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EQUITABLE ADVISORS, LLC PART 2A
Equitable Advisors, LLC (CRD 6627), brochure dated September 30, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
Equitable Advisors, LLC
1345 Avenue of the Americas, New York, NY 10105
(866) 283-0767, Option 2
www.equitableadvisors.com
2026 Firm Brochure
(Form ADV Part 2A)
This
Brochure provides information about the qualifications and business
Equitable Advisors,
Company
we
questions about the contents of this Brochure, please contact us at (866) 283-0767, and select Option 2
and then Option 2 again. The information in this Brochure has not been approved or verified by the United
SEC
States Securities and Exch
Advisers Act
Equitable Advisors is registered as an investment adviser with the SEC under the Investment Advisers Act
of 1940, as amended
. Registration of an investment adviser does not imply a certain
level of skill or training. The oral and written communications investment advisers provide to you,
including through brochures such as this one, provide you with important information you should use to
determine whether to hire or retain an investment adviser.
https://adviserinfo.sec.gov.
September 30, 2026
Item 2 Summary of Material Changes
This Brochure dated September 2026 provides information as part of our ongoing updating process, and
constitutes an interim, (other-than-annual) amendment. This Brochure also constitutes the disclosure
required to be provided to plan sponsors under Section 408(b)(2) of the Employee Retirement Income
ERISA
from and amends our most recent Brochure, filed as our annual amendment on March 31, 2026, in the
following respects. Equitable Advisors does not consider the following to be material changes but includes
this discussion to show changes from the previously filed version.
.
Equitable Advisors has added language disclosing the merger of Equitable Holdings -- its
in a merger of equals with Corebridge Financial, another
Item 4
publicly traded parent company
publicly-
stockholders on July 30, 2026, and is expected to close by year-end 2026, pending regulatory
approvals. .
Item 4 - Information relating to our regulatory assets under management, number of accounts,
discretionary versus non-discretionary account breakdown, and other information has been
updated.
Item 10
The discussion in this Item has been updated to provide changes to affiliated registered
investment advisers; because the merger has not yet occurred, this update does not include post-
merger registered affiliates.
.
We will provide clients additional ongoing disclosure information about material changes, including
revised Brochures or future summaries of material changes directing clients to such Brochures. Any such
information will be provided to clients free of charge. A client may request a current copy of this and any
future Brochures at any time by contacting Equitable Advisors at (866) 283-0767 and selecting Option 2
https://adviserinfo.sec.gov/firm/6627
and then Option 2 again, or by going online to
(also known as Form
on our disclosure
CRS or Form ADV Part 3)
website https://equitableadvisors.com/legal/disclosures.
and
on
our
disclosure
website
https://adviserinfo.sec.gov
https://equitableadvisors.com/legal/disclosures.
registered investment adviser representatives.
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Item 3 Table of Contents
Item
Page
Item 2
Summary of Material Changes ........................................................................................................ 1
Item 4
Advisory Business ............................................................................................................................ 3
Item 5
Fees and Compensation ................................................................................................................ 32
Item 6
Performance-Based Fees and Side-By-Side Management ............................................................ 38
Item 7
Types of Clients.............................................................................................................................. 38
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 38
Item 9
Disciplinary Information ................................................................................................................ 40
Item 10
Other Financial Industry Activities and Affiliations ..................................................................... 41
Item 11
Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading ............. 42
Item 12
Brokerage Practices ..................................................................................................................... 44
Item 13
Review of Accounts ..................................................................................................................... 45
Item 14
Client Referrals and Other Compensation .................................................................................. 47
Item 15
Custody ........................................................................................................................................ 51
Item 16
Investment Discretion ................................................................................................................. 52
Item 17
Voting Client Securities ............................................................................................................... 53
Item 18 - Financial Information ................................................................................................................... 53
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Item 4
Advisory Business
A.
Overview
Equitable Advisors and its IARs
Equitable Advisors
Advisers Act
Exchange Act
Equitable Advisors
Company is a Delaware limited liability company
formed in July 1999. The Company is registered with the Securities and Exchange Commission SEC as
(1) an investment adviser under the Investment Advisers Act
,
and (2) a broker-dealer
a registered broker-dealer, the Company is a member of the Financial Industry Regulatory Authority, Inc.
FINRA .
Equitable Advisors is a
EQH , a public
company under the Exchange Act. EQH common stock is traded on the New York Stock Exchange (NYSE:
EQH). EQH comprises two principal financial services franchises
Equitable and AllianceBernstein.
Equitable is the brand name of the retirement and protection subsidiaries of EQH, including Equitable
Financial Life Insurance Company (Equitable Financial) (NY, NY); Equitable Financial Life Insurance
Company of America (Equitable America), an AZ stock company with an administrative office located in
Charlotte, NC; and Equitable Distributors, LLC.
AB is the brand name of the global
asset management and broker-dealer subsidiaries of AllianceBernstein L.P., which provides investment
management and research services worldwide to institutional, high-net-worth, and retail investors.
EQH has agreed to a merger of equals with financial services firm Corebridge Financial
Corebridge is a public company registered under the Exchange Act, the securities of which trade on the
NYSE (NYSE: CRBG). The merger was approved by each
and is expected to close by year-end 2026, pending regulatory approvals. Corebridge has both broker-
dealer and registered investment adviser subsidiaries. This Brochure will be updated after the merger to
address the business, conflicts, and other material issues that result from the transaction and the
integration of the firms. Additional information regarding the merger
company filings with the SEC, available at https://ir.equitableholdings.com/financial-information/sec-
filings/default.aspx
https://www.sec.gov/search-filings.
Equitable Advisors
its respective advisory contracts under the Advisers Act and currently is obtaining the consent of existing
clients to the technical change in control.
As an investment adviser, Equitable Advisors and its investment adviser representatives (in such capacity,
IARs are also
IARs owe a fiduciary duty to advisory clients. With very limited exceptions,
registered representatives in its broker-dealer business; many, but not all, of
registered
representatives in its brokerage business are also IARs. Many of our IARs also are licensed as insurance
agents of Equitable Network, LLC, a licensed insurance company; Equitable Network is also an indirect
subsidiary of EQH and, therefore, an affiliate of the Company Equitable Network . IARs act as insurance
agents when recommending variable annuity or other insurance products to clients. Our IARs are
generally referred to in this Brochure as IARs. In our marketing and other materials, our IARs may also be
known as Financial Professionals, Financial Consultants, Associate Financial Planners, Financial Planners,
Financial Advisors, or Registered Representatives (in the broker-dealer context).
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SAM
Equitable Advisors requires that its professionals satisfy certain baseline requirements in serving as IARs.
Most of our IARs are able to offer the full range of advisory services described in this Brochure. The
Company generally requires its IARs to hold a Series 7 and Series 65 or Series 66 license. In some cases,
the Company permits persons to serve as IARs with the Series 6 license, but they cannot advise Strategic
for
certain advisory services, Equitable Advisors requires that an IAR hold additional credentials, undergo
specific training, or satisfy other qualifications before providing such services. For example, these include
providing certain financial planning services, exercising discretionary authority over client accounts in
SAM program, or serving as a fiduciary or investment manager to a qualifying plan account under
Section 3(21) or Section 3(38) of ERISA (each as discussed in this Item 4 below).
in this Brochure.
In some cases, IARs not authorized to provide a given service are permitted only to refer clients to other
IARs or to third-party asset management firms (e.g., those defined below as TAMPs). Depending on your
needs, such limitations may present a conflict of interest for your IAR if the IAR is limited in his or her
ability to provide the full range of advisory services. The IAR may be incentivized to recommend or not
recommend certain services or actions based on what he or she is able to provide. You should discuss
such limitations with your IAR to ensure you understand any applicable limitations and any conflicts of
interest to which they give rise.
Equitable Advisors and its IARs do not provide legal, accounting, or tax advice. We recommend that clients
consult their own legal, accounting, and tax advisers in connection with the implementation of a financial
plan or in connection with asset management, as they deem appropriate. Additionally,
IARs do not provide investment advisory services to federal, state, or local governmental entities.
Certain professional organizations may have disclosure or other requirements that apply to individual IARs
who are members of such organizations or hold a designation issued by such an organization (e.g., the
Certified Financial Planner Board of Standards, Inc.). Equitable Advisors is not responsible for monitoring
This Brochure provides important disclosures primarily relating to the investment advisory services
available through Equitable Advisors. For additional information about Equitable Advisors, see Equitable
Form CRS
-
GCOI
Disclosure
Principles
of
Investing
brochure.
foregoing materials
are
available
Compensation and Conflicts
Form CRS is a relationship summary designed to inform
regarding the customer or client relationship among brokerage, investment advisory, or a
combination of both. The GCOI describes conflicts the Company faces. The Compensation and Conflicts
Disclosure is a supplement to the GCOI describing compensation paid by third parties to Equitable
Advisors and, in some cases, its financial professionals. For a discussion of risks in advisory accounts, see
our
at
The
https://equitableadvisors.com/legal/disclosures or through your IAR.
B.
We tailor our advisory services to the individual needs of our clients. Prior to providing a client with any
investment advisory services, an IAR will work with the client to mutually define the scope of the services.
risk tolerance, and
, future cash requirements, and priorities. In
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providing ongoing asset management services, an IAR will meet with the client at least once annually to
review this information and update it if there are material changes.
As with its asset management services, in providing financial planning advice an IAR will work with the
client to determine the personal information and assumptions that should be used in developing the
financial plan, so that any analysis and projections included reflect the client s circumstances and views
on future conditions and events. These assumptions may include personal assumptions (e.g., retirement
age, life expectancy, and income needs) as well as economic assumptions (e.g., inflation rates, tax rates,
and investment returns). Such assumptions and projections are described in more detail in this Item 4,
below.
C.
The Advisory Services We Provide to Clients
Advisory Business, we provide more details regarding our advisory services. We offer two
In this Item 4
main types of investment advisory services:
(1) financial planning (discussed in Section D), and
(2) asset management services (discussed in Section E).
In some circumstances, we also offer education and other services to retirement plan sponsors and their
participants and, as part of our asset management business, fiduciary advisory services to plan fiduciaries
(including discretionary and non-discretionary asset management). This business is specifically discussed
in Sections D and E below.
D.
Financial Planning Services
1. Financial Planning Generally
Our IARs may provide personal financial planning services that include education, advice, and the
preparation and delivery of a written financial plan, as well as general advice and recommendations to
help the client achieve his or her personal financial goals. In some circumstances, affiliated representatives
of Equitable Advisors may also refer potential clients for financial planning services to other investment
advisers and receive compensation for the referral.
Our personal financial planning services typically involve three steps:
gathering information from the client and completing a client profile;
developing the advice or plan; and
delivering and presenting the plan or advice to the client.
In entering into a financial planning relationship with the Company, a client signs a financial planning
services agreement and, in most cases, agrees to pay a fee in exchange for those services. We offer both
fee and non-fee financial planning programs. Additional information relating to how financial planning
Fees and Compensation below. The financial planning
fees are determined and paid is included in Item 5
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agreement can be cancelled at any time by either party for any reason and has a maximum one-year term;
at the expiration of that term, if desired, the client must execute a new financial planning agreement to
continue the financial planning relationship. In addition, except as described below with respect to
financial planning provided without additional fee as a value-add to asset management services, Equitable
Advisors will refund the full financial planning fee paid by any client who is not satisfied with the services
and requests a refund within ninety (90) days after service delivery.
Upon delivery of a financial plan or advice to a client, the client will review the plan or advice and
acknowledge receipt through a signed delivery receipt or via an electronic acknowledgement. The
plan or advice. The financial plan or advice will not include analysis or recommendations regarding specific
securities or investment or insurance products. Such advice or recommendations may only be provided
pursuant to a separate brokerage or advisory agreement and relationship with the Company and are not
included in or part of the financial planning services or the financial plan.
Generally, if the client decides to purchase investments or insurance products through the IAR in his or
her capacity as a broker-dealer registered representative or insurance agent, Equitable Advisors will
receive commissions and the IAR will receive a portion of those commissions. Such purchases would be
made pursuant to a brokerage relationship with Equitable Advisors, and the client may be required to
open a brokerage account.
in implementing the financial plan. These services are offered as a new advisory relationship with
Equitable Advisors, subject to a separate agreement and the opening of an advisory account. Equitable
Advisors will receive an asset-based fee for such services, a portion of which is paid to the IAR.
Thus, the IAR has an incentive to recommend that such brokerage or insurance products or advisory
services be obtained through Equitable Advisors, which is a conflict of interest in its recommendations to
. Equitable Advisors addresses that conflict through supervisory
oversight and controls designed to ensure that all recommendations by its IARs comply with regulatory
requirements and are in the best interests of the client. Clients have no obligation to purchase any such
products or services through Equitable Advisors or its affiliates.
In some circumstances, IARs may offer financial planning services to their advisory clients in managed
accounts as part of the advisory services without a separate fee for such services, as described in the
. In such cases, the asset-based advisory fee paid by the
client would include the financial planning services.
Equitable Advisors also makes a variety of financial analyses, account review tools, and reports available
to clients in our capacity as a broker-dealer (and/or through our insurance affiliate, Equitable Network),
to provide education and/or advice regarding products, or in our capacity as a registered investment
adviser to help clients select, allocate their assets among, and monitor the performance of specific
investments. Unless accompanied by a financial planning agreement and a copy of this Brochure, these
.
The following is a description of the various personal and other financial planning services we offer.
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Goals-Focused Planning
particular situation
Based on the long-term goals a client has identified, an IAR will analyze
and provide recommendations on the topics that align with his or her goals.
Financial Position
financial plan is secure. This
current level of cash reserves to provide an assessment of his or her
The Financial Position topic is designed to ensure the foundation of
area may also evaluate
ability to cover expenses in case of emergency.
Insurance Needs
This service is intended to prepare clients for unexpected needs or the effect on cash flow or net worth
arising from death, disability and long-term care, or other circumstances specific to
personal
IAR may provide advice regarding the level of survivor income protection and
financial situation.
disability insurance a client may need in order to protect his or her
financial goals and
desired lifestyle. This service may include estimates of survivor income needs resulting from a lost pension
or Social Security income due to a spouse passing away.
plan may also include advice on the
level of long-term care coverage he or she may need to protect assets from depletion and to maintain a
desired retirement lifestyle.
Asset Allocation and Investment Planning
This service provides a client with an evaluation
assets and potential strategies to help
optimize portfolio performance to reach his or her goals. An asset allocation report may be provided to
help a client develop an investment portfolio that is designed with a level of risk that he or she finds
acceptable. Such asset allocation reflects a long-term approach to investing. The
(i.e., short-term reallocations
among asset classes), and, as in its other financial planning services, this service does not generally include
recommendations of specific securities or other investment or insurance products.
Retirement and Distribution Planning
Retirement Planning helps a client plan for retirement. The IAR may provide the client with a current
estimate of future retirement income and expenses and can illustrate potential savings and investment
combinations to help the client meet his or her retirement needs. Distribution Planning helps a client
understand actions required to transition into retirement. This may involve an IAR significantly
repositioning, addressing timing issues, and reviewing risk tolerance to provide adequate income and
financial security during
retirement years. The client may also receive analysis to help him or
her understand and evaluate options for plan distributions, Social Security benefits and elections, work,
leisure, health care, and other decisions.
Education
This service helps clients plan for funding sources and expenses related to education. An IAR can provide
the client with solutions for existing assets, income, savings, and funding options that can be designated
toward achieving
or his or her
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Estate Planning
This service will help you prepare for passing wealth to your beneficiaries in an efficient manner. It may
include an analysis that provides an estimate of estate settlement costs and the possible remainder of
your estate(s) that could be passed on to heirs. Your IAR will propose options to help manage costs, leave
a legacy, and provide for others. In addition, your IAR can assist your attorney in the settlement of an
estate. Neither the Company nor the IAR provides legal or tax advice, including in this or any financial
planning service offered.
Stock Options
This service provides clients with multiple strategies to consider in exercising employment-based non-
qualified and incentive stock options. This may include portfolio analysis intended to help the client
determine the appropriate time to exercise options given risk and reward considerations and to illustrate
the after-tax effects of exercise and sell strategies while considering tax and cash flow efficiency.
Income Tax Planning
This service is intended to address general tax considerations for financial services products, transactions,
and ownership structures. Working with
tax professional, an IAR can also help identify options
related to financial planning strategies and goals. This service may also analyze various strategies for tax
efficient withdrawals from tax-deferred accounts and seek to minimize the taxation of Social Security
income. Neither Equitable Advisors nor the IAR provides tax or legal advice, including under this or any
other planning service.
Major Purchase Planning
Major Purchase Planning seeks to identify annual and monthly savings needed for various goals such as
making a large purchase (e.g., a second home) and/or other income sufficiency needs. This service may
also analyze different personal financial choices such as spending less for the major purchase, saving more
for the major purchase, and adjusting the timing of the major purchase. This may include an analysis of a
client s current financial position relative to a level of income sufficient for various other goals the client
has identified.
Divorce Planning
This service is designed to propose strategies for one party to a divorce to arrange for his or her personal
finances during a divorce. This service may include a divorce financial plan, which is designed to assist the
individual client (one of the divorcing parties) and his or her attorney in evaluating the long-term financial
consequences of proposed divorce or settlement options.
This service does not recommend a preferred divorce settlement option. Additionally, any illustrations
regarding ownership of assets or division of assets and liabilities are for educational and illustrative
purposes only and are not recommendations of any course of action; all decisions regarding such matters
should be made by the client in consultation with his or her attorney. Note that any documents, analyses,
and other reports provided, and statements made, by an IAR in providing the divorce planning service
may be discoverable by another party to the proceeding; a client should consult with his or her attorney
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regarding such issues and the availability of such materials in discovery, as well as any other legal issues.
To reiterate, the Company does not provide legal advice.
Assumptions, Projections, and Estimates are not Guaranteed
The financial plan or accompanying materials may include financial projections, including hypothetical
performance of certain asset classes or types of investments. Such projections in financial plans (as well
as those provided in any subsequent investment advice or recommendations) are necessarily based on
numerous assumptions as to future conditions that may not ultimately prove accurate, which may include
assumptions as to interest rates, inflation rates, income tax rates, Social Security benefits, and returns on
investments, among other things. The IAR
should be used in developing individualized financial planning advice, so that any projections or estimates
incorporate the client s personal goals, objectives, circumstances, and needs. The goal is to refine the
assumptions made and variables considered in making a financial plan to take into account individual,
personal information about the client, such as age, income, desired retirement age, life expectancy,
income needs, risk tolerance, and time horizon, among other things, as well as broadly-applicable
considerations such as inflation rates, tax rates, and overall market returns.
related to acceptable risk levels may also be measured through the completion of a risk tolerance
questionnaire. These assumptions and estimates are intended to help the client estimate amounts needed
to fund specific future goals (e.g., education funding, retirement, etc.) and develop appropriate strategies
to meet those goals.
Any financial projections are dependent on future events that are inherently uncertain. As a result,
neither the Company nor an IAR can provide you with any assurance that such projections or any
estimates, including the economic assumptions underlying the projections, will be realized or, even if
realized, will result in the client meeting his or her financial goals.
All projections and estimates are furnished for illustrative purposes only. They are not guarantees of any
kind, including with respect to the return on any investments or investment strategies or in pursuing any
other course of action.
Potential and current financial planning clients are encouraged to review our Proposal Tool Disclosure
which discusses how performance-related illustrations and projections are calculated and created, as well
as their limitations and key considerations in reviewing them. The Company maintains and posts this
disclosure at https://equitableadvisors/com/legal/disclosures.
Absent a follow-on agreement for future financial planning or other advisory services, the Company and
its IARs will not monitor or update the financial plan. Clients are encouraged to periodically review their
plans previously received to take account of changing conditions, including, among other things, changes
in their own circumstances, goals, or objectives, and determine if an updated financial plan is appropriate.
2. Financial Planning Seminars
IARs may conduct investment advisory seminars for employer-sponsored employee meetings, specific
client groups, or other types of group meetings. Seminars may cover many aspects of financial planning,
including risk management, cash management, investment planning, income tax, retirement planning,
and estate conservation. The fees charged for seminars are described in our response to Item 5
Fees
and Compensation below.
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Seminars will be general in nature and limited to educational and impersonal advice. The information an
IAR provides
attendees will not be obligated to implement any advice, recommendation, or information they receive
through Equitable Advisors or any other party. Attendees of such seminars are not advisory clients of the
Company by virtue of such attendance.
any other law. In addition, the limits on Equitable Advisors
qualified retirement plan that is subject to ERISA or an IRA subject to applicable provisions of the Internal
Revenue Code
Internal Revenue Code .
3. Corporate Financial Planning
Equitable Advisors may enter into written agreements with select corporate, institutional, or membership
organizations to provide planning services to their employees, partners, independent contractors, or
members. The fees, if any, in connection with these services are subject to negotiation between Equitable
Advisors and the organization. The negotiated fees may be specific to a given organization and may vary
substantially from the fees described elsewhere in this Brochure. Those receiving financial planning or
other services under an institutional agreement typically pay lower fees than those clients who otherwise
enroll in personal financial planning services.
The services provided by Equitable Advisors pursuant to corporate agreements are not intended as
provided to employees that participate in a qualified retirement plan that is subject to ERISA or an
IRA subject to the Internal Revenue Code.
4. Business Strategies Services
Equitable Advisors may also allow certain credentialed IARs to provide Business Strategies Services, which
include business exit planning and other business planning services. Under Company policy, such IARs
must meet additional requirements over and above those required of IARs before they are permitted to
provide such services. Business Strategies Services includes providing certain educational modules to
business owners to assist them in accomplishing their objectives with regard to the realization and
preservation of maximum business value and personal wealth. IARs utilize a client questionnaire to
determine which educational modules may be of value to the client.
E.
Asset Management Programs
Equitable Advisors
Assisting clients in allocating investment among separate account programs offered by LPL
Program, as
LPL Program and acting as portfolio manager in LPL
Financial (each
described below,
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Making endorsements (referrals) of persons to one or more third party asset managers (or
TAMPs offered through the Company, with or without the Company providing additional client
services depending on the arrangement with the TAMP, and
Providing ERISA fiduciary non-discretionary and discretionary investment manager services to
qualified retirement plans and retirement investors subject to ERISA.
The following are the types of programs offered by Equitable Advisors (through the LPL Programs and the
TAMPs).
Mutual Fund Advisory Programs
mutual fund programs that allow investors to allocate their
assets across multiple mutual funds. These programs typically include elements such as client
profiling, fee-based pricing, and rebalancing.
Exchange Traded Fund (ETF) Advisory Programs
managed account programs that allow investors
to allocate their assets across multiple ETFs. These programs typically include elements such as
client profiling, fee-based pricing, and rebalancing.
non-discretionary and discretionary fee-based advisory
IAR as Advisor Programs (e.g., SAM)
programs that enable investors to hold different types of securities (e.g., mutual funds, ETFs,
equities, fixed income, etc.).
Separately Managed Account (SMA) Advisory
managed programs that utilize separate accounts
as the investment vehicle. These separate accounts are managed by a third-party money manager
and will contain individual securities such as equities and individual fixed income securities. These
can be traditional, where a single account corresponds to a single investment strategy, or multi-
discipline, where the program offers multiple disciplines within the same separate account with
an overlay manager responsible for coordinating the multiple disciplines into a unified portfolio.
Unified Managed Account a single account that houses multiple investment products such as
separately managed account managers, mutual funds, and ETFs. The account utilizes a platform
The following sub-sections 1 and 2 provide a high-level description of the programs generally available
through Equitable Advisors. Sub-Section 3 specifically discusses our qualified plan and ERISA services,
including our ERISA fiduciary services. The following is not a full description of any program. Clients and
potential clients should consult the
Form ADV Part 2A and its program materials or the applicable
LPL Program Brochure to determine the specifics of each particular investment program, including
information regarding separately managed accounts in each program, risks, conflicts of interest, and other
matters.
1.
Equitable Advisors offers clients access to various investments advisory programs offered through LPL and
on a discretionary or non-
in the SAM program serves as the portfolio manager to clients
discretionary basis. The LPL programs offered by Equitable Advisor are:
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OMP
MWP
Manager Select
PWP
SAM
Except for SAM, all the LPL Programs offered by Equitable Advisors are wrap programs, meaning a single
transactions and other administrative and custodial services. The features of wrap programs and certain
risks and conflicts of interest in such programs are discussed below. The Program Brochure for each of
these LPL Programs is available at https://equitableadvisors.com/legal/disclosures. The Program
Brochures describe the relevant LPL Program and include the account agreement for that Program
Form ADV Part 2A (or the Wrap Program Brochure, as well as this Brochure, and both LPL and the
, among other things. Potential clients should carefully
read the relevant Program Brochure prior to investing in any LPL Program through Equitable Advisors.
Under many of the LPL Programs, LPL acts as co-adviser with the Company and has discretionary authority
to implement models or strategies. However, the LPL
Programs vary. The LPL Programs include the SAM program in which the IAR directly recommends
investments to clients. Subject to client consent and Company approval, an IAR may exercise discretion
over a
client on each recommendation. Consult the full LPL Program brochures or your IAR for more information.
2.
Descriptions of the LPL Programs Offered
OMP OMP offers clients the ability to participate in a professionally managed asset allocation
program using Optimum Funds Class I shares. The IAR obtains the necessary financial data from
the client, assists the client in determining the suitability of the program, and assists the client in
setting an appropriate investment objective. The client will authorize LPL on a discretionary basis
to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client.
There are up to six Optimum Funds that may be purchased for the account.
MWP
ETFs
-
ETNs
MWP offers clients the ability to participate in a unified managed account program.
Clients authorize LPL on a discretionary basis to purchase and sell mutual funds and exchange-
-end funds, equities or fixed-
income securities pursuant to
investment objective. The IAR will obtain
personal and financial data from client, assist client in determining the suitability of the Program,
assist client in setting an appropriate investment objective and selecting one or more model
-party investment strategist or an IAR
of the Company (in MWP Advisor Sleeve) consistent with the c
Two of the MWP strategists are affiliates of Equitable Advisors -- AB and Equitable Investment
Management (the brand name for Equitable Investment Management Group, LLC). IARs may
recommend these affiliates as strategists in MWP. Also, LPL makes available portfolios created
as an accommodation for Equitable Advisors. PST is a
state-registered investment adviser owned and operated by a registered representative of the
Company. PST is not affiliated with or under the control of the Company. PST has not met the LPL
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selection and review criteria that LPL applies to other portfolio strategists and its portfolios are
strategists.
Manager Select
In the Manager Select program, Equitable Advisors, through its IARs makes
available to clients the services and/or model portfolios of third-party portfolio management
firms. Within the Manager Select, LPL offers two alternatives
the Separately Managed Account
Platform (the SMA Platform
MP Platform
Platforms
er,
serves as the custodian, provides brokerage and execution services, and performs administrative
services such as client reporting. The Company through its IAR assists the client to determine the
the management of the account, and, in the case of the SMA Platform, select an investment
strategy and SMA Portfolio Manager, or in the case of the MP Platform, select a model portfolio
-party investment advisers.
PWP
Portfolios
Models
PWP is a unified managed account program in which LPL and Equitable Advisors provide
ongoing investment advice and management. In PWP, clients invest in asset allocation portfolios
may include a combination of mutual
funds, ETFs
-party money managers. The
Models typically consist of equity and fixed income securities but may include investment
made available in a Portfolio. LPL acts as the overlay portfolio manager in coordinating the trades
among the various securities and sleeves of a PWP account. LPL has discretionary authority to
purchase and sell securities in the account.
SAM
UITs
Under the SAM program, Client authorizes Equitable Advisors, on a discretionary or
nondiscretionary basis,
to purchase and
sell eligible securities, including no-load and load-waived mutual funds, unit investment trusts
closed-end funds, interval funds, and ETFs, ETNs, equities, fixed income, options, and
certain alternative investments (on a non-discretionary basis), and to purchase and sell separate
accounts within variable annuities. The IAR will obtain the necessary personal and financial data
from the client, assist the client in determining the suitability of the Program, and assist the client
in setting an appropriate investment objective.
In connection with any of these programs, our IARs may from time to time retain third-party economists,
analysts, or consultants to develop model portfolios, provide financial or economic research and data,
develop capital markets assumptions, interpret and analyze economic and financial data sets and trends,
develop economic models, or otherwise support the investment advisory services provided by the IARs
under these programs.
Equitable Advisors receives a portion of the advisory fee for the services it provides in all of the LPL
Programs. The fees for LPL Programs paid to the Company as well as other compensation Equitable
Advisors and its IARs receive are described in more detail in Item 5 - Fees and Compensation.
11
September 2026
model for his or her clients) are discussed in greater detail in subsection (c) below.
Additionally, Equitable Advisors has other relationships with LPL. LPL acts as Equitable Advisors fully
disclosed clearing firm for broker-dealer products and services and also provides back- and middle-office
advisory businesses.
As a result, there are potential and actual conflicts of interest associated with the compensation to LPL
for services to Equitable and the division of compensation between the two firms for services to clients
(see also Item 5, Item 13, and Item 14). These conflicts and implications for the client are discussed in
greater detail in the relevant LPL Program Brochure. Equitable Advisors addresses these conflicts of
interest by disclosing them to you as well as through training, tools, and processes to ensure
designed to ensure that each recommendation meets all regulatory requirements.
PTC
PTC is a wholly owned subsidiary of LPL Financial and is not affiliated with Equitable Advisors. PTC provides
a variety of trust services. The option of using PTC is the decision of the client. Equitable Advisors IARs
cannot provide legal or tax advice in conjunction with the trust services available through PTC and clients
are encouraged to consult with their legal and tax advisors prior to selecting PTC as their provider for trust
services. Equitable Advisors IARs are not compensated for the use of
rust services. Clients that
have selected PTC as their trust provider may choose to invest the trust assets in any of the advisory
programs available through LPL Financial.
certain of the LPL advisory programs and brokerage accounts may offer the
ability to access funds through ACH instructions, wires, and other transfers. The security of customer
accounts is our paramount concern, and if at any time such security may be jeopardized by using ACH
instructions, wires and other transfers, these features may be terminated by Equitable or LPL. Equitable
and LPL each reserve the right to refuse any directive or instruction relating to ACH, wires, or transfers in
their sole discretion.
LPL provides collateralized lending services through certain federally chartered savings bank(s) with
respect to securities held in SAM advisory and brokerage accounts. This is referred to as margin lending.
Clients should refer to the SAM brochure for more info on such lending. Clients using this lending will pay
a rate of interest on such loans, which is not paid to the Company. The Company charges its advisory fee
on the net amount of assets, excluding any borrowing on margin.
a.
SAM Program -- IAR as Portfolio Advisor
In the SAM program, the IAR makes recommendations of specific investments to clients, and with client
discretionary authority is discussed in this Item 4 and in Item 16 below. In all the other LPL Programs
available through Equitable Advisors, any discretionary portfolio management services are provided by
LPL and/or its delegate.
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(1)
SAM Program Accounts
(a)
SAM Accounts Generally
In SAM accounts, the IAR serves as portfolio adviser on a non-discretionary or discretionary basis where
previously purchased load mutual funds (e.g., equities, fixed income, options, no-load and load waived
investment objectives. In most cases,
mutual funds, variable annuities, and ETFs) pursuant to
portfolio management services for SAM accounts are provided on a non-discretionary basis, which means
the client must approve all investment recommendations prior to execution. With client written consent
and Company approval, an IAR may provide advisory services for a SAM account on a discretionary basis
(see Item 16
Investment Discretion).
In a SAM account, the client and the IAR can agree that (1) the client pays the flat-fee ticket charges (i.e.,
transaction charges) for executing trades in the account through LPL, or (2) the IAR pays such charges. In
the second option, the overall advisory fee paid to LPL in SAM (and the portion paid to the Company and,
thus, the IAR) may be higher than it would be if the client paid the ticket charges.
The IAR paying the ticket charges creates a conflict of interest in that it may incentivize an IAR to minimize
-
trading and avoid transaction costs. A
commissions). The Company has controls in place to monitor the level of trading activity in SAM accounts.
The Company has in place a system of alerts to identity SAM accounts which trade infrequently, indicating
a brokerage account may be more suitable for the client. Further, when the IAR pays the ticket charges, it
creates an incentive for the IAR to select investment options that minimize the transaction costs. For
NTF
such funds, no ticket or transaction charges are paid by the client (or, in this case, the IAR). NTF shares
often have a higher internal expense ratio than their counterparts for which a transaction charge is paid,
such that the incentive for an IAR to avoid ticket charges by using NTF shares could also lead an investor
to pay higher expenses on its mutual fund investments.
Variable annuities available on the SAM platform are proprietary to Equitable Life Insurance Company, an
affiliate of Equitable Advisors. When acting as such, IARs will not receive up-front commissions for
recommendations of Equitable proprietary variable annuity products in SAM accounts but will receive
an ongoing asset-based fee on the invested amounts as with any SAM investment, as described more fully
EIM , or
AB. Equitable Advisors and its IARs may receive other compensation and benefits related to
recommendations of proprietary products, such as the 1290 Funds and AB Funds. IARs are prohibited
from using discretionary authority to purchase the 1290 Funds or AB Funds and any product proprietary
to an Equitable Advisors affiliate
client consent is required for such investments even in otherwise
discretionary accounts. This compensation creates a conflict of interest in that an IAR is incentivized to
needs. These conflicts of interest are disclosed in this Brochure, the LPL Program brochures, and other
materials discussing the products and services offered, as well as in our GCOI disclosure. All of these
materials are provided at account opening and are available on our disclosure website
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athttps://equitableadvisors.com/legal/disclosures. Important information regarding compensation and
conflicts of interest can also be found in the prospectus for any funds offered, which are available on
request.
A client should consider these additional payments and the potential conflicts of interest they create
carefully prior to investing in the LPL Programs through Equitable Advisors. Additional conflicts of interest
and other potential compensation that may create conflicts of interest are discussed in Item 5 below. The
client is encouraged to ask their IAR for additional information should they have any questions regarding
these payments, the conflicts, and how Equitable Advisors addresses these conflicts. In the case of a
specific variable annuity or mutual fund, clients should refer to the
prospectus or Statement
of Additional Information for more information regarding additional compensation Equitable Advisors and
the IAR may receive and the conflicts it raises.
(b) Alternative, Complex, and Structured Investments in SAM Accounts
IARs may also recommend certain alternative, complex, and structured products in SAM accounts, as
some structured products are Certificates of Deposit CDs
Equitable Advisors and appropriately qualified IARs may recommend alternative investments approved
by the Company to SAM advisory clients. These alternative investments include non-traded business
BDCs
REITs
interval and tender offer funds. These investments are all considered to be alternative investment
products due to their non-traditional structure, regulation, and terms, as well as their relative illiquidity
as compared to exchange-traded mutual and other funds. These alternative investments are discussed in
greater detail below.
C
e.g., sector funds, structured notes and leveraged ETFs) and alternative
investments (e.g., non-traded BDCs and REITs, exchange funds) are generally viewed as difficult for
average investors to understand and typically invest, in whole or in part, in non-
strategies or instruments. These products are often speculative, have high portfolio management fees,
carry higher or unique risks (e.g., valuation risk, commodity risk, and lack of liquidity), and require
additional investor experience when compared to traditional investments.
(2)
MWP Advisor Sleeve Program
In MWP, the IAR recommends one or more strategists and allocations among the model portfolios the
strategists design. LPL effects transactions to
discretionary basis. The strategists do not tailor their models to any client or any specific
objectives, or other specific circumstances. LPL serves as overlay manager and is responsible for
investment decisions and for ensuring that implementation of the models adheres to the reasonable
restrictions on investments the client has communicated to LPL or the IAR.
the IAR recommends an Equitable Advisors IAR serve as the
strategist and that the client invest in the model portfolios that IAR designs. In each case, LPL implements
The IAR
the model through its
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serving as strategist has no discretionary authority to implement the models the IAR designed;
implementation and discretionary authority to make transactions rest entirely with LPL.
and are not available to clients of other financial firms
subject to the LPL selection and review criteria that LPL applies to other portfolio strategists in MWP. This
means that LPL would not subject the Equitable Advisors IARs to the due diligence and screening criteria
it applies to other portfolio strategists. Clients should not perceive that the availability of their or another
Equitable Advisors IAR as a strategist in the MWP program platform means that LPL has vetted, assessed,
abilities, experience, or portfolio management acumen. Clients should bear this
in mind in determining whether to select an Equitable Advisors IAR as strategist.
Clients should and are encouraged to speak to their IAR regarding the IAR or another Company IAR serving
as strategist in MWP Advisor Sleeve and to discuss the arrangement and the services to be provided.
Clients should be certain they understand the investment strategies and techniques the IAR intends to
utilize as an MWP Advisor Sleeve strategist in designing model portfolios, the associated risks, and the
portfolios, the basis of their research, their buy and sell criteria, and the resources they are able to
ADV Part 2B (also referred to as a Brochure Supplement) for mor
experience and education.
MWP Fee Provisions
As set forth more fully in the MWP program brochure, LPL charges three fees in connection with MWP
accounts: the Advisor Fee (of which the Company receives a portion), the Strategist Fee, and the LPL
Program Fee. These fees are separate and paid as compensation for distinct services. The Advisor Fee is
for the investment advisory services of Equitable and the Equitable Advisors IAR. The Strategist Fee is a
fee for the model portfolio design services of a strategist, and ranges from 0% to 0.25%. The LPL Program
Fee is for the investment advisory, administrative, trading, and custodial services of LPL, and ranges from
0.08% to 0.35%. When an Equitable Advisors IAR is the strategist (MWP Advisor Sleeve), the Strategist
Fee is waived as the Advisor Fee is presumed to include compensation for such strategist services. This
portfolios in MWP Advisor Sleeve. In MWP Advisor Sleeve, the Advisor Fee may not exceed 2.35%, as
discussed in Item 5 below.
LPL may change the
prior notice to clients.
4.
Alternative Investments
Properly qualified IARs may recommend alternative investments such as non-traded BDCs and REITs and
certain interval funds and tender offer funds for purchase in SAM accounts. In many cases, IARs may also
recommend such investments through brokerage accounts in their capacity as registered representatives.
Certain alternative investments may only be available through advisory or brokerage. Certain TAMP or
LPL programs may also invest in such investments. IARs may only recommend such alternative
investments to clients meeting certain liquid net worth thresholds. As a result, not all SAM clients may be
15
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able to purchase alternative investments. In addition, the Company imposes concentration limits on
Company (not including the other LPL Programs other than SAM or TAMP programs).
A BDC is a type of pooled investment company that is registered and which has elected to be regulated
1940 Act
an open-end or closed-end investment company. A BDC invests primarily in certain qualifying private
companies and must satisfy certain asset composition and other thresholds and requirements under the
1940 Act. Under the 1940 Act, a BDC is required to provide significant managerial assistance to a
significant portion of its portfolio companies. BDCs facilitate the flow of capital to private companies and
provide retail investors with exposure to private equity and private debt investment markets.
A REIT is a company that owns, and in most cases operates, income-producing real estate such as
apartments, shopping centers, offices, hotels, etc. Some REITs also engage in financing real estate. A REIT
functions as a corporation that directly invests in real estate through property ownership or mortgages,
acquiring property portfolios over several years with the goal of generating rental income and property
value appreciation.
In each case, the BDCs and REITs offered by the Company as alternative investments are not publicly
traded, making them more illiquid and subject to fewer reporting obligations than their traded
counterparts. They offer periodic liquidity through redemption programs. While such non-traded REITs
and BDCs may offer repurchase programs, they ordinarily impose significant conditions and restrictions
on such programs. The holding periods on non-traded REIT and BDC investments vary and may require
holding periods of ten (10) years or more. Therefore, non-exchange traded REITs and BDCs may result in
higher compensation to your IAR than products that have a readily available market. Certain non-traded
, may offer greater liquidity to investors, generally on a quarterly
basis. BDCs and REITs are long-term investments, and investors should be aware that liquidity is not
guaranteed at any time.
These alternative investments sold within an advisory program such as SAM will not incur an up-front
sales charge to the client for the sale (i.e., the IAR will not receive a commission for their sale). Equitable
Advisors receives a portion of the dealer manager fee that is paid on alternative investment accounts,
including assets held within advisory accounts. Furthermore, they are subject to the ongoing asset
management fee agreed upon between the client and Equitable Advisors. Effectively, the value of these
alternative investments is treated as part of the value of the account for purposes of applying the advisory
fee under SAM.
Equitable Advisors also may offer qualified investors access to certain investment companies exempt from
registration as investment companies under the 1940 Act, primarily through LPL, in their capacity as
-dealer business. These include hedge funds, fund-of-
hedge funds, and exchange funds structured as limited partnerships or limited liability companies.
Equitable, in its capacity as a registered broker-dealer, and its IARs, acting as broker-dealer registered
representatives, may act as promoters for certain of these funds. Hedge fund and fund-of-hedge fund
interests are not available in the SAM program or any LPL Programs.
generally less than five years
Certain alternative investment products (and certain structured notes and CDs that may also be available
in SAM accounts) bear a short to intermediate maturity
although some
may have terms as long as fifteen years. Purchasing a product bearing a long period until maturity in an
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directly or in a brokerage account. If purchased in the brokerage context, the IAR would receive an upfront
commission, while in the advisory context the value of the investment is subject to the ongoing, asset-
based advisory fee and no commission is paid to the IAR. Depending on the circumstances, purchasing
through one channel or the other (brokerage or advisory) may result in a lower fee ultimately paid by the
client over time.
Equitable Advisors may make the same, similar, or different alternative investments available to
customers in its brokerage business through its registered representatives. If such alternative investments
are purchased through the broker-dealer channel, different fee structures will apply; for example,
Equitable Advisors and its selling registered representative (which may also be an IAR) will receive a sales
commission rathe
Equitable Advisors and its IARs may have a financial incentive to recommend purchasing an investment in
one of these structures (advisory or brokerage) in a given situation over the other because of the different
compensation structures and terms. Under certain conditions, including length of time that the product
is held, a client may pay a higher sales charge in a commission-based product or may pay more in an
advisory account which is subject to an ongoing fee based on assets under management. Other factors
may also affect how much a client pays in either an advisory or brokerage structure. Equitable Advisors
has supervisory policies and controls in place to monitor whether the purchase of such an investment in
an advisory or brokerage context is suitable for the client, and whether a brokerage or advisory account
In connection with any alternative investment decision, as with any securities investment decision, a client
should consult his or her IAR for more information regarding the different fee and commission structures
that may apply, depending upon whether the client purchases the investment product in an investment
advisory program or in a broker-dealer account. As part of the analysis, a client should consider and
discuss his or her investment time horizon and overall likely costs before deciding what type of
relationship (i.e., brokerage vs. advisory) is appropriate for the investment. The Company encourages
clients to consult with their own legal, tax, and accounting advisors in considering alternative investments.
2.
Referrals to TAMPs
Equitable Advisors refers investors to TAMPs and, in many cases, assists clients in allocating their assets
. As a promoter referring clients to TAMPs, Equitable
Marketing
Advisors acts in accordance with the Advisers Act, including Rule 206(4)-
Rule
When a client invests with a TAMP based on an endorsement by the Company, the TAMP typically has the
authority to place trades on their behalf without first consulting the client (i.e., the program sponsor has
some cases, an IAR will assist
depending upon the TAMP. Equitable Advisors refers investors to TAMPs through two types of
arrangements, each of which is discussed below. In the first, Equitable Advisors refers an investor to a
TAMP, but the referred investor becomes and remains a client of the Company, and the Company provides
Client Referral
Arrangement
relationship with the referred investor and provides no ongoing advisory or other services with respect to
Handoff Referral Arrangement
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These TAMPs sponsor advisory programs or offer investment models and charge the client an advisory
fee based on assets invested. The TAMP pays Equitable Advisors a portion of that advisory fee on an
ongoing basis for its referral and ongoing client management services and advice (in Client Referral
Arrangements) or, in other TAMP relationships when Equitable Advisors does not provide additional
services or ongoing advice (in Handoff Referral Arrangements), solely for its referral.
The Company performs initial due diligence on each TAMP it endorses, and, based on such diligence, each
PRC
below. After approval, the Company enters into a promoter or referral agreement with the TAMP
governing the services it provides, its compensation, and the terms on which it refers investors. The
Company monitors the TAMPs to which it refers investors on an ongoing basis. In addition to general
ongoing monitoring, the Company conducts an annual due diligence review of the TAMPs pursuant to
which each must answer the due diligence questionnaire. The questionnaire requires the TAMP to provide
certain updated documents, policies, and procedures; provide updated answers to certain questions
regarding its services and compliance with regulation, and reaffirm representations and commitments
made in its agreement with the Company.
In both Client Referral Arrangements and Handoff Referral Arrangements, Equitable Advisors (and,
through the Company, its IARs) are compensated with respect to each investor that becomes a client of a
TAMP based on a percentage of the advisory fee paid to the TAMP by the referred investor. When it makes
an endorsement/referral, Equitable Advisors will disclose at that time the nature of its arrangement with
the TAMP (e.g., whether it represents a Client Referral Arrangement or a Handoff Referral Arrangement,
among other things), the compensation it will receive for the referral, as well as any other material
conflicts of interest. Referred persons are required to sign a disclosure form to evidence receipt of such
receipt of compensation for the referral, among other potential conflicts.
Generally, IARs are able to recommend TAMPs to new prospective investors for referral. Certain TAMPs,
however, are limited to existing business and are not available for IARs to recommend to new referred
an IAR can service existing accounts, but
investors
may not refer new clients to the service only TAMP. Generally, these service-only TAMPs are approved
by the Company as accommodations to IARs that join the Company from other advisory firms, allowing
these IARs to continue servicing existing referral relationships with such TAMPs. In some cases, service-
only TAMPs may be later approved by the PRC as TAMPs available for new business, or a TAMP open to
new business may be made service-only going forward. In limited circumstances, IARs joining Equitable
Advisors from another advisory firm are permitted to continue offering a TAMP to new referral investors,
but the TAMP is not available for investor referrals by other Equitable Advisors IARs.
A few key points regarding our arrangements with TAMP programs:
Generally, we initially will carry out various client interface between the referred investor and the
TAMP in both Client Referral and Handoff Referral arrangements, which may include assisting the
client in completing account opening paperwork and facilitating communication between the
TAMP and the client. In Client Referral Arrangements, an IAR may also provide recommendations
Client Referral arrangements, the Company will meet with the client at least annually to update
determine if the
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TAMP investment and allocation remain suitable and will facilitate communication between the
TAMP and the client on an ongoing basis.
Generally, the TAMP will be responsible for determining the specific investments and/or sub-
The Company does not have the ability to select the custodial broker-dealers used by the TAMPs
in effecting client trades. Those decisions are made by the TAMP and in accordance with your
applicable program disclosure document. You should carefully review the Form ADV Part 2A of
the TAMP and its other disclosure materials to fully understand the conflicts of interest it may
face in selecting service providers and executing transactions in your account, among other things.
In Client Referral arrangements, our ongoing responsibilities and those of the TAMP will be
program disclosure document, which we urge the client to read prior to investing.
Your client agreement will generally be between you and the applicable TAMP. Equitable Advisors
may or may not be a party to such agreement, depending on the TAMP. In Client Referral
arrangements our mutual responsibilities are described either in your agreement with the TAMP
(when we are a party) or in a separate agreement between you and Equitable Advisors entitled
Third-
Third-Party Programs Agreement
which can be found on our Disclosure Website (https://equitableadvisors.com/legal/disclosures).
required to agree to the Third-Party Programs Agreement as a condition of your investment.
In Handoff Referral Arrangements, we will not have ongoing contact and responsibilities with
respect to your account after you are referred to a TAMP.
The following is a list of the TAMPs that Equitable Advisors makes available to its clients as of the date of
this Brochure and a brief description of the programs the TAMPs offer. For more information on these
programs, including the applicable account minimums (which generally range from $10,000 to $2 million),
fees, expenses, and potential conflicts of interest, please see the Form ADV Part 2A or program disclosure
document of the respective TAMP, which will be provided to you prior to your opening an account with
the TAMP. These Form ADV Part 2As are also
https://adviserinfo.sec.gov/.
a. Client Referral Arrangements
Under the Client Referral Arrangements, Equitable Advisors maintains ongoing responsibilities and serves
as an investment adviser to the client. The IAR facilitates the ongoing communication between the TAMP
and the client and meets with the client at least once each year to obtain updated client information. This
client information allows the IAR to determine whether the TAMP and its programs as then allocated
remain
. As noted above, the specific activities the Company performs may
vary with each TAMP, but will be described either in your client agreement with the TAMP (if the Company
is a party to that agreement) or in our Third-Party Programs Agreement (if the Company is not a party to
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Client Referral Arrangement TAMPs Open for New Referrals
Equitable Advisors offers clients access to various investment advisory programs offered through ACM.
For each of the ACM programs (Model Separate Accounts and Private Account Strategies), the Equitable
Advisors IAR works with you to complete the individual client questionnaire, which allows ACM to
determine the appropriate investment strategy recommendations to meet your investment objectives.
Core, Growth, Core Dividend, Income with Growth, Balanced, Balanced Defensive (Overlay) and Fixed
Income.
Note that ACM may allow you to use funds from your advisory account offered through ACM to pay
premiums on life and annuity products, including products offered by Equitable Financial Life Insurance
Company, an insurance company affiliate of Equitable Advisors (along with Equitable Financial Life
-party insurance carriers.
SDBA
Equitable Advisors also offers ACM as an investment advisory option, called PathFinder, to provide
assistance in managing assets that retirement plan participants have elected to move into their self-
program offers managed mutual fund strategies
that can be combined in different ways to reflect your specific investment objectives, taking your risk
tolerance and time horizon into account. For direct payroll contributions, ACM imposes no minimum
investment amount although your plan may limit how much money you can have in or contribute to your
SDBA.
AssetMark provides a variety of advisory programs to clients including Privately Managed Portfolios,
Multiple Strategy Portfolios, No Load Mutual Fund Portfolios, ETF Portfolios, Privately Managed Account
Solutions, Select Solutions, and Preservation Strategy. For each AssetMark program, an IAR consults with
clients to assess their financial situation and identify their investment objectives in order to assist the
select advisory service(s) and investment objective(s) available within the program(s). AssetMark
manages client
and level of risk tolerance. Note that AssetMark may allow you to use funds from your advisory account
offered through AssetMark to pay premiums on life and annuity products, including products offered by
Equitable Life Insurance Company, an insurance company affiliate of Equitable Advisors, and third-party
insurance carriers.
Boyd Watterson specializes in managing fixed- income portfolios, equity portfolios, and blended strategies
for individuals and institutions in a single strategy separately managed account program. Clients can
tional investment options or a customized approach that
access to portfolios managed by Boyd Watterson, a Titanium Asset Management Company (formerly
Sovereign Advisers). While Equitable Advisors offers clients the ability to invest directly through Boyd
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Watterson, Boyd Watterson also provides separately managed accounts through specific investment
-Manager or
Equitable Advisors offers clients access to various investment advisory programs offered through Brinker
Capital, Destinations Programs, Core Asset Manager, Unified Managed Account, and Retirement Plan
Services Program/Retirement Plan Services Plus. Brinke
funds or ETFs, ETNs, and mutual funds. For each of the Brinker programs, the Equitable Advisors IAR works
with you to complete the individual client questionnaire, which allows Brinker to determine the
appropriate investment strategy recommendations to meet your investment objectives.
funds, and real assets.
The investment minimum is $25,000, with flexibility for smaller accounts upon exception from Mariner.
Equitable Advisors offers clients access to PlanMember Elite, an advisory program offered by PSEC, which
as noted below is an affiliate of Equitable Advisors. PSEC constructs a series of asset allocation portfolios
with varying risk profiles that are invested in mutual funds. PSEC primarily markets this program to
financial situation and investment objectives. Services are based on the individual needs of the client.
PlanMember Elite has five portfolio models constructed with primarily index funds and another set of five
models constructed with both index and active funds. The portfolio model objectives range from
conservation of principal and inflation protection to maximum long-term growth.
In addition to Elite, PSEC may also provide advisory services to accounts that are opened through the
PlanMember OPTIFUND program. Similar to Elite, this program utilizes the same strategies; however, the
funds used within the models may differ. In addition to the advisory programs, PSEC also offers non-
advisory retirement plan accounts, subject to different fees and charges.
Equitable Advisors may also refer participants in the PSEC 403(b)7 programs for advisory and management
services of their mutual fund holdings with PSEC, an affiliate of Equitable Advisors.
Equitable Advisors offers clients access to various investment advisory programs offered through SEI
including the Managed Accounts Program, Integrated Managed Account Program and Private Client
rograms, the Equitable Advisors IAR works
with you to complete the individual client questionnaire which allows SIMC to determine the appropriate
investment strategy recommendations to meet your investment objectives. Certain proprietary mutual
funds may also be available from SIMC outside of an investment advisory program. Different fees and
charges may apply to such funds.
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Note that SIMC may allow you to use funds from your advisory account offered through SEI to pay
premiums on life and annuity products, including products offered by Equitable Life Insurance Company,
an insurance company affiliate of Equitable Advisors, and third-party insurance carriers.
Equitable Advisors offers TPFG as an investment advisory option to provide assistance in managing assets
that retirement plan participants have elected to move into their self-directed brokerage account (their
SDBA). TPFG provides investment advice to plan participants based on risk assessment questionnaires and
meetings designed to determine their goals and risk temperament (risk profile). TPFG can, at its sole
discretion, waive any applicable minimum amount requirements.
Equitable Advisors offers clients access to portfolios managed by Trek Financial, which uses a goal-based
portfolios will help you meet your investment objectives. The TAMP does not have a stated minimum
account size.
The SIA program offered through Equitable Advisors offers investment management services tailored to
the unique needs of individuals. SIA offers these services through two types of solutions: (1) The Signature
Allocation and Targeted Series and (2) The Signature Elite program. These solutions offer clients
investment diversification and preferences across a wide spectrum with minimum
investment
requirements of $50,000. Note that SIA is only available through certain IARs who joined the Company
with preexisting client relationships with SIA.
Service-Only Client Referral TAMPs - Not Open to New Referrals
The following are the service-only TAMPs that are subject to Client Referral arrangements with the
Company.
-only basis
including the CLS Nationwide Qualified Plans, Individualized Account Management Portfolios, AdvisorOne
Portfolios, ETF Portfolios and Master Manager Strategy Portfolio. Each of these programs offers advisory
services to clients and may include mutual fund investments, separate account management, and ETFs.
Variable annuities will not be offered, although CLS does use these products in some of their portfolios.
b.
Handoff Referral Arrangements
Handoff Referrals the IAR is providing an endorsement of the given TAMP under the Advisers Act as a
promoter, but does not form a client relationship with the referred investor and does not provide ongoing
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Service-only Handoff Referral TAMPs are not discussed, as the Company has no ongoing involvement with
presently does not refer new investors to such service-only TAMPs.
-
Forefront Analytics
The Handoff Referral TAMPs to which Equitable Advisors continues to refer business (rather than on a
Hightower Advisors, LLC, The Colony Group, Raymond James Financial Services,
GKFO, UBS Financial Services, Sentinel Pension Advisors, LLC, Corient Private Wealth,
ProNVest"), and Baldwin Group Wealth Advisors, LLC.
Equitable Advisors may also refer EquiVest variable annuity plan participants to the investment advisory
and asset management services of ProNVest for management of their variable annuity sub-accounts at
Equitable. Equitable Advisors (and its IAR(s)) are compensated for referrals to ProNVest and do not
provide any investment advisory services to the client regarding the ProNVest account. All investment
agreement between the client and ProNVest. Equitable Advisors only engages plan participants for
referrals, and not the plan sponsors. ProNVest is not an affiliate of Equitable Advisors or Equitable or any
of their affiliates. See the Form ADV Part 2A of ProNVest for more information on its investment advisory
practices, available at https://adviserinfo.sec.gov/.
Company) are investment adviser representatives and/or owners of Baldwin Group Wealth Advisors. This
firm is one of a small number of independent investment advisers owned by registered representatives
ORIAs . The Company does
of the Company
not own an interest in or control Baldwin Group Wealth Advisors.
will be provided by the relevant TAMP pursuant to an agreement with the client to which Equitable
Advisors is not a party. See the Form ADV Part 2A of the specific TAMP for more information on its
investment advisory practices and other policies and terms, available at https://adviserinfo.sec.gov/.
(i)
Referrals to Our Affiliate BPWM
Equitable Advisors may refer clients to the investment advisory and asset management services of an
BPWM
Advisors (and its IAR(s)) are compensated for referrals to BPWM and do not provide any investment
arrangements). Compensation paid to the Company and its IARs for such referrals does not increase the
fees charged to such investors relative to other similarly situated investors with BPWN. All investment
Form ADV
agreement between the client and BPWM to which the Company is not a party. See
Part 2A for more information on its investment advisory practices.
3. Retirement Plan Investment Advisory Support Services
Non-Fiduciary Services
23
September 2026
Equitable Advisors may enter into agreements with sponsors of retirement plans to provide general
Retirement Services
sponsor and/or plan participants in exchange for a fee, further information about which is provided in
Fees and Compensation. Only appropriately credentialed IARs are authorized by Equitable
Item 5
Advisors to provide Retirement Services.
The plan sponsor will select the Retirement Services to be provided. The Retirement Services are for
general educational purposes only and are intended to help plan sponsors discharge their fiduciary
responsibilities to the qualified plan and plan participants. The plan sponsor may also select certain
Retirement Services that will provide general education to plan participants to help in their understanding
of the terms and provisions of the qualified plan.
sponsor regarding specific investment options to select under a qualified plan or portfolio plan design,
nor will the Retirement Services involve providing any recommendation to any plan participant regarding
(i) the allocation of their qualified plan account balance, (ii) contributions to investment options under the
qualified plan, or (iii) the investment alternatives of their account balances at retirement or separation
from services, unless the plan sponsor agrees in writing to allow recommendations to participants
regarding their investment alternatives at retirement or separation. Specific Retirement Services selected
by the plan sponsor will be described in the written agreement entered into between Equitable Advisors
and the plan sponsor. Equitable Advisors and its IARs may also act as consultants to other investment
advisers providing plans with similar non-
other adviser, not the plan nor any participant.
In certain instances, an IAR providing Retirement Services to plan sponsors may provide reports and/or a
sample investment policy statement created with software tools owned and operated by companies that
are not affiliated with or under common ownership, control or operation with Equitable Advisors, its
affiliates, or IARs. Any such reports or investment policy statements are not recommendations regarding
any securities transactions and are provided solely to assist plan sponsors in making informed decisions
relative to the management of their qualified plans. Responsibility for adopting a specific investment
policy statement
, if desired, and to select specific investment
options for the plan.
Arrangements for Retirement Services may also include the opportunity for participants to receive, at
their sole discretion, additional personalized financial services, including, but not limited to, personal
financial planning services, investment advisory asset management services, or insurance or brokerage
Optional Services
or qualified plan sponsor. Neither the qualified plan nor any qualified plan participant will be obligated at
any time to purchase any additional products or services (including Optional Services) through Equitable
sponsoring Equitable Advisors or its IAR with regard to the provision of Optional Services. The decision to
receive Optional Services is solely the decision of the qualified plan participant.
Unless otherwise agreed in writing, Equitable Advisors and its IARs will not act as ERISA fiduciaries with
respect to any qualified plan, and any investment materials provided to plan participants will be general
24
September 2026
in nature and limited to educational information regarding the qualified plan and its available investment
options. Such information may include:
Providing specifics about the qualified plan and its design;
Providing a list, by asset class, of all available investment choices (such list will not include any
specific investment recommendations);
Providing Morningstar, Ibbotson or other investment profiles for all available investment choices
including fund sheets, which include a general description of the investment objectives,
identification of the corresponding asset class, the risk characteristics, and the annualized net
rates of return;
Providing general financial and investment information, e.g., educational information and
materials regarding general financial and investment concepts;
Providing general asset allocation models, including information and materials that provide
participants with models of asset allocation portfolios of hypothetical individuals with different
time horizons and risk profiles;
Providing interactive investment materials, which may include questionnaires, worksheets,
software, and similar material that provide the means for participants to estimate future
retirement income needs and assess the impact of different asset allocations; or
Such other information as may be permitted under the DOL Regulations and guidance pertaining
b.
ERISA Fiduciary Services
Retirement Plan Consulting Services
RPCS
Unless approved by the Company, Equitable Advisors policy does not permit an IAR to act (1) as a
fiduciary under ERISA Section 3(21) or (2) as a fiduciary and discretionary investment manager under
ERISA Section 3(38), by providing investment advice to a qualified plan under Section 401(a) of the Internal
Revenue Code that is subject to Title I of ERISA, its sponsor, responsible fiduciary, or its participants, or
(3) in any way assuming responsibilities for a plan that would make the IAR a fiduciary under either of the
foregoing sections of ERISA. IARs must be specifically approved by the Company to act as ERISA fiduciaries
under Section 3(21) or 3(38) under the
When approved, certain restrictions and limitations are imposed upon the nature and mean and methods
of providing such services. No services provided to retirement plan participants are intended to constitute
law or regulation.
(1)
ERISA Section 3(21)
Under the RPCS program, Equitable Advisors may enter into an agreement with a retirement plan sponsor
permitting an approved IAR to provide non-discretionary advisory services as an ERISA fiduciary pursuant
ERISA Fiduciary Services
assist a plan fiduciary in the initial selection and ongoing monitoring of the investment line-up available
25
September 2026
to the plan participants. Only appropriately credentialed IARs who are specifically approved by Equitable
Advisors under the RPCS program are authorized to provide ERISA Fiduciary Services.
(a)
Non-Discretionary Investment Option Recommendation
When acting as a non-discretionary fiduciary under ERISA Section 3(21), Equitable Advisors will analyze
the list of available investment options for the qualified plan and provide the plan sponsor with a
recommended list of core asset classes that, when combined, constitute a prudent investment lineup for
a qualified plan seeking a basic level of complexity. Equitable Advisors will also provide definitions of
additional asset classes/categories that, when combined with core asset classes, will constitute prudent
investment lineups for those plan sponsors seeking more sophisticated levels of complexity. Equitable
options from each asset
class/category that are appropriate for long-term strategic asset allocations. Equitable Advisors will
evaluate the investment options, including comparing their performance to appropriate benchmarks and
peer group(s). Equitable Advisors will
investment options within each of the core asset class groups, as well as supplemental asset
classes/categories. Equitable Advisors will also provide some general guidelines as to how many and what
management type (active or passive) of investment options are appropriate to select with respect to each
of the asset class groups to assist the plan sponsor in making its final investment option selections.
Non-Discretionary Monitoring of Investment Options
(b)
In providing ERISA Section 3(21) fiduciary services, Equitable Advisors reviews investment option
performance on a quarterly basis or as otherwise agreed with the plan sponsor. Each investment option
will be reviewed, and investment options that do not meet the criteria will be placed on a watch list.
Placement of an investment option on the watch list does not mean that it will be removed from the
investment options but, rather, triggers further due diligence. That due diligence seeks to determine if
the original bases for selecting the investment option are still valid. Equitable Advisors will provide the
plan sponsor with a quarterly report summarizing its review.
Once an investment option is on the watch list, it will remain there until further due diligence indicates
that it should be either removed from the watch list or removed as an investment option. To be removed
from the watch list, certain qualitative and quantitative measures must be met. If, after further due
diligence, Equitable Advisors determines that the investment option no longer meets the criteria for
remaining on the core list, Equitable Advisors will identify one or more suitable replacements to the extent
available on the platform.
(2)
ERISA Section 3(38) Discretionary Services
No services
may be provided to qualified plan participants in an ERISA fiduciary capacity (i.e., with respect to their
assets in the subject plan), although upon written consent of the plan sponsor, recommendations may be
made to plan participants regarding their investment alternatives at retirement or separation. A summary
of the ERISA Fiduciary Services is provided below. Plan sponsors should refer to their written agreement
with Equitable Advisors for more details regarding the specific services to be provided and the fees to be
paid.
26
September 2026
to qualified plans under ERISA Section 3(38). Generally, such 3(38) approved IARs have an established
track record providing services as a non-discretionary 3(21) fiduciary, among other criteria for approval
under the RPCS program. These services are only available to qualified plans, not plan participants. Plan
sponsors electing 3(38) Investment Manager services delegate to Equitable Advisors and its IARs the
authority to provide the 3(21)(A)(ii) selection and ongoing monitoring services with respect to of the
specific securities, mutual funds, institutional funds, or funds (including removal and replacement)
available through the applicable qualified plan platform as investment options in the qualified plan, but
in a discretionary capacity. The terms and/or availability of 3(38) investment manager services may be
affected by DOL or other rulemaking and may be terminated or subject to change by Equitable Advisors.
The ERISA Fiduciary Services provided will be based upon the information provided to Equitable Advisors
by the plan sponsor, including, but not limited to, the investment options available under the qualified
plan. Equitable Advisors and its IARs may utilize the software options or tools as described below to help
guide the recommendations to the plan sponsor or discretionary investment decisions, where applicable.
The plan sponsor will agree to review at least annually and to advise Equitable Advisors of any changes in
the investment options that are available under the qualified plan or to the demographic or other
information previously provided to Equitable Advisors regarding the qualified plan. Equitable Advisors and
its IARs may also act as consultants to other investment advisers providing plans with similar fiduciary
er, and not the plan nor any participant.
Additional services may include assistance (in a non-discretionary or discretionary capacity as elected by
investment menu, creation, or development of target date funds with appropriate glidepath options for
the plan and certain other services as may be described within the ERISA Fiduciary Options agreement
between the plan sponsor and IAR.
(3)
Additional Provisions
Except in the case of ERISA 3(38) investment manager services, Equitable Advisors and its IARs will not
and service provider(s). IARs will also not exercise discretion with respect to specific securities or funds
available through a group annuity platform that will be investment options eligible under the qualified
plan. When Equitable Advisors services as a 3(21) ERISA fiduciary, it remains the sole responsibility of the
plan sponsor or named fiduciary to select and retain the qualified plan platform and service provider(s),
to establish and maintain the investment policy for the qualified plan, to determine the appropriate mix
and number of asset classes to be included in the investment options available under the qualified plan,
and to select the specific mutual funds, institutional funds or funds available through group annuity
contracts that will be investment options under the qualified plan. If a qualified plan contains a company
stock or self-directed brokerage option, Equitable Advisors shall not be required to take such stock or
brokerage options into account in making any of its determinations or recommendations. The plan
sponsor shall retain sole fiduciary responsibility with respect to such company stock or self-directed
brokerage options.
The ERISA Fiduciary Services provided will be based upon the information provided to Equitable Advisors
by the plan sponsor, including but not limited to the investment options available under the qualified plan
platform. The plan sponsor will agree to review at least annually any changes in the investment options
that are available under the qualified plan platform or in the demographic or other information previously
27
September 2026
provided to Equitable Advisors regarding the qualified plan. The plan sponsor must advise Equitable
Advisors of such changes promptly to allow the Company to fulfill its fiduciary duty to the client and
effectively serve its needs. In providing the ERISA Fiduciary Services to Plan Sponsors, Equitable Advisors
and its IARs may utilize software and other tools operated by the Retirement Plan Advisory Group
None of Equitable Advisors, its affiliates, or its IARs are affiliated with or
RPAG
under common ownership, control, or operation with RPAG, Fi360, or Plan Tools.
Arrangements for ERISA Fiduciary Services may include the opportunity for participants to receive, at their
sole discretion, Optional Services as described above in the section on Retirement Plan Investment
Advisory Support Services and in Corporate Financial Planning. No investment advisory relationship
qualified plan nor any qualified plan participant will be obligated at any time to purchase any additional
products or services (including Optional Services) through Equitable Advisors, its affiliates, or other
decisions under the qualified plan endorses or is sponsoring Equitable Advisors or its IAR about the
provision of Optional Services to participants. The selection of an Equitable Advisors IAR to provide
Optional Services is solely the decision of the qualified plan participant.
Equitable Advisors' IARs may perform joint work or receive referrals from other Equitable Advisors IARs.
agreements with clients for ERISA fiduciary services do not include these IARs, who may
The
work separately with individual plan participants, including the provision of advice regarding their
investment alternatives at retirement or separation.
This Brochure also constitutes the disclosure required to be provided to plan sponsors under ERISA Section
408(b)(2) and the DOL Regulations issued thereunder. The fee range charged for ERISA Fiduciary Services
and other important information relating to the fees for ERISA Fiduciary Services and Optional Services is
Fees and Compensation. IARs generally receive approximately 40 90% of advisory
provided in Item 5
fees received by Equitable Advisors with respect to ERISA Fiduciary Services, the same range as the
.
Equitable Advisors and/or its IARs may reimburse plans or otherwise defray the costs for expenses such
as mailings and/or other administrative expenses.
In addition to the services described above, in limited circumstances, certain Equitable Advisors IARs have
entered into joint work arrangements whereby such professionals, acting as investment adviser
representatives, but not ERISA fiduciaries, refer plans to other Equitable Advisors IARs who are
credentialed to act as ERISA fiduciaries as part of the Retirement Plan Consulting Services program. In
such instances, the ERISA credentialed IAR serves as the primary client contact. The referring IAR receives
initial and ongoing compensation for the referral. Please contact your IAR for more details.
In assisting plan sponsors with the selection of plan investment options, IARs may choose to include
certain funds that are affiliated with Equitable Advisors, such as 1290 Funds or AllianceBernstein (AB)
Funds, or variable annuity products manufactured and/or distributed by Equitable Advisors or its affiliates.
In assisting plan sponsors with selection of plan service providers and platforms, IARs that are credentialed
to act as ERISA fiduciaries may propose a qualified plan platform that is manufactured by an affiliate of
AR 360
Vision with recordkeeping and administrative services also provided by Equitable affiliates. In those
events, there is an incentive for the IAR to recommend the product issued or service provided by the
28
September 2026
affiliate even where the IAR does not directly benefit. This conflict is addressed through disclosure here,
and the fact that the IAR does not benefit directly from such recommendations. The IAR and Equitable
Advisors intend to comply with the provisions of applicable Prohibited Transaction Exemptions issued by
the DOL and clearly describe the conflicts of interest that are posed by selecting a product affiliated with
Equitable Advisors. Plan sponsors should carefully review all disclosures and consider the potential
conflicts prior to making the decision to select the applicable program for their plan.
F.
Assets Under Management
As of March 31, 2026
$47,255,793,924.
This calculation only includes assets in SAM accounts and other limited arrangements in accordance with
It does not include any of the assets invested with any of the TAMPs or in other LPL Programs (other than
SAM) described above. Of the regulatory assets under management amount, $24,784,640,932 was
managed by us on a discretionary basis, and $22,471,152,992 was managed on a non-discretionary basis.
US Dollar Amount
Number of Accounts
Discretionary
Non-Discretionary
$24,784,640,932
$22,471,152,992
47,356
51,666
Total
$47,255,793,924
99,022
Item 5
Fees and Compensation
The following discussion generally describes how Equitable Advisors and its IARs are compensated for the
advisory services we provide our clients. Below, we also discuss other sources of compensation that the
Company and/or IARs may receive, including from third parties or in contexts outside of advisory services,
as well as the potential or actual conflicts of interest such compensation may create. See also Item 14,
below, for a discussion of additional compensation received from various sources in connection with the
advisory and brokerage services.
Disclosure as well as the GCOI,
available at https://equitableadvisors.com/legal/disclosures.
Certain registered representatives/IARs who operate
receive fees or commissions but rather are compensated by Equitable Advisors on a salary basis. These
registered representatives/IARs typically receive additional compensation from Equitable Advisors in the
form of an annual cash bonus based in part on total products and services sold. This presents a conflict of
interest similar to the brokerage conflict described above in that the IAR and Equitable Advisors benefit
from increased sales. The fees charged to the client for purchases of these products and/or services are
whether as IARs (advisory services) or as registered representatives (brokerage).
Financial Planning Services
29
September 2026
The Financial Planning Agreement will set forth the amount of the financial planning fee and the timing
and terms of its payment. The fee determined by you and your IAR will also be indicated on the fee receipt.
Your IAR will explain the fee and the factors considered in calculating the fee prior to asking you to sign
the Financial Planning Agreement. The client or the IAR may terminate the Financial Planning Agreement
at any time and for any reason. If you cancel the Agreement by written notice within five (5) business days
after the signing of the Agreement, Equitable Advisors will refund all fees paid. After that five (5) business
day period, the fee will be prorated or will be charged based on the hours billed by the IAR at the time of
notice of termination.
IARs also may offer fee-based financial planning services under your annual asset-based fee within certain
types of managed accounts. In these circumstances, the financial planning services are ongoing for the
duration of your managed account (or until otherwise agreed between the client and the IAR) and may
involve financial planning advice regarding assets outside of the managed account.
Fees for financial planning may be fixed or hourly. If fixed, the client will pay a set amount for the services.
For new financial planning clients, fixed fees may range from $250 to $25,000. Fees may exceed this limit
under certain circumstances. Thereafter, fees for follow-on reviews of a financial plan created by your IAR
generally range from $250 to $12,500. If the fee is charged hourly, the fee will equal an agreed-upon
hourly amount multiplied by the estimated number of hours. Hourly fees are negotiable and generally
be used to determine the fee.
range from $100 to $400 per hour.
Typically, the fee is determined and billed when the client executes the Financial Planning Agreement,
although generally the client has the option of paying the fee in installments.
IAR may offer
the client options to implement the plan. Should you decide to purchase products offered by your IAR(s)
to implement your financial plan rather than ongoing advisory services, your IAR will be acting in his or
her capacity as a broker-dealer registered representative and/or as an insurance agent of Equitable
Network, and you will enter into a separate agreement to cover these brokerage and/or insurance
services. In these capacities, your IAR will be representing the issuing and distributing companies, which
may be affiliated with Equitable Advisors, and, in the event of a purchase, the IAR and Equitable Advisors
(and/or its affiliates) will generally be entitled to commissions or other compensation in addition to the
fee paid by the client for the financial planning services. This presents a conflict of interest inherent in
every brokerage relationship in that the IAR and Equitable will benefit every time there is a transaction.
If you decide to enter into continued investment advisory services with the Company in implementing
your financial plan or otherwise through the TAMP referral arrangements or LPL programs the Company
offers, you will enter into an advisory agreement with the Company, become an advisory client, and will
pay a separate fee from that paid for your financial plan, as described below.
In addition to fees and possible commissions received by IARs related to fee-based financial plans, IAR(s)
under certain circumstances receive other compensation and benefits related to financial planning advice.
This presents a conflict of interest in that there is an incentive to enter into a fee-based financial planning
arrangement based on the compensat
and actual conflicts of interest to clients through documents such as this Brochure, our Form CRS, GCOI,
and other materials discussing the products and services offered. The client should consider these
additional payments and the potential or actual conflicts of interest they create carefully prior to agreeing
to a fee-based financial plan offered through Equitable Advisors. The client is encouraged to ask his or her
30
September 2026
IAR for additional information should he or she have any questions regarding these payments or the
conflicts of interest they can create.
Clients always have the option to purchase investment products that Equitable Advisors recommends
through other brokers or agents that are not affiliated with Equitable Advisors.
Asset Management Programs and Retirement Plan Services
LPL Program Fees
In investing in LPL programs, clients pay LPL an annualized Account Fee generally based on a percentage
Account Fee , a portion of which LPL pays to the Company. The Account Fee
is charged for the investment advisory services of LPL and Advisor, as well as the administrative, custody,
and clearing services of LPL. The full scope of the Account Fee and the terms of its payment to LPL in the
LPL Programs Some LPL Programs charge additional fees, as described in the relevant LPL Program
Brochure, but in each case the Account Fee in an LPL Program serves as compensation for Equitable
LPL pays Equitable Advisors a percentage of the Account Fee, and Equitable
Advisors provides a portion of that fee to your IAR, generally between 40-90%. The remainder is retained
by Equitable Advisors. The percentage of the Account Fee your IAR receives may be higher for certain LPL
Programs relative to other LPL Programs, creating an incentive for an IAR to recommend those with higher
fees. Generally, fees are deducted from client accounts. The minimum and maximum Account Fee for
each LPL Program is provided in the chart below.
The Account Fee is customarily negotiable (in whole or in part). Each LPL Program has its own maximum
Account Fee; the highest account fee in an LPL Program is 2.5%
annualized basis and is usually payable quarterly in advance. Fees for Retirement Plan Services and/or
ERISA fiduciary services can be based on assets under management or can be a fixed fee
for such Retirement Plan Services or ERISA fiduciary services
generally is 0.75%
terms.
These
LPL
Program
materials
are
available
The applicable Account Fee will be described in the Program Brochure and Account Agreement for the
applicable LPL program. A client should read the applicable Program account agreement and overall LPL
Program brochure carefully and ensure that the client understands the amount of the Account Fee, the
manner in which it is calculated, what other costs or expenses are included or excluded, and other
applicable
at
https://equitableadvisors.com/legal/disclosures.
In limited cases, as determined between the client and the IAR, the Account Fee may be calculated on a
tiered basis, becoming lower with greater assets in the LPL program account. Clients should be certain
they fully understand how such tiered fees are calculated. Such tiered fees would be reflected in the
account agreement signed by the client.
In some programs, clients are able to elect to be billed their annual advisory fee.
Certain of the LPL programs offer additional services in consideration of the program fee including order
execution, custody and clearing, which would otherwise be charged separately. Rather than paying those
transaction and other charges, they are included in the Account Fee for the Program based on the value
31
September 2026
of the assets, including the value of the no-load and load-waived mutual fund holdings. The method of
calculating and applying the Account Fee in such Programs may vary.
-
In Manager Select, which employs third-
trades may be charged to clients. Step-out trades occur when a third-
transactions fees for
party adviser executes trades other than through LPL, the custodial broker-dealer for Manager Select.
Some advisers in Manager Select frequently or regularly engage in trades through other brokers than LPL
and therefore incur and pass through to clients such step-out trade costs. For more information, see the
Manager Select Program Brochure.
As described in Item 4, above, in the SAM program the client and the IAR may determine that the IAR will
pay the transaction costs incurred in the SAM account, rather than the client paying such costs. When the
IAR bears the transaction costs of a SAM account, the overall fee to the client may be higher than it
otherwise would be to account for such costs which will be borne by the IAR. This arrangement can create
a conflict of interest in incentivizing an IAR to trade less in a client account or to prefer lower-fee options,
as described above in Item 4. The IAR would be financially incentivized to select to pay transaction costs
if it is able to minimize trading costs such that the additional fee charged, if any, is greater than such costs.
If contemplated, clients should discuss such arrangements with their IAR to fully understand the terms.
Note that LPL requires that clients use LPL as exclusive custodial broker in the SAM program; trades are
executed though LPL and step-out trades are not permitted. Equitable Advisors monitors execution of
trades in SAM in reviewing whether the program remains in the best interest of clients.
TAMP Fees Paid to Equitable Advisors
In its TAMP referrals, Equitable Advisors receives an ongoing payment from the advisory fee the referred
investor pays to the TAMP. The TAMP remits a portion of that amount to the Company, and the IAR
receives a portion. This payment generally continues for as long as the referred investor remains a client
of the TAMP, subject to the terms of the applicable referred agreement with the TAMP. This fee paid to
Equitable Advisors does not increase the fee paid by a referred investor relative to any other client of the
TAMP. The amount and terms of the fee are paid pursuant to the terms of the referral agreement
between Equitable Advisors and the TAMP. The terms of this fee are discussed in the TAMP program
documents and the client agreement between the TAMP and the referred investor.
Minimum and Maximum Equitable Advisors Compensation Chart
This chart does not include other possible fees, depending on the LPL Program or TAMP program, only
the minimum and maximum portion that may be paid to Equitable Advisors. As a result, when other fees
are considered in the aggregate, your overall fee would generally be higher than what is presented below.
Product
ACM Model Separate Account Strategies
ACM Private Account Strategies
AssetMark GMS
AssetMark Privately Managed Portfolios
AssetMark PMAS (IMA)
AssetMark PMAS (CMA)
AssetMark PMAS (PRX)
AssetMark ETF Portfolios
Min
0.50%
0.50%
0.50%
0.50%
0.50%
0.50%
0.50%
0.50%
Max
2.50 %
2.50%
1.50 %
1.50%
1.50%
1.50%
1.50%
1.50%
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September 2026
AssetMark Funds
Other Fund Strategies
Nationwide Tactical Strategies
IAM Portfolio
IAM Hybrid Portfolio
ETF Portfolio
Advisor One Protection (formerly CPM 3)
Master Manager Strategy Portfolio
Wealth Accumulation
AdvisorOne Portfolio
Product
AssetMark No-Load Mutual Funds
AssetMark No-Load Mutual Funds
AssetMark GPS & GPS Select Solutions
Trek Financial
Boyd Watterson
Brinker Destinations
Brinker Personal Portfolios
Brinker Core Asset Manager
Brinker Retirement Plan Services (including Retirement Plan Services Plus)
CLS
CLS
CLS
CLS
CLS
CLS
CLS
LPL Optimum Market Portfolios Advisory (OMP)
LPL Strategic Asset Management
LPL Manager Select
LPL Model Wealth Portfolios (MWP)
LPL Personal Wealth Portfolios (PWP)
Mariner Wealth Advisors
PlanMember Elite
PlanMember OPTIFUND Managed Account Option
Signature Investment Advisors
SIMC MAP (SEI)
SIMC iMAP (SEI)
SIMC MF Asset Allocation (SEI)
The Pacific Financial Group
Min
0.50%
0.50%
0.50%
0.50%
0.20%
0.50%
0.50%
0.50%
0.30%
0.20%
0.50%
0.50%
0.50%
0.50%
0.50%
0.50%
0.00%
0.00%
0.00%
0.00%
0.00%
0.50%
0.50%
0.55%
0.50%
0.50%
0.50%
0.50%
0.50%
Max
1.50%
1.50%
1.50%
1.50%
1.50%
2.50%
2.00%
2.00%
2.00%
2.00%
2.00%
2.00%
2.00%
2.00%
2.00%
2.00%
2.00%
2.50%
2.50%
2.35%
2.35%
1.50%
1.35%
1.35%
1.40%
1.50%
1.50%
1.50%
0.75%
These fees may be higher than what you might pay with other investment advisers or that you might pay
if you were investing through a traditional brokerage account.
In investment advisory accounts, neither Equitable Advisors nor the IAR is paid a sales commission for the
investments you make and transactions in your account. Certain products offered to advisory clients
advisory accounts may also be available on Equitable Advisors brokerage platform;
different fee structures would apply for transactions outside of an investment advisory account. An IAR
servicing your advisory account may, in some instances, make available investments in the IAR
as a broker-dealer or licensed insurance agent, as determined to be in your best interest. In this case, the
IAR will disclose the role in which the IAR is acting (i.e., as broker-dealer registered representative,
insurance agent, or in an advisory capacity as an IAR). Conflicts related to account type (brokerage versus
and Form CRS available at
https://equitableadvisors.com/legal/disclosures.
As discussed above and in greater detail in the applicable LPL Program brochure, in certain LPL programs
custodial fees and transaction fees are separate from the Account Fee and are paid directly to LPL as the
broker-dealer and custodian on the account. In most of the LPL Programs, custody and administration
fees are included, as discussed in the applicable LPL Program brochure. In cases where there are mutual
33
September 2026
and other fund expenses are in
funds, ETFs, BDCs, or REITs,
addition to the Account Fee and any other fees paid by the client, as described in the Program Brochure
Equitable Advisors is generally not compensated from these underlying expenses.
In certain programs (such as SAM), some funds pay 12b-1 fees to Equitable Advisors while others do not.
If the mutual fund pays Equitable Advisors 12b-1 fees in connection with assets invested in the fund in
SAM accounts, Equitable Advisors rebates those fees to the client on a quarterly basis. This removes the
potential incentive for an IAR to recommend a fund that pays 12b-1 fees over one that does not. IARs
may receive 12b-
-dealer for
sales of mutual fund shares.
In general, commissions and other compensation payable to Equitable Advisors in connection with the
sale of investment or insurance products and services are comparable to those charged by other full-
service firms for the same products and services. In some cases, similar products or services may be
available from other sources at a lower fee or commission or without a fee or commission (which may
have the effect of lowering the cost to the customer and/or increasing the return on the product).
Some IAR
loan often made when an experienced IAR joins Equitable Advisors. An IAR is not required to pay back the
loan if the IAR remains with Equitable Advisors for a certain period and/or maintains a certain level of
business production. LPL reimburses Equitable Advisors under certain circumstances for a portion of the
amounts of such loans to IARs. This creates a potential or actual conflict that is addressed through this
disclosure and by the fact that the business production requirement is not tied to certain products.
Equitable Advisors and IARs may receive other compensation from LPL or, in the case of an IAR, from LPL
or Equitable Advisors, such as bonuses, awards or other things of value. Under certain circumstances, LPL
provides reimbursement of fees that Equitable Advisors or its IARs pay to LPL for administrative services.
Pursuant to the agreement between them, LPL pays Equitable Advisors an amount, in addition to a
percentage of Client's Account Fee, based on the current market value of all client assets that Equitable
Advisors maintains in LPL advisory programs. LPL pays this from the Account Fee it retains, and it is in
addition to the amount otherwise paid to Equitable Advisors for its services. Payment of this amount does
not result in any higher or additional client fees. Therefore, Equitable Advisors (and potentially, indirectly,
IARs) receive a greater financial benefit if more client assets are invested in LPL Programs. Generally, the
amount of compensation that Equitable Advisors receives from LPL is more than what Equitable Advisors
and its IARs would receive if the client participated in programs of other investment advisers or paid
separately for investment advice, brokerage, and other client services. Therefore, Equitable Advisors and
its IARs at times have a financial incentive to recommend an LPL Program account over other programs
and services.
As noted above, we disclose potential and actual conflicts of interest as well as additional information
through documents such as this disclosure document, our Form CRS, our GCOI, and other materials
discussing the products and services offered, including but not limited to any LPL Program brochure, TAMP
program materials, and other related materials. In TAMP investments, investors should carefully review
the conflicts and compensation disclosure in applicable program materials and the Form ADV Part 2A of
the relevant TAMP, which will be provided to investors considering such an investment at or prior to their
entering into a client agreement with the TAMP. Form ADV Part 1A and Part 2A for such TAMPs can be
located on
adviserinfo.sec.gov.
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September 2026
For additional information on other compensation that Equitable Advisors and its IARs may receive in
connection with providing advice to clients, please see Items 10, 11 and 14 of this Brochure.
Depending upon the program and other factors, IARs generally receive approximately 40 to 90% of
advisory fees received by Equitable Advisors.
In addition, there are transaction costs charged by the broker-dealer for executing trades that may or may
not be included in the advisory fee, depending on the program. For example, in Manager Select, costs
related to step-out trades will not be included in the wrap fee for the program. Information relating to
such costs are set forth in the TAMP materials or LPL Program brochures, as well as the account opening
documentation relating to each program. Please ask your IAR if you would like details regarding the
charges associated with any LPL Program, TAMP program or investment or insurance product presented
to you by your IAR.
Item 6
Performance-Based Fees and Side-By-Side Management
Equitable Advisors does not charge any performance-based fees on client accounts (i.e., fees based on a
share of capital gains in, or capital appreciation of, the assets of a client account).
Item 7
Types of Clients
Equitable Advisors provides investment advice to individuals, trusts, estates, charitable organizations,
banks or thrift institutions, corporations and other business entities, and pension and profit-sharing plans.
Each TAMP program and LPL program has its own minimum account size, but the minimums do not vary
based on the type of client. Please refer to the applicable LPL Program brochure or the applicable
Form ADV Part 2A, or equivalent program brochure, for details regarding the minimum account size for
each program or contact your Equitable Advisors IAR.
As noted in Item 4, Equitable Advisors has certain liquid net worth and other minimum requirements that
must be met before an IAR can recommend alternative investments in client SAM accounts (which apply
equally in recommendations in the
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
and investment strategies that IARs may use when developing a financial plan, formulating investment
advice, or managing assets.
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September 2026
The principal source of information used by Equitable Advisors to prepare financial plans is the
information provided by clients, including personal data, assets and liabilities, income expectations,
assumed rate of inflation and return on assets, long term and short-term financial goals, risk tolerance
and other relevant data. IARs use certain Company-approved tools as well in crafting and presenting
financial plans. Additionally, to prepare some financial plans, the staff at the Equitable Advisors Financial
Planning Team may consult from time to time with other employees (some or all of whom may be
employees of Equitable Advisors or its affiliates) having legal, accounting, or actuarial training to help
develop or review financial planning advice.
With regard to investment advisory services, Equitable Advisors subscribes to various market and
investment publications and services directly or indirectly through LPL. Equitable Advisors also analyzes
the prospectuses and offering memoranda of mutual funds, unit investment trusts, direct participation
programs, variable annuities, variable life insurance and other life insurance policies in developing and
evaluating investment and/or planning recommendations. National conventions, professional meetings,
membership in industry organizations such as the International Association for Financial Planning and the
Investment Company Institute also serve to provide Equitable Advisors with continuing access to the
practical experiences of others and current developments.
Equitable Advisors and its IAR
LPL Research
-house
IARs with access to
investment research and advice, market and economic commentary, performance reporting and
recommendations, and portfolio management tools and services, which cover topics including mutual
funds, separate accounts, REITs, ETFs, fixed income, and certain alternative investments.
Equitable Advisors' Policy Advisory Committee (the "PAC") oversees Equitable Advisors' policies. This
includes review and approval of financial planning and other tools to help ensure the presentation of
quality investment advice. New asset products and investment offerings, investment management
programs, and TAMPs
PRC.
Discussion of Risk
Investing in securities involves the risk of loss that clients should be prepared to bear, including loss of
principal invested. Clients must be prepared to bear such investment losses. Understanding the type of
risk, is a key component of the investment decision making process. Risks associated with specific
investments and investment types are described in detail in the prospectus or other product offering
documentation for those investments, and more general risks are set forth in the TAMP materials or LPL
Program brochure for each investment program.
Programs, Compensation and Conflicts Disclosure,
and GCOI disclosure, available at
https://equitableadvisors.com/legal/disclosures. These materials expand upon and address conflicts the
Company and IAR face in performing the services described herein.
The primary risk involved in financial planning services stems from the possibility that the financial
information and assumptions (such as assumptions regarding future market behavior) used in connection
with developing the financial plan are or will prove to be inaccurate. Such inaccuracy could result in the
objectives and financial needs
implementation of the plan in a manner such
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September 2026
are not met. Furthermore, even if the financial plan is appropriate, the plan may not be implemented
appropriately.
As discussed in Item 4
Advisory Business, for asset management programs other than SAM, Equitable
IARs do not recommend securities; rather, they work with clients and recommend the advisory
programs and models of third-party advisers -- the TAMPs
and the LPL Programs. As with all such
programs, investments are subject to market risk, will fluctuate, and may lose value. Asset allocation does
not guarantee a profit or protection against loss.
As noted above, TAMPs offer investment advisory programs. Equitable Advisors serves as an investment
adviser in referring clients to these programs in the Client Handoff arrangement, and the third party serves
as the principal sponsor and an investment adviser. These programs may clear through or retain broker-
dealers other than Equitable Advisors or LPL Financial.
As discussed, investing in securities involves the risk of loss that clients should be prepared to bear. The
types of risk vary depending on the type of securities and investment advisory programs in which a client
participates and are described in their respective offering documents and program materials.
Item 9
Disciplinary Information
Equitable Advisors is dually registered as an investment adviser and broker-dealer. As such, it is subject to
oversight and regulation (and potential disciplinary action) by the SEC and FINRA (the self-regulatory
agency that regulates broker-dealers). The following are summaries of regulatory actions against the
Company during the past ten years. Additional details about the Company or these matters can be
Investment Adviser Public
http://www.finra.org/Investors/ToolsCalculators/BrokerCheck, or the
Disclosure website at http://www.adviserinfo.sec.gov.
In an order dated May 2, 2019, FINRA alleged that the Company distributed documents that did
not accurately represent the credit quality of certain bond funds offered within group annuity
contracts for 401K retirement plans. The findings stated that certain enrollment forms,
investment options attachments, and other documents that were created by the
affiliated life insurance company and distributed to retirement plan sponsors inaccurately
represented that certain bond funds were investment-grade when, in fact,
findings also stated that the
supervisory systems and written supervisory procedures
compliance with relevant FINRA rules in that
the Company did not have supervisory systems or
description of the credit quality of bond funds that its insurance affiliate distributed to plan
sponsors. The Company, without admitting or denying the findings, consented to an Acceptance,
Waiver and Consent with FINRA and was censured, fined $600,000, and required to send
corrected disclosures to all affected plan participants and pay restitution to plan participants in
an amount totaling $172,461.33.
In an order dated March 11, 2019, the SEC charged the Company with willful violations of Sections
206(2) and 207 of the Advisers Act, alleging that from January 1, 2014 through August 8, 2014,
the Company at times purchased, recommended, or held for advisory clients mutual fund share
classes that charged 12b-1 fees instead of lower-cost share classes of the same funds for which
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September 2026
the clients were eligible, and failed to adequately disclose the conflicts of interest inherent in such
recommendations. Without admitting or denying the findings, the Company consented to the
imposition of a cease-and-desist order, censure, undertakings, and payment of disgorgement and
pre-judgment interest to affected clients in the amount of approximately $1,134,152. The SEC
self-reporting of this matter in connection with the Share Class Selection
noted the
Disclosure Initiative and the
certification of completion of substantially all of the
undertakings the SEC required in connection with the order. The SEC did not impose a civil
monetary penalty.
Item 10
Other Financial Industry Activities and Affiliations
through your
acting as an investment adviser, as described in this
Equitable Advisors
Brochure, and as a broker-dealer offering investment products and services (including variable insurance
products) to its clients. In its capacity as a broker-dealer, Equitable Advisors distributes mutual funds, unit
investment trusts, and variable life insurance and annuities, and offers brokerage and other services for
general securities as an introducing broker, with LPL acting as clearing broker and maintaining custody of
client assets. For additional information regarding our brokerage business, please see Item 12 below, our
Form CRS, and GCOI, available
IAR or on our disclosure website at
https://equitableadvisors.com/legal/disclosures.
For execution and clearing of brokerage transactions in its role as introducing broker-dealer, Equitable
Advisors maintains a clearing arrangement with LPL. In the LPL programs, LPL serves as the exclusive
broker-dealer.
Fees and Compensation above for a discussion of the compensation and
With limited exceptions, th
brokerage business and may also be licensed insurance agents (life, health, casualty, long-term care,
annuities, variable life, etc.). When appropriately licensed, Equitable Advisors' IARs usually offer variable
and traditional life insurance and annuity products of Equitable, Equitable Life and Annuity Company, and
numerous other unaffiliated life insurance companies, in their capacity as insurance agents associated
with Equitable Network, an insurance agency affiliate of Equitable Advisors. Please refer to Item 4
Advisory Business and Item 5
conflict of interest implications of these various relationships.
file with
the
SEC on
its
Several companies affiliated with Equitable Advisors are also registered investment advisers. For
information regarding their investment advisory business, please refer (where applicable) to each Form
ADV on
Investment Adviser Public Disclosure website
http://www.adviserinfo.sec.gov/. These related persons are as follows:
AB CarVal Investors L.P., File No. 801-71932;
AB Custom Alternative Solutions LLC, File No. 801-60159;
AllianceBernstein L.P., File No. 801-32361;
AllianceBernstein Corporation, File No. 801-39910;
Alliance Corporate Finance Group Incorporated, File No. 801-43569;
AllianceBernstein Holding L.P., File No. 801-32361;
AB Private Credit Investors LLC, File No. 801-80389;
Sanford C. Bernstein & Co., LLC, File No. 801-57937;
Equitable Investment Management Group, LLC, File No. 801-72220;
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September 2026
39177;
PlanMember Securities Corporation, File No. 801
PlanMember Asset Management Corporation, File No. 801-111678;
AB Broadly Syndicated Loan Manager LLC, File No. 801-119242;
Bernstein Institutional Services, LLC, File No. 801-129468; and
CarVal CLO Management LLC, File No. 801-131161.
Note that the foregoing do not include registered advisers that will become affiliates after the EQH
board of directors and
stockholders but is not expected to be effected until later in 2026.
EIM is the adviser to certain proprietary mutual funds known as the 1290 Funds which IARs may
recommend to clients in the SAM Program and, as noted in Item 4 above, is available as a Strategist that
IARs may recommend to clients in the MWP program. The 1290 Funds are registered investment
companies under the 1940 Act and offered by prospectus. Equitable Advisors IARs may recommend the
1290 Funds within certain advisory products (such as SAM accounts) as well as through its brokerage
platform. Different price structures apply depending upon how the funds are purchased and which class
is selected.
outside investment adviser
Additionally, in limited instances, Equitable Advisors has entered into written agreements with investment
advisers who are not affiliated with Equitable Advisors, but which are owned and/or operated by one or
more Equitable Advisors registered representatives
ORIA .
Ordinarily, these persons are solely registered representatives of Equitable Advisors in its brokerage
business, and their advisory services are conducted through the ORIA. In certain limited cases, the
principals, owners, and investment adviser representatives of these outside investment advisers are
dually registered as investment adviser representatives of Equitable Advisors and the ORIA. Certain of
the purchase of brokerage or securities products through Equitable Advisors. Under certain
circumstances,
and other Equitable
Advisors registered representatives and IARs are permitted to refer prospective investment advisory
clients to the ORIA.
Code of Ethics, Participation or Interest in Client Transactions, and
Item 11
Personal Trading
Code of Ethics
Equitable Advisors maintains a Code of Ethics that applies to all of our advisory
in
accordance with Rule 204A-1 under the Advisers Act, which includes our IARs. The Code of Ethics and
advisory supervised persons in
other policies and procedures
understanding their obligations under applicable law and regulation, to detect and prevent violations of
and IARs satisfaction of their fiduciary duty to clients, to
the securities laws
ensure disclosure of, avoid, address, and/or mitigate
,
and prevent or detect other practices that may be inappropriate, illegal, or improper.
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September 2026
As described below, the Code of Ethics also assists the Company in monitoring the personal securities
under the Advisers Act (generally,
our IARs and others who are privy to client trading and account information). A copy of the Code of Ethics
is available for review on our disclosure website at https://equitableadvisors.com/legal/disclosures.
Alternatively, you can request a copy of the Code of Ethics from your IAR.
Participation or Interest in Client Transactions and Personal Trading
Equitable Advisors and our IARs do not recommend specific securities to clients in connection with our
investment advisory services
selected by the third-party program sponsor (LPL or a TAMP, or a subadvisor) that the client has chosen,
with the help of his or her IAR, with which to invest. In the TAMP programs, the TAMP or third-party
advisers which the TAMP consults select the investments or create and adjust model portfolios
implemented by the TAMP. In all LPL Programs save for SAM, underlying strategists, managers, or LPL
Advisor Sleeve, certain
, with LPL
Equitable Advisors IARs may create and manage a model portfolio
determining implementation of the portfolio with discretionary authority over the client account.
For the SAM program, the IAR recommends specific securities to clients, which may include funds
managed by AB and/or EIM, affiliates of Equitable Advisors, as well as insurance products offered through
our affiliate, Equitable Network (in their capacity as licensed insurance agents of that affiliate). However,
IARs may not recommend the purchase or sale of any individual securities of our publicly traded parent
company, Equitable, or individual securities of any Equitable affiliate, including AB. The definition of
, and derivative
instruments, including, without limitation, ADRs, bonds, and notes. Further, when an IAR exercises
discretionary authority over a SAM account, the IAR cannot exercise such authority with respect to
insurance products issued by, or funds managed by, our affiliates (e.g., Equitable-sponsored variable
annuities, 1290 Funds managed by EIM (discussed below), etc.).
In SAM accounts, IARs may recommend the purchase or sale of mutual funds in the 1290 family of funds
(managed by EIM) or funds managed by AB. An affiliate of Equitable Advisors, 1290 Asset Managers, is
the investment adviser to the 1290 funds and receives a management fee for its advisory services to the
funds. This affiliate benefits financially when more assets are invested in the 1290 funds. Alliance
Bernstein, L.P. is the investment adviser to the AB Funds and is also an affiliate of Equitable Advisors.
Alliance Bernstein, L.P. also benefits financially as additional assets are invested in the AB Funds. Because
your IAR is an associate of Equitable Advisors, he or she has an indirect incentive to recommend a 1290
fund or AB Fund over another mutual fund family. This conflict of interest may affect the ability of your
IAR to provide clients with unbiased, objective investment advice concerning the selection of mutual funds
for the account. Note, however, that Equitable Advisors takes steps to mitigate these conflicts of interest.
Equitable Advisors does not compensate your IAR in a manner that is based on his or her
recommendations of the 1290 funds or AB funds
is not determined based
on assets invested in the 1290 funds or AB funds, and Equitable Advisors does not compensate your IAR
based on the recommendation of a particular mutual fund of the same class of mutual fund shares over
another.
In addition, the IARs ability in the SAM program to recommend specific securities may result in situations
where (i) an IAR personally invests in the same securities that are recommended to clients; or (ii) an IAR
buy or sells securities for the IAR
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September 2026
IAR
recommended to a client. Conflicts of interest could arise in such instances, including the possibility that
the IAR
through client recommendations to influence the price of a security the IAR is invested in or contemplating
buying or selling for the IAR
We address these conflicts of interest in a number of ways including by disclosing them to you. As noted
above, our Code of Ethics regulates the personal securities trading activities of our IARs that we have
deemed to be access persons. Our Code of Ethics requires our access persons to maintain their personal
securities accounts with Company-approved broker-dealers. These broker-dealers provide Equitable
Advisors with a
These reports are analyzed by
our Personal Brokerage Accounts Group to compare an IAR s personal trading to trading in client accounts
, among other things).
to identify issues (
We will take appropriate action to remedy any circumstance in which
trading may affect
the client or improperly uses client information or transactions to benefit the IAR, including by reversing
the trades so that the client receives a more favorable price.
IPO
Our Code of Ethics also prohibits access persons from acquiring for their own account securities in any
requires access persons to obtain specific written approval prior to
acquiring for their own account any securities in a limited offering (e.g., a private placement of securities).
These prohibitions are intended to help address potential and actual conflicts of interest that could arise
relating to allocation of IPO and other limited offerings of securities to our clients.
IARs may aggregate their personal trades with those of clients to obtain a better price. However, in such
cases, controls are in place to prevent IARs from allocating trades or prices obtained in a manner that
favors themselves or certain clients over others. Aggregation of trades is discussed in greater detail in
Item 12 below.
Item 12
Brokerage Practices
Equitable Advisors generally does not select or recommend broker-dealers for client transactions in the
TAMP or LPL programs that the Company offers and does not itself perform brokerage services in
connection with such programs
. In a small number of TAMPs, the IAR, in working with the client
to open the TAMP account, may recommend a custodial broker-dealer from options provided by the
TAMP. The TAMPs may use that custodial broker-
the custodial broker would be more expensive. However, the TAMP or its delegated sub-adviser generally
may use another broker-
-
-dealer. The costs of such step-out trades are not included in
the wrap account fee and will be separately charged to the client.
Certain of the TAMPs may use LPL as broker-dealer to execute all or a portion of the trades for their
client transaction,
custody, and brokerage policies and practices and any conflicts it may face in this area.
In LPL programs, LPL serves as the broker-dealer for holding custody of client assets and executing
transactions. When an IAR acts as portfolio manager in SAM accounts, LPL requires that the client appoint
LPL as the sole and exclusive broker-dealer for transactions in the SAM account agreement. Clients cannot
41
September 2026
select their own brokers in the LPL programs, including SAM. The Company
duty to clients.
We do not utilize any soft dollar arrangements, use client brokerage commissions to obtain research or
other products or services, or permit a client to direct brokerage through a specified broker-dealer (unless
provided as an option by an asset management program). For more information regarding the selection
of broker-dealers for client transactions, custody, and best execution, please refer to the respective
Form ADV Part 2A and/or account agreement.
In the SAM program, Equitable Advisors IARs place
either on a
discretionary or non-discretionary basis. The IAR may aggregate orders and allocate the price among all
applicable clients, so that all clients may receive improved pricing. This will generally be done only for
discretionary accounts, as Equitable Advisors does not permit its IARs to exercise time and price discretion,
and thus they are unable to hold client-approved transactions in non-discretionary accounts from the
market. An IAR may determine not to aggregate transactions, for example, based on the size of the trades,
the number of client accounts, the timing of the trades, the liquidity of the securities, and/or the
discretionary or non-discretionary nature of the trades. If an IAR does not aggregate orders, some clients
purchasing securities around the same time may receive a less favorable price than other clients. This
means that this practice of not aggregating may cost clients more money. LPL is also an investment adviser
in the SAM program, and is the broker-dealer for those accounts, but it generally does not aggregate
orders unless instructed by Equitable Advisors.
In aggregating orders through LPL, an IAR must set the allocation of the aggregated trade prior to entering
it and cannot change that allocation. Trades are generally allocated pro rata. This control seeks to prevent
IARs from allocating an aggregated trade in a way after time for price discovery that favors one client over
another, or the IAR
trades aggregated with those of clients
Item 13
Review of Accounts
Financial Planning
time the plan is prepared and terminate upon delivery of the plan. Thus, we do not typically initiate any
periodic or other reviews of financial plans we deliver to clients except insofar as such clients are receiving
investment advice related to their financial plan pursuant to an asset-based fee advisory account. As
noted in Item 4, above, certain of our IARs will offer financial planning as part of a broader advisory
account relationship. However, clients are encouraged to review their financial plan periodically to take
account of changes to their financial circumstances, goals, market conditions, or other factors. Although
not obligated to do so, clients may engage Equitable Advisors to assist in reviewing and updating a
financial plan, in which case the client will enter into a new financial planning agreement with Equitable
Advisors and pay a fee for the review and updating services. The review may follow the same general
format as the original plan or may focus only on specific issues of concern to the client. The review and
fees charged will follow the same guidelines and procedures described throughout this Brochure for our
financial planning activities. See Items 4 and 5 for a specific discussion of financial planning fees.
Asset Management Programs: IARs monitor and review advisory accounts on an ongoing basis and as
needed based on the nature of the account, the strategy employed, and other factors. IARs servicing Client
Referral Arrangement TAMP accounts and LPL Program accounts (including SAM and MWP), described in
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Advisory Business, are required to meet with the client at least annually, if not more frequently.
Item 4
At this review, the IAR and the client
and/or investment needs, among other factors, which may affect their risk tolerance, time horizon,
financial goals, and/or investment objectives. These reviews are not conducted in Handoff Referral
Arrangement TAMP accounts.
SAM accounts may also be required to be reviewed upon triggering certain thresholds in the Proactive
Surveillance system the Company employs to assist in monitoring accounts. This system monitors SAM
accounts for various metrics that indicate the potential need for rebalancing or other servicing, and
produces alerts to the IAR and supervisory personnel when triggered. Alerts are issued for breaching
certain thresholds or limitations around investment or cash concentration, account inactivity, and other
factors.
From time to time, certain advisory account balances may decline below the stated minimum for the
relevant program. Consistent with our fiduciary duty to our clients, we will periodically review those
accounts to determine if it is appropriate to continue within the advisory program. The review will
determine the cause of the decline and will inform
next steps, which would include the IAR
confirming that the account type (e.g., brokerage versus advisory) and program are still suitable for and
in the best interests of the client.
Regular Reports
Financial Planning
additional regular reports are typically provided to financial planning clients.
Investment Advisory Programs: Most of the investment advisory programs we make available to our
clients provide, at a minimum, quarterly reports to the client. However, since the vast majority of the
TAMPs and LPL - the reports will be produced
programs are sponsored by third party investment advisers
ERISA Fiduciary Services
sponsors, periodic reports will be provided to the qualified plan sponsor. These reports will provide
updated information on the investment options within the plan, to aid the qualified plan sponsor in
monitoring the selected options.
Important Note Regarding Consolidated and Performance Reports, and Proposal Tools:
Our IARs may provide clients with consolidated financial and/or performance reports, as well as
investment proposals created using tools owned and operated by third parties including Investigo, a
division of Broadridge, eMoney Advisors, LLC, AssetMap, Envestnet MoneyGuide, PlanLab, and
ClientWorks (provided by LPL). In some cases, TAMPs make their proprietary proposal tools available to
IARs in referring investors to the TAMPs. These reports are provided for information purposes only and as
a courtesy to the client.
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Accuracy of the information contained in a consolidated or performance report is not guaranteed. Clients
their account custodian. Source documents may contain notices, disclosures and other important
information and may also serve as a reference should questions arise regarding the accuracy of a
consolidated or performance report. Differences in reporting times for various assets (including those
held away) may result in differences between an Equitable Advisors report and a source document. Clients
should compare source documents to any reports received and contact their IAR immediately if
discrepancies occur. In addition, clients should carefully read the disclosures included on any report or
proposal they receive, particularly where the report or proposal contains hypothetical performance
information regarding past or future investment performance. For more information regarding proposal
our disclosure website at https://equitableadvisors.com/legal/disclosures.
instances, held away assets may be non-verifiable by us and may not be covered by SIPC protections,
depending on the nature of the custody arrangement and the custodian. These reports may also include
assets that are difficult to value accurately, such as closely held business or partnership interests or
collectibles, and which may also be held away. We have no obligations with respect to these assets, and
no independent effort has been made to validate their values. Nothing in a report should be construed
as evidence of any opinion or guarantee of the accuracy or reasonableness of any such values.
Item 14
Client Referrals and Other Compensation
Client Referrals
Inbound Referrals to the Company by Third Parties
endorsement
in exchange for compensation. We structure such referral arrangements in accordance with the
Marketing Rule under the Advisers Act and other applicable federal and state laws as paid endorsements.
Clients referred to the Company will receive disclosure at the time of the endorsement or referral that
will describe the arrangement, note whether the referring party is a client of Equitable Advisors, set out
the compensation we pay to the referring party, and describe any other conflicts of interest. The Company
reviews any materials that contain an endorsement prior to use by the promoter and maintain records of
the signed disclosure documents provided by the referred client.
Equitable Advisors entered into referral agreements where it receives client referrals from ORIAs, defined
in Item 10 above, banks, credit unions, trade groups, and associations. As discussed in Item 10, certain
ORIAs offer financial planning services and, after delivery of the financial plan, offer securities products
and/or advisory services as EQA registered representatives or IARs in implementing the financial plan.
When the Company receives referrals from such entities, it pays compensation which may take the form
of a percentage of the overall advisory fee the Company receives on an ongoing basis, a one-time
payment, or a fixed periodic fee for the arrangement. The referring party promoting or endorsing
Equitable Advisors has an incentive to refer clients to the Company because of the compensation received,
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September 2026
rather than based exclusively on the needs of the referred party. Absent an advisory or other relationship
between the promoter and the referred investor, such referring parties do not owe the referred investor
Equitable Advisors may enter arrangements to receive information on prospective advisory, insurance, or
sell such information as potential leads. They do not match persons providing information with financial
firms.
Outbound Referrals to TAMPs and Other Advisers
Equitable Advisors refers clients to third-party advisers, including the TAMPs, AB, its affiliate, and PSEC.
When doing so, Equitable Advisors complies with the provisions of the SEC marketing rule. At the time of
making an endorsement of the third-party firm, the IAR will provide such referred person with a disclosure
. However, this disclosure does
statement for that person to sign and return
not obligate a referred person in any way. Such a person may choose, entirely at his or her option, whether
to become an investment advisory client or not of Equitable Advisors or the investment adviser that is the
subject of the referral. Such a referred person may also choose different services and products available
through Equitable Advisors that are not investment advisory in nature, such as life insurance or securities
products.
Certain registered representatives of Equitable Advisors may also refer broker-dealer business to qualified
IARs and receive referral fees. Certain Equitable Advisors IARs may act as promoters to other investment
advisers (i.e., the TAMPs) and receive fees in that capacity. This includes certain affiliates like AB and
certain of the ORIAs.
Additional Compensation Received by the Company and IARs
Financial Support Payments
Mutual Funds. In the case of a variable product, mutual fund, or
529 plan, we urge you to carefully read the applicable prospectus/offering statement, which provides
details on the product features and any charges or costs associated with the product. Equitable Advisors
provides enhanced marketing and support opportunities to certain fund families (including affiliated fund
families such as AB and 1290 Funds) and, in return, such fund families pay financial support to Equitable
Advisors in addition to any commissions Equitable Advisors and its IARs receive for the sale of such funds
while acting as a broker-dealer.
bp
Financial support payments received by Equitable Advisors from mutual funds will generally be structured
as: (i) an annualized percentage of assets placed by Equitable Advisors into the fund (generally ranging
from 1
bps ) (0.01%) through 5 bps (0.05%)), subject to an alternative annual
minimum payment generally ranging from $10,000 through $250,000; and/or (ii) an annual flat fee
payment (up to $2 million) irrespective of assets placed by Equitable Advisors into the fund. Financial
support payments are generally not assessed with respect to assets held in mutual funds through qualified
retirement or other accounts or plans subject to ERISA.
To view a list of fund families that provide Equitable Advisors with additional financial support
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September 2026
IARs and on our disclosure
Principles of Investing brochure, which are available from
website at https://equitableadvisors.com/legal/disclosures.
Equitable Advisors also receives financial support payments from certain mutual fund companies for
SAM and MWP Advisor Sleeve programs.
assets placed
Equitable Advisors also receives financial support payments from certain money market mutual fund
companies used in connection with cash sweep vehicles.
Financial support payments are generally not assessed with respect to assets held in asset management
programs through qualified retirement or other accounts or plans subject to ERISA. The financial support
payments (if any) are disclosed more fully in the Client Agreement, fee disclosure, and/or Equitable
Conflicts Disclosure, which as noted above is available on our disclosure website and may also be obtained
from any IAR.
Financial Support Payments
Alternative Investments. Equitable Advisors also receives financial
support payments for assets placed by Equitable Advisors in certain alternative investments, including
non-traded REITs and BDCs. Financial support payments in connection with these securities are intended
to compensate Equitable Advisors for certain marketing and other services. Financial support payments
from such companies generally range from 100 bps (1.0%) to 150 bps (1.5%) based upon total sales of the
alternative investment offering sold by Equitable Advisors. Such financial support payments are made to
Equitable Advisors from the broker-dealer managing the sales syndicate for such entities.
Financial Support Payments
TAMPs. Equitable Advisors also receives financial support
payments from certain of the TAMPs to which it refers investors or clients in addition to the portion of
the advisory fee it receives for individual referrals. Equitable Advisors currently receives financial support
payments from the following program sponsors: ACM, AssetMark, Brinker, Colony Group, PlanMember,
SIMC, and Boyd Watterson. Financial support payments from each program sponsor generally range from
1 bp (0.01%) to 10 bps (0.10%) of client assets referred to the TAMP and may be subject to a minimum
payment amount. Certain programs make payments based upon annual assets in the program, or a
combination of sales and assets under management. Alternatively, some TAMPs pay financial support
payments through a flat fee. Financial support payments are paid to the Company by the TAMP and are
not part of the fees paid by the client to the TAMP.
The financial support payments to the Company described above will not result in a higher payment to a
IAR
indirectly benefit the IAR insofar as the payments are used by Equitable Advisors to support costs related
to marketing or training.
Cash Sweep Payments. LPL shares income it receives from the cash sweep program with Equitable
Advisors. Additional information regarding cash sweep payments in connection with these programs is
ash sweep programs
clients should carefully review.
General Fees and Reimbursements from LPL. Equitable Advisors and its IARs receive
compensation as a result of clients participation in the LPL programs. In addition to the portion of the
Account Fee for its services, as discussed in Items 4 and 5 above, Equitable Advisors and IARs receive
46
September 2026
additional compensation from LPL. For example, LPL under certain circumstances provides
reimbursement of fees that Equitable Advisors or its IARs pay to LPL for administrative services. Pursuant
to the agreements between LPL and Equitable Advisors, LPL pays Equitable Advisors an amount based on
the current market value of all client assets that Equitable Advisors maintains in LPL Programs. This
amount is paid from the portion of the Account Fee retained by LPL and is in addition to the amount paid
for its services from the Account Fee and does not result in any higher or additional client fees. This
additional amount based on assets invested in the LPL Programs provides Equitable Advisors with a
greater financial benefit if more client assets are invested in LPL Programs. The amount of compensation
that Equitable Advisors receives from LPL is generally more than what Equitable Advisors and its IARs
would receive if the client participated in programs of other investment advisers or paid separately for
investment advice, brokerage, and other client services. Therefore, Equitable Advisors and its IARs
generally have a financial incentive to recommend an LPL Program account over other programs and
services.
Equitable Advisors receives an advisory reallowance fee from LPL based on a percentage of average
advisory assets under management custodied at LPL in advisory programs for which LPL is a sponsor.
Equitable Advisors provides a fee to certain Equitable Advisors IARs based on a percentage of their total
business production.
Equitable Advisors and/or its IARs receive 12b-1 fees, other transaction charges and service fees, IRA and
Qualified Retirement Plan fees, administrative servicing fees for trusts, other charges required by law, and
marketing support from certain mutual funds held in investment advisory accounts. However, 12b- 1 fees
are rebated to the client quarterly except in certain circumstances relating to the cash sweep program.
Please see the applicable LPL Program Brochure for additional information about
cash sweep
program and charges and fees paid to LPL and Equitable Advisors. Investors should also consult the GCOI
and Compensation and Conflict Disclosure.
Equitable Advisors and its IARs receive non-cash compensation from certain TAMPs, LPL, or other third-
party investment advisory program sponsors. Such compensation may include such items as gifts of
nominal value, an occasional dinner or ticket to a sporting event, or reimbursement in connection with
educational meetings or marketing or advertising initiatives. Such sponsors also pay for education or
training events that are attended by IAR
IARs face a conflict in
accepting such compensation in that it may influence their investment decisions to favor sponsors
providing it over those that do not. The Company has policies and procedures in place to monitor and
limit the amount and frequency of any such non-cash compensation and ensure they comply with
applicable law and regulation.
IARs and their managers receive higher levels of cash compensation or other incentives for recommending
issued by third parties. Among other things, they qualify for certain benefits, such as health and retirement
benefits, based solely on purchases of these proprietary products. Equitable Advisors receives
compensation from an affiliate, Equitable Distributors, attributable in part to the benefits payments in
connection with recommendations of Equitable variable insurance products in SAM accounts. In addition
to commissions or advisory fees, IARs and their managers at times receive other compensation related to
purchases of proprietary products resulting from their recommendations. For example, they may receive,
among other things, Equitable stock options and/or stock appreciation rights, allowances and other
47
September 2026
assistance with marketing and related activities, training and education, trips, prizes, entertainment,
awards, and other merchandise.
In addition, in its brokerage business, Equitable Advisors or its registered representatives receive a
.
are not paid to an IAR in advisory accounts.
equal to or in excess of $1 million and generally ranges from 25 bps (0.25%) to 100 bps (1.00%) and will
be disclosed in the prospectus or Statement of Additional Information of the mutual fund.
Accepting compensation in connection with the sale of securities or other investment products, including
financial support payments and asset-based sales charges or service fees from the sale of mutual funds,
presents a conflict of interest in that there is an incentive to recommend investment products based on
the compensation received, rather than
clients through documents such as this disclosure document, the prospectus, the LPL Program Brochures,
and other materials discussing the products and services offered. The client should consider these
additional payments and the potential conflicts of interest they create carefully prior to investing in any
securities or asset management programs offered through Equitable Advisors. The client is encouraged to
ask his or her IAR for additional information should he or she have any questions regarding these
payments or the potential conflicts of interest they create.
SEI Advisor Benefits Program
-cash benefits pursuant to a
A very
third-party loyalty program offered by SEI, a TAMP to which Equitable Advisors refers clients. Equitable
IARs who have placed various levels of
certain benefits, such as access to conferences and experts on business matters, networking events,
educational resources, business operation webinars, and other non-cash benefits. The Company does not
allow for cash payments or reimbursements of expenses by SEI in this Program (save for hotel or flight
expenses incurred in attending an SEI conference). Clients considering an SEI program should consider the
actual or potential receipt by an IAR of such benefits, which creates a conflict of interest. Clients are
Advisor Benefits Program
encouraged to speak with their IAR if they have any questions regarding
and whether the IAR participates. The Company monitors use of this program on a semi-annual basis
through information provided by SEI.
Item 15
Custody
As a general policy and practice, the Company does not have or accept custody over client assets as
defined under Rule 206(4)-
custody rule . The Company does not
have custody over client assets in referring clients to TAMP programs, nor do we select the custodial
broker-dealers used to execute transactions in such programs. Further, in LPL programs, LPL acts as broker
and custodian for the LPL Program accounts, and the Company does not have custody of client assets.
The Company is deemed to have custody of client assets in the context of the proprietary variable annuity
products offered by its affiliates and available through the SAM program. Clients can purchase two
ADV,
Equitable proprietary variable annuity products via the SAM platform: Structured Capital Strategies
and Investment Edge
ADV. Equitable Advisors does not maintain the client assets with respect to such
investments. Instead, its affiliate, Equitable Financial, has custody. As a result
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September 2026
client assets
assets, that custody is imputed to Equitable Advisors under the custody rule. This is the only circumstance
in which the Company is deemed to have custody under the Advisers Act. It undergoes an annual surprise
exam by an independent public accountant registered with the PCAOB. Also, the Company affiliate with
custody of the assets undergoes an internal controls audit and receives an internal control report on its
In connection with these annuity investments, clients should receive at least quarterly statements from
custodial statements are the official records of
statements or reports to you regarding your account, including consolidated or performance reports. Any
additional statements provided by Equitable Advisors are provided for informational purposes only. We
urge you to carefully compare the official custodial statements you receive from Equitable Financial to
any statements the Company or LPL may provide. Comparing statements may allow you to determine if
the account transactions, including deductions to pay advisory fees, are accurate. Please report any
discrepancies you identify to your IAR.
Please see our response to Item 13
Review of Accounts, above, for more information on the consolidated
or performance reports we may provide. Clients in all asset management programs other than SAM should
Form ADV Part 2A or the relevant program materials for more
refer to
information on
custodial practices, including information regarding the frequency of
statements the account custodian will provide.
Item 16
Investment Discretion
Discretionary accounts are those in which the client grants an investment adviser authorization to trade
securities without obtaining specific client consent for each transaction. In its TAMP programs and in all
but one of the LPL programs (SAM, discussed below and described in Item 4), the Company does not make
recommendations of specific securities for client advisory accounts. As a result, Equitable Advisors cannot
exercise discretionary trading. As described below, in SAM IARs may exercise discretionary authority over
client accounts when: (1) the IAR is approved by the Company to exercise discretionary authority
generally, and (2) the client has authorized discretionary authority in writing and the Company has
approved such discretionary authority with respect to
In the event the IAR exercising
discretionary authority leaves the firm or is otherwise unavailable, the Company will reassign the account
to another qualified and approved IAR to continue to exercise discretionary authority. A client may
, in which case transaction-
by-transaction approval will once again be required.
With limited exceptions, IARs are not permitted to exercise discretionary authority over SAM accounts for
clients subject to ERISA. Generally, where Equitable Advisors is authorized to act on a discretionary basis
in an account subject to ERISA, Equitable Advisors and the IAR do so as an investment manager appointed
under ERISA Section 3(38). The Company imposes certain qualification and other requirements on those
permitted to act as ERISA fiduciaries through the RPCS program, including Section 3(38) investment
managers, as discussed in Item 4 above.
In order to authorize discretionary authority over a SAM account, a client must sign a Discretion
Authorization Form providing Equitable Advisors with the authorization to place equity, fixed income, and
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September 2026
mutual fund trades on their behalf without seeking client preapproval. A IAR may not transact in certain
securities on a discretionary basis even in the case of a SAM account for which the client has authorized
discretionary trading. By way of example and not limitation, an IAR with discretionary authority cannot
use that discretion to purchase an annuity, alternative investments, or proprietary investments within a
SAM account; such investments require that the client consent to such transactions in each instance.
The Company approves IARs to manage discretionary accounts based upon experience and training,
guidelines for offering and
including training required to become familiar with
managing discretionary accounts. Prior to placing a discretionary trade, the IAR will be fully credentialed
and versed in the product being traded.
Item 17
Voting Client Securities
Equitable Advisors and its IARs do not and will not vote proxies on behalf of advisory clients, nor do we
provide advice to clients as to how or whether they should vote proxies. For the advisory programs we
or
offer through LPL and TAMPs
program brochure
proxies. In certain LPL programs, LPL or its delegate has the authority to vote client proxies; in others, the
in some cases, the TAMP or its delegate may
client retains that ability. The same is true of the TAMPs
vote proxies or, in other cases, the client will be responsible for proxies.
voting
Item 18 - Financial Information
See attached Statement of Financial Condition.
50
September 2026
[STATEMENT OF FINANCIAL CONDITION]
1
September 2026
Report of Independent Registered Public Accounting Firm
To the Board of Directors and Member of Equitable Advisors, LLC
Opinion on the Financial Statement Statement of Financial Condition
We have audited the accompanying statement of financial condition of Equitable Advisors, LLC (the
as of December 31, 2025
In our opinion, the financial statement presents fairly, in all material respects, the financial
position of the Company as of December 31, 2025 in conformity with accounting principles generally
accepted in the United States of America.
Basis for Opinion
. Our responsibility is to
The financial statement
express an opinion on the Company's financial statement based on our audit. We are a public accounting
firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are
required to be independent with respect to the Company in accordance with the U.S. federal securities
laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.
We conducted our audit of this financial statement in accordance with the standards of the PCAOB. Those
standards require that we plan and perform the audit to obtain reasonable assurance about whether the
financial statement is free of material misstatement, whether due to error or fraud.
Our audit included performing procedures to assess the risks of material misstatement of the financial
statement, whether due to error or fraud, and performing procedures that respond to those risks. Such
procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the
financial statement. Our audit also included evaluating the accounting principles used and significant
estimates made by management, as well as evaluating the overall presentation of the financial statement.
We believe that our audit provides a reasonable basis for our opinion.
New York, New York
March 2, 2026
We have served as the Company's auditor since 1999.
(1)