EQUITABLE ADVISORS, LLC

Equitable Advisors, LLC 1345 Avenue of the Americas, New York, NY 10105 (866) 283-0767, Option 2 www.equitable.com 2025 Firm Brochure (Form ADV Part 2A) This Form ADV Part 2A (this “Brochure”) provides information about the qualifications and business practices of Equitable Advisors, LLC (“Equitable Advisors,” the “Company,” or “we”). If you have any 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 States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Equitable Advisors is registered as an investment adviser with the SEC under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). 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. information about Equitable Advisors is available on the SEC’s website at Additional https://adviserinfo.sec.gov. September 26, 2025  Item 2 – Summary of Material Changes This Brochure dated September 26, 2025, 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 Security Act of 1974, as amended (“ERISA”), and the regulations thereunder. This Brochure is different from our most recent Brochure, filed as our annual amendment for 2024on March 27, 2025, in the following respects. Equitable Advisors does not consider the following changes to be material changes, but includes this discussion to show changes from the prior filed version. • Item 4 – Certain of the third-party asset managers (defined in the Brochure as TAMPs) listed in Item 4 have been recharacterized among the categories Equitable Advisors offers to reflect the nature of the referral arrangements. Also, TAMPs with which Equitable Advisors has no current referral clients and to which it has ceased making referrals have been removed to reflect that fact. • Item 4 - Information relating to our regulatory assets under management has been updated. • Item 5 – Our advisory fee chart has been updated to reflect current fee minimums and maximums paid to Equitable Advisors and to reflect the current programs offered. 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 and then Option 2 again, or by going online to the SEC’s website at https://adviserinfo.sec.gov/firm/6627 and clicking on “Part 2 Brochures.” Our Relationship Summary for Retail Investors (also known as Form CRS or Form ADV Part 3) can be found by clicking on “Part 3 Relationship Summary” on that website. information about Equitable Advisors is available via the SEC’s website: Additional https://adviserinfo.sec.gov, and on our disclosure website www.equitable.com/CRS. The SEC’s website also provides information about Equitable Advisors’ registered investment adviser representatives. ii September 2025  Item 3 – Table of Contents Item Page Item 2 – Summary of Material Changes ...................................................................................................... ii Item 3 – Table of Contents .......................................................................................................................... iii Item 4 – Advisory Business .......................................................................................................................... 1 Item 5 – Fees and Compensation ............................................................................................................... 27 Item 6 – Performance-Based Fees and Side-By-Side Management ......................................................... 32 Item 7 – Types of Clients ............................................................................................................................ 32 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 32 Item 9 – Disciplinary Information .............................................................................................................. 34 Item 10 – Other Financial Industry Activities and Affiliations .................................................................. 34 Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading .......... 36 Item 12 – Brokerage Practices ................................................................................................................... 38 Item 13 – Review of Accounts .................................................................................................................... 39 Item 14 – Client Referrals and Other Compensation ................................................................................ 41 Item 15 – Custody ....................................................................................................................................... 45 Item 16 – Investment Discretion ............................................................................................................... 45 Item 17 – Voting Client Securities .............................................................................................................. 46 Item 18 - Financial Information ................................................................................................................. 46 iii September 2025  Item 4 – Advisory Business A. Overview – Equitable Advisors and its IARs Equitable Advisors is a Delaware limited liability company formed in July 1999. The Company is registered with the SEC as (1) an investment adviser under the Advisers Act, and (2) a broker-dealer under the Securities Exchange Act of 1934, as amended (“Exchange Act”), and, as a registered broker-dealer, the Company is a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”). Equitable Advisors is an indirect wholly owned subsidiary of Equitable Holdings, Inc. (“EQH”), a public company under the Exchange Act, the common stock of which 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. AllianceBernstein (“AB”) is the brand name of the global asset management and broker-dealer subsidiaries of AllianceBernstein L.P., which provide investment management and research services worldwide to institutional, high-net-worth, and retail investors. As an investment adviser, Equitable Advisors and its investment adviser representatives (in such capacity, “IARs”) owe a fiduciary duty to advisory clients. All of the Company’s IARs are also registered representatives in its broker-dealer business; however, many, but not all, of the Company’s registered representatives in sits brokerage business are also IARs. Many of our IARs also are licensed as insurance agents of Equitable Network, LLC, a licensed insurance company and another indirect subsidiary of EQH, and therefore is an affiliate of the Company (“Equitable Network”). IARs act as insurance agents and act in such capacity when recommending variable annuity 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). Most, but not all, of our IARs are able to offer the full range of advisory services described in this Brochure. Equitable Advisors imposes certain baseline requirements for its professionals in serving as IARs. However, for some advisory services, Equitable Advisors requires that an IAR hold additional credentials, undergo specific training, or satisfy other qualifications before providing such services. These include, for example, providing certain financial planning services, exercising discretionary authority over client accounts in LPL’s Strategic Asset Management Program (“SAM”), 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). Therefore, not all of the Company’s IARs are able to provide all of the services described in this Brochure. In some cases, IARs not authorized to provide a given service are permitted only to refer clients to other of our IARs or to third-party asset management firms. Depending on your needs, such limitations may present a conflict of interest for your IAR. You should discuss any 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 investment advice, as they deem appropriate. Additionally, Equitable Advisors’ IARs do not provide investment advisory services to federal, state, or local governmental entities. 1 September 2025  This Brochure discusses conflicts of interest that are relevant to Equitable Advisors’ business as a registered investment adviser under the Advisers Act. Certain professional organizations may also have disclosure or other requirements that apply to individual IARs that are members of such organizations or hold a designation issued by such an organization (e.g., the Certified IARs Board). Equitable Advisors may discipline IARs for violations of the rules or ethical codes of such organizations, but is not responsible for monitoring or enforcing IARs’ compliance with such organizations’ requirements and specific standards of conduct. For additional information, please see Equitable Advisors’ Relationship Summary for Retail Investors (“Form CRS”), General Conflicts of Interest Disclosure (“GCOI”), Third-Party Compensation and Conflicts of Interest Disclosure (“Compensation and Conflicts Disclosure”), and Principles of Investing brochure. For a discussion of certain risks of investment advisory programs and investments Equitable Advisors offers, see our Risks of Investing in Advisory Programs brochure. All of the foregoing materials are available on our disclosure website at https://equitable.com/CRS. Clients are, of course, always welcome to contact their IAR and request any of these materials or pose any questions they may have. B. Tailoring Our Services to a Client’s Needs We strive to tailor our advisory services to the individual needs of our clients. Prior to providing a client with any financial planning or other investment advisory services, an IAR will work with the client to mutually define the scope of the services. This process will include an exploration of the client’s values, attitudes, expectations, risk tolerance, and time horizons, as well as the client’s financial goals, needs, and priorities. In the context of its asset management services, the IAR will meet the client at least once annually to review this information with the client and update it if there are material changes. In providing financial planning advice, an IAR will work with the client to determine which assumptions should be used in developing the financial plan so that any analysis and projections included reflect the client’s views on future conditions and events. Such assumptions will also be used in providing asset management services to clients. 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 We offer two main types of investment advisory services: (1) financial planning (discussed in Section D below), and (2) asset management services (discussed in Section E below). 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. 2 September 2025  In this Item 4 – Advisory Business, we will provide more detail regarding our financial planning and asset management services. D. Financial Planning Services 1. Financial Planning Generally Our Financial Professionals may provide personal financial planning services that include education, advice, and the preparation and delivery of a written financial plan or advice that includes general 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, agreeing 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 are determined and paid is included in Item 5 – Fees and Compensation below. The financial planning 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 ongoing advice models, 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. The financial plan or advice will not include investment advice, analysis, or recommendations regarding specific securities or investment or insurance products. 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 financial planning advisory relationship ends upon the client’s acknowledgment of the written financial plan or advice. However, because our IARs are also registered representatives of Equitable Advisors in its brokerage business and licensed insurance agents of Equitable Network, they are able to identify securities and insurance products that may be suitable for implementing the plan or advice. These product-specific implementation recommendations may be prepared in a separate written document following delivery of the financial plan. Such a document is not 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 any commissions received, by the Company in his or her capacity as a registered representative of the Company’s in its capacity as a broker-dealer or as an insurance agent of Equitable Network. Thus, the IAR has an incentive to recommend that such products 3 September 2025  or services be obtained through Equitable Advisors, which is a conflict of interest in its recommendations to implement a client’s financial plan. 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, its affiliates, or other carriers. The IAR may also recommend Equitable Advisors’ asset management services in implementing the financial plan. These services are subject to a separate agreement and Equitable Advisors will receive an asset-based fee for such services. This fee raises a conflict of interest in that the IAR has a financial incentive to recommend Equitable Advisors’ services in implementing the plan, just as it does in recommending products through its brokerage and insurance business, discussed above. In some circumstances, IARs with clients in managed accounts include financial planning services within the services provided as part of their annual asset-based fee and will not charge a separate financial planning fee for such services, as described in the “Asset Management Programs” section below. Equitable Advisors also makes a variety of financial analyses, account review tools, and reports available to clients. Unless accompanied by a financial planning agreement and a copy of this Brochure, these documents are not part of Equitable Advisors’ financial planning services and are provided to clients either in our capacity as a broker-dealer (and/or insurance agent, by our 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. The following is a description of the various personal and other financial planning services we offer. Goals-Focused Planning Based on the long-term goals a client has identified; an IAR will analyze the client’s particular situation and provide recommendations on the topics that align with his or her goals. Financial planning services may or may not also include other services listed below. Financial Position The Financial Position topic is designed to ensure the foundation of a client’s financial plan is secure. This area may also evaluate the client’s current level of cash reserves to provide an assessment of his or her ability to cover expenses in the 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 the client’s personal financial situation. A client’s IAR may provide advice regarding the level of survivor income protection and disability insurance a client may need in order to protect his or her (or survivors’) 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. A client’s 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. 4 September 2025  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. (Please note that asset allocation is a long-term approach to investing and that financial planning services generally do not include advice regarding “market timing” (i.e., short-term reallocations among asset classes)). As in its other financial planning services, this service does not 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 significant repositioning of assets, addressing timing issues and reviewing risk tolerance in order to provide adequate income and financial security during the client’s 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 the client’s or his or her dependents’ educational goals. 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 a client’s 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 5 September 2025  efficient withdrawals from tax- deferred accounts and to minimize the taxation of Social Security income. Neither Equitable Advisors nor an IAR provides tax or legal advice under this planning service (or any other financial planning service we offer). 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 your current financial position relative to a level of income sufficient for various other major purchase goals you have 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 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 class 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 will work with the client to determine which “assumptions” 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. The client’s assumptions 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. 6 September 2025  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 www.equitable.com/CRS. 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. Seminars will be general in nature and limited to educational and impersonal advice. The information an IAR provides at a seminar is not intended to address any attendee’s personal financial situation, and 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. Seminars provided to groups of employees are not intended as “employee benefits” covered by ERISA or any other law. In addition, the limits on Equitable Advisors’ activities described below under “Retirement Plan Investment Advisory Services” apply to any services provided to employees that participate in a qualified retirement plan that is subject to ERISA or an IRA subject to applicable provisions of the Internal Revenue Code of 1987, as amended (the “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. 7 September 2025  The services provided by Equitable Advisors pursuant to corporate agreements are not intended as “employee benefits” covered by ERISA or any other law. In addition, the limits on Equitable Advisors’ activities described below under “Retirement Plan Investment Advisory Services” apply to any services provided to employees that participate in a qualified retirement plan that is subject to ERISA or an individual retirement account (“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 generally 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’ asset management services are comprised of three primary areas: (1) assisting clients in allocating investment among separate account programs offered by LPL Financial (an “LPL Program”), including acting as portfolio manager in LPL’s SAM Program as described below, (2) endorsements (referrals) of clients to one or more third party asset managers (or “TAMPs”) offered through the Company, and (3) ERISA fiduciary and investment manager services to qualified retirement plans and retirement investors subject. Under many of the LPL Programs, LPL acts as co-adviser with the Company, and may have discretionary authority to trade in clients’ accounts in the program in order to implement various models or strategies as overlay manager or otherwise. However, the LPL Programs vary, and each is described in greater detail below. The LPL Programs include the Strategic Asset Management (or “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 SAM account, meaning the IAR may place trades in the client’s account without first consulting the client on each recommendation (i.e., exercises “discretion” or “discretionary authority” over the account). The Company urges you to consult the full LPL Program brochures for more information generally, and to discuss any discretionary authority with you IAR if applicable. 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 “discretion” to trade on behalf of the client in the account) and applies various models or strategies. In some cases, an IAR will assist in the referred investor’s allocation among a TAMP’s models and strategies, 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 certain ongoing review and client administration services for the client’s TAMP account (a “Client Referral Arrangement”). In the second, Equitable Advisors endorses a TAMP but does not enter into a client relationship with the referred investor and provides no ongoing advisory or other services with respect to the TAMP account (a “Handoff Referral Arrangement”). 8 September 2025  1. Types of Advisory Programs offered through TAMPs and LPL Programs • 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 include elements such as client profiling, fee-based pricing, and rebalancing. • IAR as Advisor Programs (e.g., SAM) – non-discretionary and discretionary fee based advisory 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 that provides the ability to manage an investor’s assets in a comprehensive portfolio. The following Sub-sections 2 and 3 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 of the TAMP 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. 2. Referrals to TAMPs As a promoter in referring clients to TAMPs, we act in accordance with the Advisers Act, including Rule 206(4)-1 thereunder (the “Marketing Rule”) governing paid testimonials or endorsements. These TAMPs sponsor advisory programs and charge the client an advisory fee based on assets invested. The TAMP pays Equitable Advisors a portion of that advisory fee either for its referral alone (in Handoff Referral Arrangements) and in other cases for its referral and ongoing services (Client Referral Arrangements). Each TAMP the Company endorses undergoes initial and ongoing due diligence review by the Company and must be approved by Equitable Advisors’ Product Review Committee (or “PRC”), discussed below. Equitable Advisors (and, through EQA, its IARs, are compensated for each investor that becomes a client of these TAMPs based on a portion of the advisory fee paid by the referred investor to the TAMP. When it makes an endorsement/referral, Equitable Advisors will disclose at that time its arrangement with the 9 September 2025  TAMP and the compensation it will receive. Referred persons are required to sign a disclosure form to evidence receipt of such disclosures and acknowledge their understanding of the conflict of interest created by the Company’s receipt of compensation for the referral. Certain TAMPs are currently recommended by IARs to new prospective investors for referral; other TAMPs are available only to existing relationships and are not open for new referral business (referred to as “service-only TAMPs”). Generally, these service-only TAMPs are approved by the Company as an accommodation to IARs that join the Company from other advisory firms, and their existing clients’ relationships with a TAMP are permitted to continue only with respect to those clients. In some cases, service-only TAMPs may be later approved by the Company as TAMPs available for new business, or a TAMP open to new business may be made service-only. In very limited circumstances, offering of certain otherwise service-only TAMPs may be permitted for new clients with respect to certain 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 in the client’s allocation among the TAMP’s programs, models, or portfolios, as applicable. In the Client Referral arrangements, the Company will meet with the client at least annually to update information regarding the client’s needs, objectives, and other factors and to determine if the 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- managers that are used to populate a client’s account. • The Company does not have the ability to select the broker-dealers or custodians used by the TAMPs. Those decisions are made by the TAMP and in accordance with your client agreement with the TAMP and as disclosed in the TAMP’s Form ADV Part 2A and/or the 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 described in the client agreement for the program and the TAMP’s investment advisory or 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 the agreement with the TAMP (when we are a party) or in a separate agreement entitled “Investment Adviser Agreement – Third Party Programs” which can be found on our Disclosure Website (https://equitable.com/CRS). • In Handoff Referral Arrangements, we will not have ongoing contact and responsibilities with respect to your account after you are referred to a TAMP. 10 September 2025  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 available through the Company. 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 available through the SEC’s website at https://adviserinfo.sec.gov/. a. Client Referral Arrangements Under the Client Referral Arrangements with the listed TAMPs, Equitable Advisors maintains ongoing responsibilities and serves as an investment adviser to the client, seeking to meet with the client at least once each year to obtain updated information to determine if the TAMP and its programs remain suitable as well as facilitating ongoing communication between the TAMP and the client. 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 Advisory Agreement (if the Company is not a party to the TAMP’s client agreement). Client Referral Arrangement TAMPs – Open for New Referrals Advisors Capital Management (“ACM”) 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. ACM’s investment strategies include Global Growth, Global Dividend, International ADR, Small/Mid Cap 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 Insurance Company of America; together, “Equitable Financial”), and third-party insurance carriers. 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- directed brokerage account (“SDBA”). The PathFinder 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, Inc. (“AssetMark”) 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 11 September 2025  Solutions, Select Solutions, and Preservation Strategy. For each AssetMark program, an IAR consult with clients to assess their financial situation and identify their investment objectives in order to assist the client in investing in portfolios designed to meet the client’s financial needs. Working with their IAR, clients select advisory service(s) and investment objective(s) available within the program(s). AssetMark manages the assets based on a client’s individual financial circumstances, investment needs, and goals 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 Asset Management (“Boyd Watterson”) 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 choose to utilize one of Boyd Watterson’s traditional investment options or a customized approach that better fits their needs. Your Equitable Advisors’ IAR works with you to determine which of Boyd Watterson’s portfolios will help you meet your investment objectives. Equitable Advisors offers clients 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 Watterson, Boyd Watterson also provides separately managed accounts through specific investment options in different programs offered through Equitable Advisors, such as Lockwood’s Multi-Manager or LPL’s Manager Select. Brinker Capital, Inc. (“Brinker Capital”) 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. Brinker Capital’s Destinations program includes mutual 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. PlanMember Securities Corporation (“PSEC”) 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 individual retirement plans. A data gathering questionnaire is undertaken to determine the client’s 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. 12 September 2025  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. SEI Investments Management Corporation (“SEI”) 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 Mutual Fund Asset Allocation Program. For each of the SEI’s programs, 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. 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. The Pacific Financial Group (“TPFG”) 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 (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 the minimum amount requirements. Trek Financial, LLC (formerly “BCJ Capital Management”) Equitable Advisors offers clients access to portfolios managed by Trek Financial, which uses a goal-based investment approach. Your Equitable Advisors’ IAR works with you to determine which of Trek Financials’ portfolios will help you meet your investment objectives. The manager does not have a stated minimum account size. Signature Investment Advisors, LLC. (“SIA”) 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. 13 September 2025  CLS Investments, LLC (“CLS”) Equitable Advisors offers clients access to a variety of CLS’s advisory programs on a service 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 offer 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. Handoff Referral Arrangements b. The following are the Company’s Handoff Referral TAMP arrangements. As described above, in such Handoff Referrals the IAR is providing an endorsement under the Advisers Act but does not form a client relationship with the referred investor and does not provide ongoing services with respect to the referred investor’s account. The following are the Company’s Handoff Referral arrangements open to new business. Service-only Handoff Referral TAMPs are not discussed, as the Company has no ongoing involvement with prior referred investors’ accounts and does not presently refer new investors to such service-only TAMPs. The Handoff Referral TAMPs to which Equitable Advisors continues to refer business (rather than on a “service-only” basis) are Ancora Advisors, LLC., Cornerstone Advisory, Hightower Advisors, LLC, The Colony Group, Raymond James Financial Services, Forefront Analytics – GKFO, UBS Financial Services, Sentinel Pension Advisors, OneDigital Investment Advisors, LLC., Corient Private Wealth, LLC, SEI Global Institutional Group, ProNvest, Inc. (“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 advisory services regarding the client’s ProNVest account will be provided by ProNvest pursuant to an 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/. Certain Equitable Advisors registered representatives in its brokerage business (who are not IARs of the Company) are investment adviser representatives and/or owners of Baldwin Group Wealth Advisors. All investment advisory services in these Handoff Referrals with respect to the referred investor’s account will be provided by the relevant TAMP pursuant to an agreement between the client and the specific TAMP. See the Form ADV Part 2A of the specific TAMP for more information on its investment advisory practices and other policies and terms. (i) Referrals to Our Affiliate BPWM Equitable Advisors may refer clients to the investment advisory and asset management services of an Equitable Advisors’ affiliate, Bernstein Private Wealth Management (“BPWM”), a unit of AB. Equitable Advisors (and its IAR(s)) are compensated for referrals to BPWM and do not provide any investment advisory services to the client regarding the BPWM account (as in the Company’s Handoff Referral arrangements). All investment advisory services regarding the client’s BPWM account will be provided by 14 September 2025  BPWM pursuant to an agreement between the client and BPWM to which the Company is not a party. See the Form ADV Part 2A of BPWM for more information on its investment advisory practices. 3. LPL Programs a. LPL Financial Generally Equitable Advisors offers clients access to various investments advisory programs offered through LPL Financial (“LPL”). Additionally, Equitable Advisors has other relationships with LPL. LPL acts as Equitable Advisors’ securities fully disclosed clearing firm for broker-dealer products and services, and also provides back- and middle-office services through a services agreement between the companies for both the Company’s brokerage and 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 our IARs’ recommendations are in the client’s best interest, and through supervisory oversight and controls designed to ensure that each recommendation meets all regulatory requirements. In LPL accounts, clients also have the opportunity to utilize the services of Private Trust Company (“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 trust 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. Equitable Advisors IARs will assist the client in selecting a program appropriate for their investment needs. They will receive compensation for this assistance as discussed further in Item 5. As a convenience to clients, 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. In addition to the programs listed below, LPL provides collateralized lending services through certain federally chartered savings bank(s), on accounts for which LPL serves as the program sponsor. Please be aware this raises conflicts of interest that are discussed in your LPL Program Brochure. Clients should carefully review the program brochure of all LPL Programs (and TAMPs) before investing. 15 September 2025  b. LPL Programs Equitable Advisors provides clients access to various investment advisory programs offered through LPL. These programs are discussed below. The LPL Program brochures for these programs are available at www.equitable.com/CRS. These brochures describe the program and include the relevant account agreement, LPL’s Form ADV Part 2A as well as this Form ADV Part 2A, among other things. The SAM program and certain disclosures regarding MWP “Advisor Sleeve” (when an IAR is designing the model for his or her clients) are discussed in greater detail in subsection (c) below. • Optimum Market Portfolios (“OMP”) – a professionally managed mutual fund advisory program using Optimum Funds Class I shares. Your Equitable Advisors IAR works with you to complete a client questionnaire which allows LPL to determine the asset allocation to meet your investment objectives. • Personal Wealth Portfolios (“PWP”) - is a unified management account in which LPL, with assistance from sub-advisors it has selected, directs, and manages specified client assets on a discretionary basis. Your Equitable Advisors IAR works with you to determine which of the sub- advisors will work with your individual investment objectives. • Manager Select – a separately managed account program where the client, with the assistance of their IAR, will select the managers and develop an asset allocation. • Model Wealth Portfolios (“MWP”) – a unified managed account program that provides clients with access to managed portfolios of securities (which may include mutual funds, ETFs, exchange traded notes or “ETNs” and closed end funds) created and designed by LPL’s in- house research team (“LPL Research”), a third-party investment strategist (an “Outside Strategist”),1 or (if available) an Equitable Advisors IAR (referred to as MWP Advisor Sleeve)—or a third-party registered investment adviser of which certain Equitable Advisors IARs are principals and/or investment adviser representatives2—with oversight from the LPL Financial Overlay Portfolio Management Group (the “LPL Overlay Manager”). Your Equitable Advisors IAR works with you to determine which of the allocation strategies, called “models,” will work with your individual investment objectives. The Equitable Advisors IAR may recommend that you choose more than one strategist within a single MWP account. 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, 1 Two of the Outside Strategists, AB and Equitable Investment Management (the brand name for Equitable Investment Management Group, LLC which, among other things, serves as the investment adviser to the 1290 Funds, as discussed in Item 10, below) are affiliates of Equitable Advisors. See LPL’s MWP Program Brochure for additional information regarding available portfolio strategists. 2 For example, LPL makes available as an accommodation to Equitable Advisors portfolios created and designed by PST Advisors Inc. (“PST”). 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 selection and review criteria that LPL applies to other portfolio strategists and its portfolios are only available to Equitable Advisors’ clients. 16 September 2025  develop economic models, or otherwise support the investment advisory services provided by the IARs under these programs. c. SAM Program -- IAR as Portfolio Advisor Equitable Advisors and its IARs provide direct portfolio management services to our clients in the LPL SAM program. In the SAM program, the IAR makes recommendations of specific investments to clients, and, in some cases with client consent and Company approval, may exercise discretionary authority over a client’s SAM account; discretionary authority is discussed in this Item 4 and in Item 16 below. In all other LPL Programs, any portfolio management services are provided by LPL and/or its delegate. Equitable Advisors receives a portion of the advisory fee for the services it provides in all such LPL Programs. The fees for LPL Programs paid to the Company, as well as other compensation Equitable Advisors receives, are described in more detail in Item 5 - Fees and Compensation. In certain rare circumstances, we have as an accommodation entered into advisory relationships in which the IAR acts as portfolio manager with respect to assets held on a platform other than LPL. (1) SAM Program Accounts (a) SAM Accounts Generally In most cases, portfolio management services for SAM accounts are provided on a non-discretionary basis, which means the client must approve all transactions prior to execution. In some instances, 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 transaction charges for executing trades in the account through LPL, or (2) the IAR pays such charges. LPL charges flat fees (referred to as “ticket charges”) for executing trades. In the second option, the overall advisory fee paid to LPL in SAM (and the portion paid to the Company and, thus, the IAR, is higher than when the client is paying transaction charges. This creates a conflict of interest in that it incentivizes an IAR to place a client in the second option and minimize trading, or select investment options that minimize the transaction costs to the IAR. The Company has controls in place to monitor the level of trading activity in SAM accounts. In SAM accounts, the IAR serves as portfolio adviser on a non-discretionary or discretionary basis where clients (or the IAR on clients’ behalf when discretionary) may purchase and sell securities and/or liquidate previously purchased load mutual funds (e.g., equities, fixed income, options, no-load and load waived mutual funds, variable annuities, and ETFs) pursuant to investment objectives chosen by the client. IAR Variable annuities available on the SAM platform are proprietary to Equitable Life Insurance Company, an affiliate of Equitable Advisors. IARs will not receive up front commissions for recommendations of Equitable proprietary variable annuity products in SAM accounts but will receive an ongoing fee commensurate with any SAM investment as described more fully below in “Item 5 – Fees and Compensation.” In addition, an IAR may recommend a SAM client invest in the 1290 Funds, managed by the Company’s affiliate Equitable Investment Management (or “EIM”) and AB Funds, managed by the Company’s affiliate 17 September 2025  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 and 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 recommend such investment products based on the compensation received, rather than on a client’s 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 at https://equitable.com/CRS. Important information regarding compensation and conflicts of interest can also be found in the prospectus for any funds offered, which are available upon request. The 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 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 or the potential conflicts of interest they create. Furthermore, clients can refer to the prospectus or Statement of Additional Information for the specific variable annuity or mutual fund for more information regarding the additional compensation the IAR may receive. IARs may also recommend certain alternative, complex, and structured products in SAM accounts, as discussed below. Structured products typically take the form of bonds called “Structured Notes,” although some structured products are Certificates of Deposit (“CDs”). (b) Alternative Investments in SAM Accounts Equitable Advisors and select IARs make available certain alternative investments to advisory clients in SAM. These alternative investments include managed futures, business development companies (“BDCs”) and real estate investment trusts (“REITs”), which are all considered to be alternative investment products due to their non-traditional composition. See Section 4, below, for a discussion of alternative investments, including those available through SAM accounts. “Complex” investment products (e.g., sector funds, structured notes and leveraged ETFs) and alternative investments (e.g., managed futures, non-traded REITs, and BDCs) are generally viewed as difficult for average investors to understand and they typically invest, in whole or in part, in non-traditional (“alternative”) 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 on a non-discretionary basis recommends a strategist or strategists and model(s) designed by the strategist(s), and LPL implements the models in the client’s account on a discretionary basis. In the MWP Advisor Sleeve program, the IAR designs model portfolios of securities as a strategist in MWP for his/her clients. In some cases, an IAR may recommend portfolios created by another IAR of the Company. These portfolios are implemented by LPL, which maintains discretionary authority over the client’s account as overlay manager. 18 September 2025  Due to the existing arrangements between LPL and Equitable Advisors, LPL allows our IARs to offer portfolios created and designed by Equitable Advisors IARs to the Company’s clients. The portfolios created by our IARs under MWP Advisor Sleeve are only available to Equitable Advisors clients. Equitable Advisors’ IARs are not 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 wishing to use an Equitable Advisors’ IAR as a strategist should bear this in mind and should not think that the availability of their Equitable Advisors’ IAR as a strategist in the MWP program platform means that LPL has vetted, assessed, or approved of their abilities, experience, or portfolio management acumen. Clients should and are encouraged to speak to their Equitable Advisors IAR who serves as an MWP Advisor Sleeve strategist to discuss the arrangement and the services the IAR will provide. Clients should be certain they understand the investment strategies and techniques the IAR intends to utilize as an MWP Advisor Sleeve strategist, the associated risks, and the IAR’s approach to asset allocation, diversification, risk management, portfolio monitoring, and rebalancing. Clients should also be comfortable with their Equitable Advisors IAR’s experience in managing portfolios, the basis of their research, their buy and sell criteria, and the resources they are able to dedicate to serving as a strategist in MWP Advisor Sleeve. Clients should review their IAR’s individual Form ADV Part 2B (also referred to as a Brochure Supplement) for more information about their IAR’s experience and education As set forth more fully in the MWP account documentation, LPL charges three fees in connection with MWP accounts: the Advisor Fee (of which the Company receives a portion under MWP), the Strategist Fee, and the LPL Program Fee.3 These fees are separate and pay for distinct services. Where an Equitable Advisors IAR is the strategist (MWP Advisor Sleeve), the Strategist Fee is 0% as the Advisor Fee is presumed to include compensation for such services. In MWP Advisor Sleeve, the Advisor Fee may not exceed 2.35%, as discussed in Item 5 below. This removes the direct financial incentive for an IAR to recommend a client adopt the IAR’s own model portfolios in MWP Advisor Sleeve. The Advisor Fee is for the investment advisory services of Equitable and the Equitable Advisors IAR and may not exceed 2%. The Strategist Fee is a fee for the model portfolio design services of a strategist, and ranges from 0% to 0.25%.4 The LPL Program Fee is for the investment advisory, administrative, trading, and custodial services of LPL, and ranges from 0.08% to 0.35%.5 The Strategist Fee and LPL Program Fee referenced in this paragraph may change from time to time, upon thirty (30) days’ prior notice to clients. 4. Alternative Investments Alternative investments such as non-traded BDCs, and REITs may be recommended for purchase in SAM accounts, in Equitable Advisors’ brokerage accounts, and in certain TAMP or LPL Programs., IARs may only 3. See fn. 5. 4 Where PST is the strategist and the Equitable Advisors Financial Professional assigned to the account is a principal of PST, the Equitable Advisors Financial Professional would receive the Advisor Fee and, indirectly, the Strategist Fee or a portion of that fee. Where the Equitable Advisors Financial Professional assigned to the account is the strategist, the Strategist Fee is 0% as the Advisor Fee is presumed to include compensation for such services. The Strategist Fee and LPL Program Fee referenced in this paragraph may change from time to time, upon thirty (30) 5 days’ prior notice to clients. 19 September 2025  recommend such alternative investments to clients meeting certain liquid net worth thresholds. As a result, not all SAM clients may be able to purchase alternative investments. A BDC is a type of pooled investment company that is registered under Section 54 of the Investment Company Act of 1940, as amended (the “1940 Act”), rather than as 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. BDCs facilitate the flow of capital to private companies and provide retail investors with exposure to the private equity and private debt investment markets, and are required to provide portfolio companies with “significant managerial assistance.” 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. 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 and its IAR(s) will, however, receive compensation from the advisory fees on the value of all of the assets held within the client’s SAM account, including the value of any investments in such BDCs, or REITs. 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. However, the BDCs and REITs Equitable Advisors offers are non-traded, meaning there is no liquid market for their shares. 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 REITs, known as “daily NAV programs”, may offer greater liquidity to investors, generally on a quarterly basis. These are long-term investments, and investors should be aware that liquidity is not guaranteed at any time. 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 registered representatives in the Company’s broker-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. Please review the Offering Memorandum or Prospectus of the hedge fund or fund of hedge funds for more information, as the terms of each offering may differ, as well as certain fees and charges that may be applicable. Certain alternative investment products (plus some structured notes and CDs that may also be available in SAM accounts) have a short to intermediate maturity – generally less than five years, although some may go as long as fifteen years. Purchasing a product with a long period until maturity in an advisory account may result in higher compensation to a client’s IAR than if the product is purchased 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. 20 September 2025  Alternative investments purchased in advisory accounts do not carry a sales commission; however, 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. 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 rather than an advisory fee, as described in the investment’s offering memorandum. 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 as a result 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 generally is in the client’s best interest. 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 in particular his or her investment time horizon and overall likely costs before making a decision about 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 connection with alternative investments. 5. Retirement Plan Support and Fiduciary Advice a. Retirement Plan Investment Advisory Support Services Equitable Advisors may enter into agreements with sponsors of retirement plans to provide general retirement plan management education and support services (the “Retirement Services”) to the plan sponsor and/or plan participants in exchange for a fee, further information about which is provided in Item 5 – Fees and Compensation. Only appropriately credentialed IARs are authorized by Equitable 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. Certain Company-approved IARs may act as ERISA fiduciaries to plan sponsors and retirement investors. Unless otherwise agreed pursuant to an ERISA investment advisory services agreement (see “ERISA 21 September 2025  Fiduciary Services” below), the Retirement Services will not include any recommendation to any 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 advisors providing plans with similar non-fiduciary services; in such cases, Equitable Advisors’ client is the other adviser, and 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. It will remain the plan sponsor’s responsibility to adopt 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 services not related to their retirement plan (“Optional Services”). The relationship created between Equitable Advisors and a participant through Optional Services will not include the participant’s employer 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 Advisors or any other party. Further, neither the participant’s employer nor any qualified plan is a fiduciary 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 IAR will not act as ERISA fiduciaries with respect to any qualified plan, and any investment materials provided to plan participants will be general 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; 22 September 2025  • 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 to “investment education” versus “investment advice.” b. ERISA Fiduciary Services – Retirement Plan Consulting Services It is Equitable Advisors’ policy that, unless approved by Equitable Advisors, no IAR may (1) act as a fiduciary under ERISA Section 3(21) or (2) as a fiduciary 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 an ERISA fiduciary under Section 3(21) or 3(38). This is referred to as the Company’s Retirement Plan Consulting Services program (“RPCS”). Where approved, the nature of such services is described below. No services provided to retirement plan participants are intended to constitute an “employee benefit” under ERISA or any other law or regulation. In limited circumstances, Equitable Advisors may enter into an agreement with a retirement plan sponsor to provide services as a non-discretionary ERISA fiduciary pursuant to ERISA section 3(21)(A)(ii) (“ERISA Fiduciary Services”). Under ERISA section 3(21)(A)(ii), Equitable Advisors will assist a plan’s fiduciary in the initial selection and ongoing monitoring of the investment line-up available to the plan’s participants. Only appropriately credentialed IARs specifically approved by Equitable Advisors under the RPCS program are authorized to provide ERISA Fiduciary Services. Similarly, Equitable Advisors may enter into an agreement with a plan sponsor to provide discretionary “investment manager” services to the plan under Section 3(38) of ERISA (also making it an ERISA fiduciary). 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. 23 September 2025  (1) ERISA Section 3(21) (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 Advisors will identify for the plan sponsor’s consideration one or more investment 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 provide the plan sponsor with a “core list” of recommended 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. (b) Non-Discretionary Monitoring of Investment Options 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 Equitable Advisors may also allow certain credentialed IARs to act as discretionary “investment managers” 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 approved 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. 24 September 2025  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 services; in such cases, Equitable Advisors’ client is the other adviser, and not the plan nor any participant. Additional services may include assistance (in a non-discretionary or discretionary capacity as elected by the plan sponsor) in creating asset allocation models to be included as options within the plan’s 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 IAR will not exercise any discretion or authority regarding the plan sponsor’s selection of the qualified plan platform and service provider(s). IARs will also not exercise discussion with respect to specific securities or funds available through a group annuity platform that will be eligible investment options 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. 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 provided to Equitable Advisors regarding the qualified plan. The plan sponsor must advise Equitable Advisors of such changes promptly in order 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 (“RPAG”), Fi360, or Plan Tools. Equitable Advisors, its affiliates, and IARs are not affiliated with or 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 25 September 2025  created through Optional Services shall include the participant’s employer or 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 Advisors, its affiliates, or other carriers. Further, neither the participant’s employer nor any fiduciary that is responsible for making 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. The Firm’s agreements with clients for ERISA fiduciary services do not include these IARs, who may 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 provided in Item 5 – Fees and Compensation. IARs generally receive approximately 40 – 90% of advisory fees received by Equitable Advisors with respect to ERISA Fiduciary Services, the same range as the advisory fees provided to IARs with respect to the Company’s advisory services generally. 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 Equitable, such as Retirement Gateway, Equitable Retirement 360 (“AR 360”), or Equitable Retirement 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 affiliate even where the IAR does not directly benefit. This conflict is addressed through disclosure here, and by 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 June 30, 2025, Equitable Advisors’ regulatory assets under management were $38,039,299,080. This 26 September 2025  calculation only includes assets in SAM accounts and other limited arrangements in accordance with the definition of “regulatory assets under management” for the purposes of Form ADV Part 1A, Section 5. 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, $17,712,673,018 was managed by us on a discretionary basis, and $20,326,626,062 was managed on a non-discretionary basis. US Dollar Amount Number of Accounts Discretionary Non-Discretionary Total $17,712,673,018 $20,326,626,062 $38,039,299,080 36,988 52,163 89,151 Item 5 – Fees and Compensation The following discussion generally describes how Equitable Advisors and our IARs are compensated for the advisory services we provide to 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 Firm’s advisory and brokerage services. For additional information, see the Company’s Compensation and Conflicts Disclosure as well as the GCOI, available at www.equitable.com/CRS. Financial Planning Services 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 range from $100 to $400 per hour. In some cases, the client’s assets may be used to determine the fee. 27 September 2025  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. As described in Item 4, above, once a client’s financial plan is delivered and presented, the 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 compensation received, rather than on a client’s needs. We disclose potential 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 IAR for additional information should he or she have any questions regarding these payments or the conflicts of interest they can create. Certain registered representatives/IARs who operate under Equitable Advisors’ home office groups do not receive fees or commissions but rather are compensated by Equitable Advisors on a salary basis. These registered representatives 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 the same as the fees charged for purchases from Equitable Advisors’ other Financial Professionals, whether as IARs (advisory services) or as registered representatives (brokerage). Although Equitable Advisors does not maintain a formal recommended list, we leverage LPL Research’s recommended mutual fund list. 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 In investing in LPL programs, clients pay LPL an annualized Account Fee generally based on a percentage of their account value (the “Account Fee”), a portion of which LPL pays to the Company. Some LPL 28 September 2025  Programs charge additional fees, as described in the relevant LPL Program Brochure, but the Account Fee serves as compensation for Equitable Advisors’ advisory services. LPL pays Equitable Advisors a percentage of the Account Fee, and Equitable Advisors provides a portion of that fee to your IAR. The remainder is retained by Equitable Advisors for supervisory and administrative services. The percentage of the Account Fee your IAR receives may be higher for certain LPL Programs or TAMPs. programs whose overall fee percentages are significantly lower when compared to other programs. 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) but will not exceed 2.5% of the client’s account value on an 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 (also an “Account Fee” herein). The maximum Account Fee such Retirement Plan Services or ERISA fiduciary services generally is 0.75% of the client’s account value. 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 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 terms. Other fees, such as the fee for strategists in MWP may increase the fee over and above the maximum 2.5% stated above. These LPL Program materials are available at www.equitable.com/crs. 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 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. The IAR and Equitable Advisors usually receive a portion of this fee. The range of fees is up to the IAR’s discretion and, as noted above, is customarily negotiable. 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 in incurred in the SAM account, rather than the client being such costs separately. 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. If contemplated, clients should discuss such arrangements with their IAR to fully understand the terms. The following fee table details the range of fees paid to Equitable Advisors in each LPL Program and TAMP it offers, which ranges from 0.20% - 2.5%, depending on the program. This 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, your overall fee in most cases will be higher. 29 September 2025  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. 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 AssetMark No-Load Mutual Funds – AssetMark Funds AssetMark No-Load Mutual Funds – Other Fund Strategies 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 – Nationwide Tactical Strategies CLS – IAM Portfolio CLS – IAM Hybrid Portfolio CLS – ETF Portfolio CLS – Advisor One Protection (formerly CPM 3) CLS – Master Manager Strategy Portfolio CLS – Wealth Accumulation – AdvisorOne Portfolio LPL Optimum Market Portfolios Advisory (OMP) LPL Strategic Asset Management LPL Manager Select LPL Model Wealth Portfolios (MWP) LPL Personal Wealth Portfolios (PWP) 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% 0.50% 0.50% 0.50% 0.50% 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% 0.50% 0.50% 0.50% 0.50% 0.50% 0.50% 0.55% 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% 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% 1.35% 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 nor the IAR gets paid a sales commission for the investments you make and transactions in your account. Certain products offered to advisory clients within the Company’s advisory accounts may also be available on Equitable Advisors’ brokerage platform; 30 September 2025  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’s capacity 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 or as IAR). 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 cases where there are mutual funds, ETFs, BDCs, or REITs, etc. in the clients’ accounts, mutual fund and other fund expenses are in addition to any annual fee, transaction fees, or custodial fees. Equitable Advisors is generally not compensated from these fees. However, 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. 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). Often, but not always, firms that offer such products and services (which include, among others, discount brokers and direct marketers) do not provide the same level of personalized advice and/or service as Equitable Advisors seeks to provide. Some IARs receive compensation from Equitable Advisors in the form of a “forgivable loan,” which is a loan often made when an experienced IAR joins Equitable Advisors. This IAR is not required to pay back the loan if the IAR remains with Equitable Advisors for a certain period of time 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. 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 2A for such TAMPs can be located on the SEC’s website at adviserinfo.sec.gov. 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 – 90% of advisory fees received by Equitable Advisors. 31 September 2025  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; 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, on 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 TAMP’s 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 Company’s brokerage business). Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Depending on a client’s particular situation, need and expectations, there are various methods of analysis and investment strategies that IARs may use when developing a financial plan, formulating investment advice, or managing assets. 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. 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 32 September 2025  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 IARs also have access to investment research compiled by LPL’s in-house research team (“LPL Research”). LPL Research provides Equitable Advisors and its 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' financial planning and other policies, such as review and approval of financial planning tools to help ensure the presentation of quality financial planning advice. (New asset management programs are reviewed and approved by Equitable Advisors’ PRC.) Discussion of Risk Investing in securities involves the risk of loss, including loss of principle invested, that clients should be prepared to bear. Understanding the type of risk(s) exposure involved in securities and investment advisory services, as well as one’s own tolerance for 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. and Conflicts Disclosure, and GCOI disclosure, available Clients and potential clients should review the Company’s Risks of Investing in Investment Advisory at Programs, Compensation www.equitable.com/CRS. 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 implementation of the plan in a manner such that the client’s investment objectives and financial needs are not met. Furthermore, even if the financial plan is itself appropriate, the plan may not be implemented appropriately. As discussed in Item 4 – Advisory Business, for asset management programs other than SAM, Equitable Advisors’ IARs do not recommend securities; rather, they work with clients and recommend the advisory programs of third-party advisers -- the TAMPs and 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 protect against loss. As noted above, additional investment advisory programs are offered through third-party program sponsors that are unaffiliated with Equitable Advisors and LPL. Equitable Advisors serves as an investment adviser in referring clients to these programs, 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. 33 September 2025  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 through Financial 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 obtained (FINRA) BrokerCheck website Industry Regulatory Authority’s http://www.finra.org/Investors/ToolsCalculators/BrokerCheck, or the SEC’s Investment Adviser Public Disclosure website 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 Company’s affiliated life insurance company and distributed to retirement plan sponsors inaccurately represented that certain bond funds were investment-grade when, in fact, they were not. FINRA’s findings also stated that the Company’s supervisory systems and written supervisory procedures (WSP’s) were not reasonably designed to achieve compliance with relevant FINRA rules in that the Company did not have supervisory systems or WSP’s in place related to the accuracy of the 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 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 prejudgment interest to affected clients in the amount of approximately $1,134,152. The SEC noted the Company’s self-reporting of this matter in connection with the Share Class Selection Disclosure Initiative and the Company’s 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 Equitable Advisors’ principal business consists of acting as an investment adviser, as described in this 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 34 September 2025  through your 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://equitable.com/CRS. For execution and clearing of certain brokerage transactions in its role as introducing broker-dealer, Equitable Advisors maintains a clearing arrangement with LPL. In the LPL programs, LPL serves as broker- dealer. The Company’s IARs are also registered representatives of the Company in its 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 – Fees and Compensation above for a discussion of the compensation and 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; • PlanMember Securities Corporation, File No. 801 – 39177; • 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 Equitable Investment Management Group, LLC (“EIM”, also known as “1290 Asset Managers” and the brand name “Equitable Investment Management”) is the adviser to certain proprietary mutual funds known as the 1290 Funds 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 Investment Company Act of 1940 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. 35 September 2025  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 IARs (an “outside investment adviser” or “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. Under certain circumstances, those individuals and other of Equitable Advisors’ IARs under certain circumstances are permitted to refer prospective investment advisory clients to the outside investment adviser. For more information, see Item 14 (“Client Referrals”) below. Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading Code of Ethics Equitable Advisors maintains a Code of Ethics that applies to all of our advisory “supervised persons” in accordance with Rule 204A-1 under the Advisers Act, which includes our IARs. The Code of Ethics and other policies and procedures are designed to assist the Company’s IAR advisory supervised persons in understanding their obligations under applicable law and regulation, to detect and prevent violations of the securities laws, to monitor the Company’s and IARs satisfaction of their fiduciary duty to clients, to ensure disclosure of, avoid, address, and/or mitigate conflicts of interest with Equitable Advisors’ clients. and prevent or detect other practices that may be inappropriate, illegal, or improper. The Code of Ethics also assists the Company in monitoring the personal securities trading activities of those individuals deemed to be “access persons” 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 www.equitable.com/CRS. Alternatively, you can request a copy of the Code of Ethics from your IAR. Participation or Interest in Client Transactions and Personal Trading Except as otherwise described above in Item 4 – Advisory Business, Equitable Advisors and our IARs do not recommend specific securities to clients in connection with our investment advisory services except with respect to LPL’s SAM program; rather, the specific securities are selected by the third-party program sponsor (LPL or a TAMP) 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 the TAMP consults select the investments or create and adjust model portfolios implemented by the TAMP. In all of the LPL Programs save for SAM, underlying strategists, managers, or LPL selects the individual investments and rebalances the clients’ investments. In MWP Advisor Sleeve, certain Equitable Advisors IARs may create and manage a model portfolio for Equitable Advisors’ clients, with LPL 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, 36 September 2025  IARs may not recommend the purchase or sale of any individual securities of our publicly-traded parent company, Equitable Holdings, Inc. (NYSE: EQH), or individual securities of any Equitable affiliate, including AB. The definition of “individual securities” for the above referenced purposes includes all stock, fixed income, 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 Funds 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. It does not compensate your IAR in a manner that is based on his or her recommendations of the 1290 funds or AB funds. A client’s Account Fee in SAM 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) a IAR personally invests in the same securities that are recommended to clients; or (ii) an IAR buy or sells securities for the IAR’s own account at or about the same time as such securities are recommended to a client. Conflicts of interest could arise in such instances, including the possibility that the IAR could “front run,” or trade for the IAR’s personal account ahead of a client, or otherwise attempt through client recommendations to influence the price of a security the IAR is invested in or contemplating buying or selling for the IAR’s own account. 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 feed of the access persons’ account holdings and trades. These reports are analyzed by our Personal Brokerage Accounts Group to compare an IAR’s personal trading to trading in client accounts to identify issues such as “front running,” among other things. We will take appropriate action to remedy any circumstance in which an IAR’s personal trading may impact the client, including by reversing the trades so that the client receives the more favorable price. Our Code of Ethics also prohibits access persons from acquiring for their own account securities in any Initial Public Offering (“IPO”) and 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. 37 September 2025  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 disfavors clients. Aggregation of trades is discussed in greater detail in Item 12 below. Item 12 – Brokerage Practices Equitable Advisors 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. The Company acts as a broker-dealer in its brokerage business, but not with respect to the programs offered to its advisory clients. In the TAMP programs the Company offers, the applicable TAMP selects the broker-dealers used (or delegates that selection to a third-party adviser depending on the appliable TAMP program). In certain programs, the client may not have a choice of broker-dealer, while other programs may permit such choice, as agreed between the client and the TAMP. Certain of the TAMPs may use LPL as broker-dealer to execute all or a portion of the trades for their programs. A client should review the TAMP’s Form ADV Part 2A to understand its 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 the programs. 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 select their own brokers in the LPL programs, including SAM. The Company has processes in place to monitor LPL’s execution of client trades in SAM seeking to ensure LPL is meeting its execution obligations under applicable regulation. 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 program sponsor’s Form ADV Part 2A and/or account agreement. In the SAM program, Equitable Advisors’ IARs place securities orders on client’s behalf 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 to by Equitable Advisors. In aggregating orders through LPL, a 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 38 September 2025  IARs from allocating an aggregated trade in a way after time for price discovery that favors one client over another or the IAR’s personal trades aggregated with those of clients (i.e., “cherry picking”). Item 13 – Review of Accounts Financial Planning: Our financial planning services generally address the client’s financial situation at the 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 Item 4 – Advisory Business, are required to meet with the client at least annually, if not more frequently. At this review, the IAR and the client discuss any updates to the client’s personal or financial information 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 or for accounts with certain TAMPs, such as Nationwide, where Equitable Advisors has been instructed by the TAMP that they have an alternative method of completing an annual review. 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 39 September 2025  Financial Planning: Aside from the written report or “plan” that is generally provided to the client, no 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 programs are sponsored by third party investment advisers – TAMPs and LPL --the reports will be produced and delivered by the program sponsor. Clients should review the program sponsor’s response to Item 13 – Review of Accounts in the sponsor’s Form ADV Part 2A for details regarding such reports. ERISA Fiduciary Services: In addition to the initial proposal, or “plan” that is provided to qualified plan 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, 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. Accuracy of the information contained in a consolidated or performance report is not guaranteed. Clients are encouraged to review and maintain official account statements (“source documents”) provided by 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 tools and the use of hypothetical performance information, see the “Proposal Tool Disclosure” posted on our disclosure website at www.equitable.com/CRS. An Equitable Advisors report may, with the client’s authorization, include assets that we do not hold on a client’s behalf (“held away” assets) and which are not included on our books and records. In most 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 evidencing any opinion or guarantee of the accuracy or reasonableness of any such values. 40 September 2025  Item 14 – Client Referrals and Other Compensation Client Referrals Inbound Referrals to the Company by Third-Parties From time to time, we enter into promoters’ agreements (also called “referral agreements” or “endorsement agreements”) with third parties through which those parties provide us with client referrals 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. Clients referred to the Company will receive a disclosure document at the time of the endorsement or referral that will describe the compensation we pay to the referring party and the relationship (if any) between the Company and the referring party. Equitable Advisors has entered into referral agreements where it receives client referrals with unaffiliated investment advisory firms owned by registered representatives and IARs of the Company (operated as an “outside business activity” or “OBA”), certain banks and credit unions, and trade groups and associations. 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. In these cases, the referring party promoting or endorsing Equitable Advisors has an incentive to refer clients to the Company because of the compensation received, rather than based exclusively on the needs of the referred party. Generally, absent an advisory or other relationship between the promoter and the referred investor, such referring parties do not owe the referred investor a fiduciary duty or duty to act in such person’s best interest in making the referral. Outbound Referrals to TAMPs and Other Advisers Likewise, if Equitable Advisors is referring a person to another investment adviser for investment advisory services (such as a TAMP), the IAR will provide such referred person with a disclosure statement for signature. However, this disclosure does not obligate a referred person in any way; such 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. Equitable Advisors’ IARs may enter into arrangements to receive certain information on prospective insurance or securities clients. Such arrangements to obtain referrals of prospective insurance or securities clients are generally permitted by Equitable Advisors provided that the compensation paid is a nominal amount, the referral is not specific to any type of product or service, and the arrangement is not conditioned upon the opening of any type of account or the purchase or sale of any type of product. These arrangements are intended to be product-neutral and are not referral or commission-sharing arrangements; there is no restriction on the types of products or services one may choose when deciding to become a client of Equitable Advisors. 41 September 2025  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 or co-advisers to other investment advisers and receive fees in that capacity, including, in limited cases, ORIAs (discussed above). Additional Payments from Investment Product Providers 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. 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 basis point (“bp” or “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 compensation, please refer to Equitable Advisors’ Compensation and Conflicts Disclosure as well as its Principles of Investing brochure, which are available from Equitable Advisors’ IARs and on our disclosure website at https://equitable.com/CRS. 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. 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, Boyd Watterson, and Morningstar. 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. Equitable Advisors may retain portions of financial support payments for any valid corporate purpose, and these amounts may contribute to the overall profits of the Company. Financial support payments are 42 September 2025  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 Advisors’ Principles of Investing brochure, that are provided to clients, as well as the Compensation and Conflicts Disclosure, which as noted above is available on our disclosure website and may also be obtained from any IAR. Equitable Advisors also receives financial support payments from certain mutual fund companies for assets placed by Equitable Advisors in the funds through asset management programs. Currently, such asset management programs offered by Equitable Advisors are LPL’s SAM and MWP Advisor Sleeve programs. Equitable Advisors also receives financial support payments from certain money market mutual fund companies used in connection with cash sweep vehicles; in addition, 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 also available in the LPL Program Brochure for each program. Information on LPL’s cash sweep programs is also available on LPL’s Form ADV Part 2A (which is included as part of the LPL Program Brochures), which clients should carefully review. The financial support payments to the Company described above will not result in a higher payment to a client’s IAR. However, the additional payments will contribute to Equitable Advisors’ profits and may indirectly benefit the IAR insofar as the payments are used by Equitable Advisors to support costs related to marketing or training. Equitable Advisors and its IARs recommending LPL Programs to the client receive compensation as a result of the client’s participation in the LPL program. This compensation includes a fee based on a portion of the Account Fee, as discussed in Items 4 and 5 above, and also may include other compensation, such as bonuses, awards or other things of value offered by LPL to Equitable Advisors or by LPL or Equitable Advisors to the IAR. For example, LPL under certain circumstances provides reimbursement of fees that Equitable Advisors or its IARs pay to LPL for administrative services. In particular, pursuant to the agreement between LPL and Equitable Advisors, 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. This amount is paid from the portion of the fee retained by LPL, and payment of this amount does not result in any higher or additional client fees. Therefore, this additional portion of the fee provides Equitable Advisors 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 at times 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 returned to the client except in certain circumstances relating to the cash sweep program. Please see your LPL Program Brochure for additional information about LPL’s cash sweep program. 43 September 2025  In addition, in certain instances, Equitable Advisors or its IAR receives a “finder’s fee” from a mutual fund company for placing a client’s assets into the fund for broker- dealer activity. A finder’s fee is generally triggered by an asset placement 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. Equitable Advisors and its IAR 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 IARs and Equitable Advisors’ employees. The Company has policies and procedures in place to monitor 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 products issued by Equitable Advisors and/or its affiliates (“proprietary products”) rather than products 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 assistance with marketing and related activities, training and education, trips, prizes, entertainment, awards, and other merchandise. 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 on a client’s needs. We disclose potential conflicts of interest to 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 A very small number of Equitable Advisors’ IARs may receive additional non-cash benefits pursuant to a third-party loyalty program offered by SEI, a TAMP to which the Company refers clients. Equitable Advisors’ IARs who have placed a various levels of client assets into SEI’s programs will qualify to receive 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 perhaps for hotel or flight expenses incurred in attending an SEI conference). Clients considering an SEI program should consider the actual or potential receipt by a IAR of such benefits, which creates a conflict of interest. Clients are encouraged to speak with their IAR if they have any questions regarding SEI’s Advisor Benefits 44 September 2025  Program 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)-2 of the Advisers Act (known as the “custody rule”). The Company does not have custody over client assets in referring clients to TAMP programs, nor do we select the custodians used in such programs. Further, in LPL programs, LPL acts as broker and custodian for the LPL Program accounts, and the Company does not generally have custody of client assets. However, the Company has custody of client assets in the context of the proprietary variable annuity products offered by its affiliates and available through SAM. This is the only circumstance in which the Company is deemed to have custody under the Advisers Act. Clients have the ability to purchase two Equitable proprietary variable annuity products via the SAM platform: Structured Capital Strategies – ADV, and Investment Edge – ADV. Equitable Advisors does not maintain the client assets with respect to such investments. Its affiliate, Equitable Financial, has custody. As a result of this affiliate’s custody of client assets under the Advisers Act, Equitable Advisors is subject to and complies with the custody rule. In connection with these annuity investments, clients should receive at least quarterly statements from the qualified custodian that maintains the client’s investment assets. For tax and other purposes, the custodial statements are the official records of the client’s account and assets. We may provide additional 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 other asset management programs should refer to the relevant TAMP or LPL’s Form ADV Part 2A, or the relevant program materials, for more information on those firm’s 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 described below, in SAM, IARs may exercise discretionary authority over client accounts: (1) when 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 the client’s account. 45 September 2025  Generally, with very limited exceptions, IARs are not permitted to exercise discretionary authority over SAM accounts for clients subject to ERISA. 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 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, including training required to become familiar with Equitable Advisors’ guidelines for offering and managing discretionary accounts. Prior to placing a discretionary trade, the IAR will be fully credentialed and versed in the product being traded. 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), subject to very limited exceptions. Item 17 – Voting Client Securities As a matter of Company policy and practice, we do not have and will not accept authority to vote proxies on behalf of advisory clients, nor do we provide advice to clients as to how they should vote proxies. For the advisory programs we offer through LPL and TAMPs, the client should refer to the program sponsor’s Form ADV Part 2A to determine the program sponsor’s policy on and/or instructions for voting client proxies. In certain programs, LPL or a TAMP, or their delegate, may vote proxies on behalf of the client, while, in others, clients will retain the responsibility for receiving and voting proxies. Item 18 - Financial Information See attached Statement of Financial Condition. 46 September 2025  [STATEMENT OF FINANCIAL CONDITION] 1 September 2025