prospectus Fee is paid by your Advisory
Representative. In cases where your Advisory Representative pays the above fees, there is an incentive for your Advisory
Representative to trade less often or to recommend different products to avoid the fee. Our policy and procedures are
designed to ensure our Related Persons make recommendations to you that are in your best interest. Furthermore, to
mitigate this conflict, you can sign up for electronic delivery.
Sweep Program
When your Program Account is maintained at one of our clearing firms, Pershing or NFS, your free credit balance will be
automatically deposited or “swept” to a deposit account at one or more banks whose deposits are insured up to
applicable limits by the Federal Deposit Insurance Corporation (“FDIC”) (the “Sweep Program”). Under the Sweep
Program, Osaic Wealth maintains two FDIC-insured deposit programs, the Bank Deposit Sweep Program (“BDSP”) and the
Insured Cash Account Program (“ICAP”), that create financial benefits for Osaic Wealth as described below. For certain
Program Account types, free credit balances are swept to a money market mutual fund product (the “Money Market
Mutual Fund Program”), which does not create financial benefits for Osaic Wealth. Please see the Sweep Program Terms
and Conditions document, available from your Advisory Representative or from the website listed below, for full details
about the Sweep Program.
As set forth in the terms of your Customer Agreement with Osaic Wealth, you may remove your Program Account from
participating in the Sweep Program by notifying your Advisory Representative. If you remove your Program Account from
the Sweep Program, cash balances will be held by the clearing firm as a free credit balance. In addition, there are always
alternatives for the short-term investment of cash balances, including non-sweep money market mutual funds, treasury
bills, and brokered certificates of deposit, that offer higher returns than the sweep options made available to you.
FDIC Insured Deposit Program (BDSP & ICAP)
Eligible account types: all accounts except ERISA Title 1 accounts, 403(b)(7), & Keogh plans
Free credit balances swept to a deposit account will earn interest that is compounded daily and credited to your Program
Account monthly. Interest begins to accrue on the date of deposit with the banks participating in the program (“Program
Banks”), through the business day preceding the date of withdrawal from the deposit account. The daily rate is 1/365 (or
1/366 in a leap year) of the posted interest rate.
14
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
Bank Deposit Sweep Program - BDSP
Osaic Wealth has established deposit levels or tiers which ordinarily pay different rates of interest depending on deposit
balances. Generally, Program Accounts with higher deposit balances receive higher rates of interest than accounts with
lower balances. The interest rate payable to you is determined by us and is based on the amounts paid by the Program
Banks to obtain the deposits. The amount we retain, less a fee paid to our clearing agent and the third-party administrator,
will not exceed 600 basis points (6.00%) per year (the “Maximum Program Fee”) on the average daily balances held in the
BDSP. Interest paid on the deposit accounts will always be lower than the rate of return on (i) other investment products
that are not FDIC insured, such as money market mutual funds and (ii) on bank deposits offered outside of the BDSP.
Your Advisory Representative does not receive any portion of the fees paid by the Program Banks.
The income we earn from Program Banks based on your balances in BDSP will in almost all circumstances be substantially
greater than the amount of interest you earn from the same balances. As such, we receive a substantially higher
percentage of the interest generated by deposit balances in the BDSP than the interest credited to your accounts. When
evaluating whether to utilize the Sweep Program and the extent to which our fee exceeds the interest rate you receive,
you should assume that we are receiving the Maximum Program Fee described above.
Insured Cash Account Program - ICAP
Osaic Wealth will receive a monthly per-account fee for services it provides in connection with maintaining and
administering the Sweep Program for IRAs held in an advisory/ fee-based account (the “Sweep Account Fee”). The Sweep
Account Fee that each Osaic Inc. affiliated broker-dealer can earn from Program Accounts participating in ICAP is subject
to a maximum monthly per account fee that is between $30.25 and $34.50. Please refer to the applicable Sweep Program
Terms and Conditions document, which you can obtain from your Advisory Representative or from the website listed
below; refer to “Disclosures,” then to the FDIC Insured Deposit Program used in your account (ICAP), for further details
about the maximum monthly per account fee.
The Sweep Account Fee does not depend on or vary with (and is not affected by) the actual amounts held in any particular
account or your Program Account. Thus, our compensation for Program Accounts that participate in ICAP is composed
solely of the Sweep Account Fee. The fee received may differ among each Program Bank. You will have no rights to the
amounts paid by the Program Banks, except for interest actually credited to your account. The Sweep Account Fee will
reduce the interest you are paid on the amount of assets in your Program Account.
The Sweep Account Fee will generally be paid by the Program Banks on your Program Account’s behalf; however, the Fee
or any portion thereof can be deducted directly from your Program Account if, for example, the amounts paid by the
Program Banks are insufficient to cover the Sweep Account Fee. In the event that we debit all or a portion of the monthly
account fee from your account, each such amount will be reflected on your account statement. The amount of fees
received by Osaic Wealth, our clearing agent, and any other service provider reduces the interest you receive on your
deposit account(s).
Your Advisory Representative does not receive any portion of the fees paid by the Program Banks.
Money Market Mutual Funds - Pershing
Free credit balances in the following brokerage account types will be automatically swept into the Federated Hermes
Government Reserves Fund (GRFXX), which is managed by Federated Hermes Investors (“Federated Hermes”):
•
All ERISA Title 1 account types, including Profit Sharing Plans, 401(k), Roth 401(k), Simple 401(k), Individual 401(k),
qualified deferred compensation plans, defined benefit plans, target benefit plans, and money purchase pension
plans
403(b)(7) accounts
•
Keogh plans
•
The Federated Hermes Government Reserves Fund is a money market mutual fund and seeks to maintain a stable share
price of $1.00. The Fund invests primarily in a portfolio of short-term U.S. Treasury and government securities. These
investments include repurchase agreements collateralized fully by U.S. Treasury and government securities. The Fund
15
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
uses repurchase agreements to provide a liquidity base for the portfolio and a potential yield advantage relative to other
short-term securities. Although the Fund seeks to preserve the value of your investment at $1.00 per share, it cannot
guarantee it will do so. An investment in the fund is not insured or guaranteed by the Federal Deposit Insurance
Corporation or any other government agency.
Osaic Wealth does not receive any compensation from the Federated Hermes Government Reserves Fund.
For additional information about the Sweep Program for accounts custodied at Pershing, please visit our website located
at osaic.com/disclosures.
Money Market Mutual Funds - NFS
Free credit balances in the following Program Account types custodied at NFS will be automatically swept into the Fidelity
Government Cash Reserves Fund (FDRXX), which is managed by Fidelity Investments:
•
All ERISA Title 1 account types, including Profit Sharing Plans, 401(k), Roth 401(k), Simple 401(k), Individual 401(k),
qualified deferred compensation plans, defined benefit plans, target benefit plans, and money purchase pension
plans
403(b)(7) accounts
•
Keogh plans
•
The Fidelity Government Cash Reserves Fund is a money market mutual fund that seeks to maintain a stable share price
of $1.00 per share. The Fidelity Fund invests at least 99.5% of their total assets in cash, U.S. Government securities and/or
repurchase agreements that are collateralized fully (i.e., collateralized by cash or government securities). The Fidelity
Fund invests in U.S. Government securities issued by entities that are chartered or sponsored by Congress but whose
securities are neither issued nor guaranteed by the U.S. Treasury. Although the Fidelity Fund seeks to preserve the value
of your investment at $1.00 per share, it cannot guarantee to do so. An investment in the fund is not insured or
guaranteed by the Federal Deposit Insurance Corporation or any other government agency.
Osaic Wealth does not receive any compensation from Fidelity Funds.
For additional information about the Sweep Program for accounts custodied at NFS, please visit our website located at
osaic.com/disclosures.
Material Conflicts of Interest
Because the Sweep Program generates significant payments from third parties (i.e., the Program Banks that participate
in BDSP and/or ICAP) to Osaic Wealth, a conflict of interest exists. A conflict of interest also arises because we earn more
compensation from cash balances being swept to or maintained in the Sweep Program than if you purchase other
investment funds or securities. The more client deposits
held in BDSP, and the longer such deposits are held, the greater the compensation we, our clearing firms, and the third-
party administrator receive. By investing through an advisory account, the compensation we receive from the BDSP or
ICAP, as applicable, is in addition to the advisory fees that you pay. This means that we earn two layers of fees on the
same cash balances in client advisory accounts with us. If we did not receive such compensation, which is in addition to
advisory, transaction, servicing and other fees and compensation related to Program Accounts, such client fees (including
advisory fees) would generally be higher.
In addition, a conflict of interest arises as a result of the financial incentive for the Firm to recommend and offer a Sweep
Program over which they have control of certain functions. Osaic Wealth has the ability to establish and change interest
rates paid on Sweep Program balances, to select or change Program Banks that participate in the BDSP and ICAP, and to
determine the tier levels (if applicable) at which interest rates are paid, all of which generates additional compensation
for Osaic Wealth.
The Advisory Representative who makes investment recommendations for your Program Account does not receive any
compensation from these payments or based on the selection of the sweep vehicle. The Firm maintains policies and
procedures to ensure recommendations made to you are in your best interest. For more information about this service
16
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
and benefits that we receive in connection with such deposits, please refer to the Sweep Program terms and conditions
document, which you can request from your Advisory Representative.
Given the conflicts discussed above, each client should consider the importance of BDSP and ICAP to us when evaluating
our total fees and compensation and deciding whether to utilize the BDSP and/or ICAP.
Item 5 - Account Requirements and Types of Clients
The Firm offers investment advisory services to individuals, trusts, estates, non-profit organizations, corporations,
partnerships and other types of business entities.
This Program is closed to new clients. There is no minimum account requirement for the Signator Managed Account
Platform.
Item 6 - Portfolio Manager Selection and Evaluation
Envestnet is responsible for the evaluation and ongoing monitoring of the investment firms available in the Strategist
Managed Portfolios program, Separate Accounts and the Unified Managed Account. Please see Envestnet’s ADV Part 2A
for more information.
The Firm’s Advisory Representative acts as portfolio manager for AMP program, and clients rely significantly on the skills
and experience of the Advisory Representative and the Advisory Representative’s ability to select investments within the
risk tolerance and asset allocation and concentration parameters established for the UMA.
The Firm selects independent Model Providers and all independent Model Providers are subject to a due diligence process
which includes annual reviews designed to determine if a manager meets a sufficient level of quality and stability through
their policies and practices. Independent
Model Providers are evaluated using a variety of data and information from one or more resources, which may include:
public or private independent databases, responses to periodic due diligence questionnaires, quantitative and qualitative
information, research, performance reports, and other pertinent information concerning the manager. Your Advisory
Representative is responsible for determining whether any particular Model Provider or investment strategy is
appropriate based on your stated risk tolerance and investment objectives.
The Firm does not review or verify the accuracy of any marketing or other materials, including investment performance
history, that Model Provider may provide to you or your Advisory Representative. As a result, performance information
and presentations may not be uniform or consistent between Model Providers.
An explanation of how your Advisory Representative selects a Model Provider can be found in Item 4 of this brochure. If
your situation changes and your Advisor Representative determines that a particular selected Model Provider’s asset
allocation model is not consistent with your current goals and investment objectives, your Advisory Representative will
contact you to discuss different investment options.
On an ongoing basis, Envestnet reviews Model Providers participating in the Program to determine whether they continue
to meet Envestnet’s guidelines and evaluation criteria. If Envestnet detects relevant information at any time (including
qualification and/or performance concerns), we will generally follow Envestnet’s recommendation as to whether to
continue to include the Model Provider as an investment suitable for the Program or add a Model Provider to the
Program. We receive research, performance information and other information from Envestnet about Model Providers
but do not independently verify or guarantee the accuracy or validity of this information received from Envestnet, or any
other source. Further, there is a chance the performance information that we receive from Envestnet may not be
calculated on a uniform or consistent basis.
For approved Model Providers, Envestnet employs a multi-phase approach in its evaluation (“Due Diligence”). As part of
the Due Diligence, certain types of information are analyzed, including historical performance, investment philosophy,
investment style, historical volatility and correlation across asset classes. Also reviewed are the Model Provider’s Form
17
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
ADV Part 2 disclosure events, as well as portfolio holdings reports that help demonstrate the Model Provider’s securities
selection process and the prospectuses of the Funds.
Neither we nor your Advisory Representative make any representations regarding the future performance of any
investment strategy of, or security recommended by, any Model Provider participating in the Program. As always, past
performance is not a guarantee of future results.
Clients should refer to the disclosure documents (Form ADV Part 2 or other disclosure document) of Envestnet and/or
the selected Model Providers for additional information regarding the security analysis methods, sources of information,
investment strategies, and due diligence used by those parties in the management of Program accounts.
Performance Based Fees and Side-by-Side Management
Neither the Firm nor its Advisory Representatives accept performance-based fees (i.e. fees based on a share of capital
gains or capital appreciation of the assets of a client). Nor does the Firm engage in side-by-side management (i.e.
managing accounts that are charged performance-based fees while at the same time managing accounts that are not
charged performance-based fees). As a result, this disclosure item is not applicable.
Voting Client Securities
Neither the Firm nor its Advisory Representatives vote client proxies. Clients will vote proxies associated with the AMP
Program. Each third-party asset manager has its own proxy voting policies.
Item 7 - Client Information Provided to Portfolio
Managers
The model providers for Strategist Managed Portfolios are provided the necessary information to construct a portfolio
appropriate for the client’s profiled risk range.
The portfolio managers have access to all information provided by clients to the Firm. Through personal discussions with
clients and account reviews, goals and objectives, based on a client’s circumstances, are established. During the Firm’s
data-gathering process, the Firm determines the client’s individual objectives, time horizons, risk tolerance, and liquidity
needs. The Firm then develops a client’s personal investment guidelines and creates and manages a portfolio based on
that policy. Information obtained from the client is used to identify risk tolerance, objectives, and appropriate asset
allocation.
Item 8 - Client Contact with Portfolio Managers
Clients cannot speak directly to portfolio managers, except those that are Advisory Representatives of the Firm. Any
questions or issues regarding the client’s account or the investments selected for the client’s portfolio should be directed
to the Firm or the Firm’s Advisory Representative. The Firm will work with Envestnet to resolve issues related to Envestnet
portfolio managers.
Item 9 - Additional Information
Disciplinary Information
Disclosure of Disciplinary Action Related to Off-Channel Business Communications:
On August 14, 2024, Osaic Wealth, Inc (“Osaic”) was the subject of an Order Instituting Administrative and Cease-and-
Desist Proceedings (“Order”) by the U.S. Securities and Exchange Commission (the “SEC”). From at least August 2019
through the date of the Order, the SEC found that Osaic employees used personal devices to send and receive text
messages relating to investment advisory business that were not maintained or preserved. The SEC determined that Osaic
violated Section 204 of the Investment Advisers Act of 1940 and Rule 204-2(a)(7) thereunder.
18
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
The SEC imposed sanctions by censuring Osaic and ordering that it cease and desist from committing or causing future
violations of Section 204 of the Advisers Act and Rule 204-2 thereunder, requiring it to comply with certain undertakings
including retaining a compliance consultant, and pay an $18,000,000 civil penalty (payable jointly and severally with its
affiliate Osaic Services, Inc.).
Disclosure of Disciplinary Action Related to the Custody of Client Assets:
On September 28, 2023, Osaic Wealth, Inc (“Osaic”) was the subject of an Order Instituting Administrative and Cease-
and-Desist Proceedings (“Order”) by the U.S. Securities and Exchange Commission (the “SEC”). The SEC Order arose out
of the failure of Osaic to obtain verification by an independent public accountant of client funds and securities of which
it had custody from June 2017 to December 2022. Osaic used a form agreement (“Agreement”) to govern certain aspects
of its relationship with its clients and a particular clearing agent (“Clearing Agent”). This Agreement included a margin
account agreement that contained language, required by the Clearing Agent, that permitted the Clearing Agent to accept,
without inquiry or investigation, any instructions given by Osaic concerning these client’ accounts. As a consequence of
Osaic having this authority, the SEC deemed Osaic had custody of client assets. Accordingly, because Osaic failed to obtain
verification by annual examination of client funds and securities in the affected accounts, the SEC determined that Osaic
violated Sections 206(4) of the Advisers Act and Rule 206(4)-2 thereunder, commonly referred to as the “Custody Rule”.
Without admitting or denying the SEC’s findings, Osaic agreed to cease and desist from committing or causing future
violations of the Custody Rule. Osaic was censured and agreed to pay a $100,000 civil penalty.
Beginning in calendar year 2023, Osaic engaged an outside independent auditor to perform an annual surprise custody
audit as called for by Advisers Act Rule 206(4)-2.
Disclosure of Disciplinary Action Related to the Sales of Complex Exchange-Traded Products:
On November 13, 2020, the Firm entered into a settlement agreement with the Securities and Exchange Commission
(“SEC”) and an administrative order has been issued by the SEC. The SEC found the Firm violated Section 206 and Rule
206(4)-7 of the Investment Advisers Act of 1940. More specifically, during the period from January 2016 through April
2020, the Firm, did not adopt and implement policies and procedures reasonably designed to prevent unsuitable
investments by its Advisory Representatives in volatility-linked exchange traded products (“ETPs”).
Without admitting or denying the SEC’s findings, the Firm agreed to cease and desist from committing or causing any
violations and any future violations of Section 206(4) of the Advisers Act and Advisers Act Rule 206(4)-7. The Firm also
agreed to pay disgorgement, prejudgment interest, and a civil monetary penalty totaling $502,400.29.
The SEC noted that the Firm cooperated with the SEC and promptly took remedial steps relating to volatility-linked ETPs
and imposed restrictions on holding them in all client accounts maintained at the Firm.
Disclosure of Disciplinary Action Relevant to Mutual Fund Share Classes and Wrap Accounts:
On March 14, 2016, the Firm, SagePoint Financial, Inc. and FSC Securities Corporation (collectively, the “Osaic, Inc. Firms”)
consented to the entry of an Order Instituting Administrative and Cease-and- Desist Proceedings (“Order”) by the U.S.
Securities and Exchange Commission (the “SEC”). The Order focuses on two specific issues related to our fee-based
advisory business conducted between 2012 and 2014 at the Osaic, Inc. Firms. In summary, the SEC found that the Osaic,
Inc. Firms placed certain advisory clients invested in the Advisor Managed Portfolios program in mutual fund share classes
with higher expense costs when lower expense cost share classes of those funds were available. The SEC found that this
financial incentive, to place non-qualified advisory clients in higher fee share classes, presented a conflict of interest that
should have been disclosed to clients. The SEC also concluded that the Osaic, Inc. Firms failed to adopt written compliance
policies or procedures governing mutual fund share class selection. In addition, the SEC found the Osaic, Inc. Firms failed
to timely monitor certain wrap advisory accounts for inactivity pursuant to Osaic, Inc. Firms’ written compliance policies
and procedures.
Without admitting or denying the SEC’s findings, the Osaic, Inc. Firms agreed to cease and desist from committing or
causing any violations and any future violations of Sections 206(2), 206(4) and 207 of the Investment Advisers Act and
Rule 206(4)-7 thereunder. The Osaic Inc. Firms agreed to jointly pay disgorgement of $1,956,460 and prejudgment
19
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
interest of $93,399, a civil penalty of $7,500,000 and to retain a qualified independent compliance consultant. To address
the issues presented in the Order, the Firm has implemented new policies and procedures relating to mutual fund share
class selection designed to expand the number of lower cost share classes available to advisory clients, provide training
on share class selection, and require the rebating of 12b-1 fees to all advisory clients going forward. The Firm has also
enhanced its Form ADV disclosures. In addition, the Firm has enhanced its policies and procedures for the review and on-
going use of wrap accounts managed by the Firm’s Investment Advisory Representatives.
Other Financial Activity and Affiliations
The Signator Managed Account Platform includes certain affiliated mutual funds. There is no explicit incentive for the
Firm’s Advisory Representative to recommend an affiliated mutual fund over other mutual funds.
Advisors that offer the Program may be “Related Persons” to us. You should see the ADV Part 2A of your Advisor that will
be provided to you for information regarding any of their other financial industry affiliations and for any associated
conflicts of interest.
Code of Ethics
We have adopted a Code of Ethics (the “Code”) to address securities-related conduct. The Code focuses primarily on
fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest. The Code includes our
policies and procedures developed to protect your interests in relation to the following topics:
The duty at all times to place your interests first;
•
•
The requirement that all personal securities transactions be conducted in such a manner as to be consistent with
the Code and to avoid any actual or potential conflict of interest or any abuse of an employee’s position of trust
and responsibility;
The principle that investment adviser personnel should not take inappropriate advantage of their positions;
•
•
The fiduciary principle that information concerning the identity of your security holdings and financial
circumstances are confidential; and
The principle that independence in the investment decision-making process is paramount.
•
This response is only intended to provide you with a summary description of our Code of Ethics. Please refer to
our Code of Ethics in its entirety located at osaic.com/disclosures.
It is the Firm’s policy to prohibit agency cross transactions where representatives act as brokers for both buying and selling
a single security between two different clients and are compensated through an agency commission or principal mark-
up for the trades. If we adopt a different policy in this area or exceptions are made, we will observe all rules and
regulations in accordance with the disclosure and consent requirements of Section 206(3) of the Advisers Act.
Additionally, we are aware that such transactions only occur if we ensure that we meet our duty of best execution for the
client.
Related Person(s) to us may have an interest or position in securities which may be recommended to you.
Our Advisory Representatives, from time to time, can recommend investment products to you, including mutual funds,
variable and fixed annuities, and other insurance products, sponsored, distributed, or managed by our Related Persons.
Advisory Representatives may also recommend that you select portfolio managers that are Related Persons. These
Related Persons may, from time to time, place brokerage transactions with Osaic Wealth and refer you to us. Such
recommendations and arrangements might create a conflict of interest because they may result in an increase in
compensation for us, our Advisory Representatives and our Related Persons.
While our security sales are reviewed for suitability by an appointed supervisor, you should be aware of the incentives
we have to sell certain securities products and are encouraged to ask us about any conflict presented.
We may recommend securities to you or buy or sell securities for your account at or about the same time we may buy or
sell the same securities in our own account. As such, there may be instances where our interests may appear to be placed
ahead of yours. However, our firm policy prohibits us from receiving a better price on our order, if you and us invest in
the same security on the same side of the market on the same day.
20
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2
Participation or Interest in Client Transactions
Your Advisory Representative, who may be a Related Person to us, can recommend or buy and sell securities that it or its
Related Persons’ have a financial interest in. Please see the Firm’s ADV Part 2A for further details on these financial
interests and associated conflicts of interest.
Review of Accounts
Your Advisory Representative periodically reviews your account and contacts you at least annually. For further account
review details, please see the ADV Part 2A of your Advisory Representative.
Client Referrals and Other Compensation
As Program Sponsor, we receive a portion of the Account Fee as described in Item 4 above. For further details on
compensation and other economic benefits that your Advisory Representative receives, please see their ADV Part 2A.
Financial Information
Your Program assets will be custodied at Pershing or NFS. The Program does not allow, require or solicit prepayment of
more than $1,200 in fees per client, six months or more in advance. Therefore, we are not required to include a balance
sheet for our most recent fiscal year. We have no financial condition that might impair our ability to meet our contractual
commitments to clients and have never been the subject of a bankruptcy proceeding.
Securities and investment advisory services are offered through Osaic Wealth, Inc., broker-dealer, registered investment adviser and member of FINRA
and SIPC. Osaic Wealth, Inc. is separately owned and other entities and/or marketing names, products or services referenced here are independent of
Osaic Wealth, Inc. © Osaic Wealth • 18700 N. Hayden Rd. Suite 224 • Scottsdale, AZ 85255 • 800-821-5100 • osaic.com
21
Current as of August 31, 2026
© Osaic Wealth • SMAP Brochure 2026.2