ESI FINANCIAL ADVISORS

SEC File No. 801-41722 ESI Financial Advisors • One National Life Drive • Montpelier, VT 05604 • • (800) 344-7437 • www.Equity-Services.com Form ADV Part 2A March 30, 2026 This Brochure provides information about the qualifications and business practices of Equity Services, Inc., doing business as ESI Financial Advisors. If you have any questions about the contents of this Brochure, please contact us at 1-800-344-7437 or ESICompliance@nationallife.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about ESI Financial Advisors also is available on the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with ESI Financial Advisors who are registered as investment adviser representatives of ESI Financial Advisors. ESI Financial Advisors is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with information about which you determine to hire or retain an adviser. ES0408(0326) Cat. No. 48596  Item 2 – Material Changes ESI Financial Advisors (“EFA or “Firm”) removed references to certain programs otherwise covered under its Form ADV Part 2A-Appendix 1 brochure. The Firm’s ADV Part 2A brochure pertains to advisory programs offered by ESI for which ESI acts as a co-advisor in conjunction with other unaffiliated third-party services. advisors, and it describes EFA’s financial planning and financial consulting ES0408(0326) ii  Item 3 -Table of Contents Item 1 – Cover Page ....................................................................................................................................... i Item 2 – Material Changes ............................................................................................................................. ii Item 3 -Table of Contents .............................................................................................................................. iii Item 4 – Advisory Business ........................................................................................................................... 4 Item 5 – Fees and Compensation .................................................................................................................. 6 Item 6 – Performance-Based Fees and Side-By-Side Management ........................................................... 10 Item 7 – Types of Clients ............................................................................................................................. 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ...................................................... 11 Item 9 – Disciplinary Information ................................................................................................................. 12 Item 10 – Other Financial Industry Activities and Affiliations ....................................................................... 13 Item 11 – Code of Ethics ............................................................................................................................. 14 Item 12 – Brokerage Practices .................................................................................................................... 15 Item 13 – Review of Accounts ..................................................................................................................... 16 Item 14 – Client Referrals and Other Compensation ................................................................................... 16 Item 15 – Custody ....................................................................................................................................... 17 Item 16 – Investment Discretion .................................................................................................................. 17 Item 17 – Voting Client Securities ................................................................................................................ 17 Item 18 – Financial Information ................................................................................................................... 17 ES0408(0326) iii  Item 4 – Advisory Business Equity Services, Inc. (“ESI”) is a registered broker/dealer, as well as a federally registered investment adviser, doing business as ESI Financial Advisors (“EFA” or “the Firm”). ESI was founded in 1968 as an affiliate of National Life Insurance Company (“National Life”), which began doing business in 1848. NLV Financial Corporation is the sole shareholder of ESI, and the National Life Group companies, which includes National Life and Life Insurance Company of the Southwest (“LSW”). EFA provides financial planning/consulting services and asset management services to individuals, corporations, trusts, estates, charitable organizations, and retirement plans including pension and profit-sharing plans. EFA has been registered with the SEC since 1992. As of 12/31/2025, the Firm managed approximately $1.6 billion in non-discretionary assets and approximately $1.1 billion in discretionary assets across its advisory programs. Before investing in an advisory program, clients should decide if they are comfortable delegating the day- to-day management of their account(s). Investors in advisory programs typically: • Desire advice and guidance when making investment decisions; • When working with a discretionary manager, are at ease with a financial professional making their day-to-day investment decisions; • Are willing to follow a disciplined investment strategy; • Are comfortable paying quarterly, asset-based (percentage) fees for investments and advice rather than individual commissions or sales charges. EFA offers a variety of advisory programs, many of which engage the services of third-party asset managers (“TPAM”) with discretionary trading authority, and some in which the client is required to authorize some or all trading activity in their account. Clients should ensure they understand the nature of their advisory agreement with EFA and any other TPAM they engage to provide asset management and/or financial planning services. Financial planning and consulting services are available through EFA and its network of Investment Adviser Representatives (“advisory representatives” or “IAR”). Advisory representatives can offer financial planning services whereby the client receives a financial or investment plan, or similar service, for a fee. Services will generally include a written financial plan addressing the topics agreed upon in the planning agreement. Depending on their needs, clients have the option to select either a full financial analysis or an analysis of a specific financial area. In any event, the analysis will contain generic recommendations for the client and will not include specific product recommendations. Advisory representatives also offer financial consulting services, which are more limited in scope, under a separate consulting agreement. EFA makes asset management services available to its clients. These programs can be managed by multiple third-party investment advisers, or by the advisory representatives and the client. EFA acts as the adviser or co-adviser on certain of its advisory program offerings, specifically: • ESI Illuminations • American Funds Retirement Plan Solutions • AssetMark (advisor model) • Saratoga Advantage Trust • Schwab Retirement Advisor Services • SEI Investments Third-party asset managers (“TPAMs”) can, and often do, use proprietary funds in their model portfolios. Clients should refer to the appropriate third-party manager’s Form ADV Part 2A disclosure brochure for additional information on fund and share class selection specific to their selected model portfolio. EFA’s asset management programs are intended to meet an individual’s needs and goals based on an analysis of the client’s liquidity, time frame, and income and tax bracket, as well as an evaluation of the client’s risk tolerance and investment objective. The client’s advisory representative will seek to review and update this information at least annually, or at the client’s request. EFA asset management programs use different investment vehicles to meet a client’s needs and goals. Depending on the program selected, ES0408(0326) 4  the following types of investments are used: oil and gas U.S. government securities Certificates of deposit Options Cash equivalents Over-the-counter securities Interests in partnerships (real estate, interests, equipment leasing) Exchange-listed securities Corporate debt securities Municipal securities Mutual fund shares Interval fund shares Recommended investment strategies are primarily long-term strategies. However, based on the client’s needs and goals, short-term strategies and trading may be suitable, as well as margin transactions or option writing (including covered options, uncovered options, or spreading strategies). Clients have the ability to impose restrictions on investing in certain securities or types of securities, subject to the discretionary manager’s ability to comply with the request. EFA offers investment advisory services through the following asset management programs: ESI Illuminations Working with Fidelity Institutional Wealth Advisors (“FIWA”)1, EFA offers a customized investment management platform called ESI Illuminations (“Illuminations”) through FIWA’s advisory platform, Fidelity Managed Account Xchange, or “FMAX”. The following asset management programs are available on the ESI Illuminations platform: Third-Party Strategist, Advisor as Portfolio Manager, Multi-Manager Accounts, Unified Managed Accounts, and Separately Managed Accounts. For a full description of the ESI Illuminations platform, including programs, fees and expenses, please refer to ESI’s Form ADV Part 2A- Appendix 1 brochure. American Funds Retirement Plan Solutions (“American Funds”) American Funds is generally designed to serve small and mid-sized employer-sponsored retirement plans, but also offers solutions for large plans. American Funds provides retirement plans with investment options consisting of mutual funds and stable value funds. In designing the plan, the client, the plan sponsor, selects an investment menu from the American Funds platform. These solutions are available in a variety of share classes to accommodate varying plan objectives. The Plan Sponsor will determine the appropriate investments and share class(es) for the plan offerings. Plan design is based on a variety of factors, including administration objectives, plan size, financial advisor service levels, investment choice, and over-all expense objectives, and the investment options – including the fund families and risk level – will vary based on the platform selected. AssetMark (Advisor Model) AssetMark offers asset allocation services. Working with AssetMark, EFA, through its advisory representatives, assists clients in establishing an investment strategy consistent with their investment objectives and risk tolerance. The creation of the investment strategy is based on a client profile questionnaire that helps determine such factors as risk tolerance, investment objectives, and financial goals. AssetMark provides advisory services to EFA clients on a discretionary basis. Account administration, fee billing and performance reporting are provided via internet-based software. EFA acts as co-adviser on AssetMark’s advisor model portfolios, and shares in the fees collected by AssetMark. AssetMark utilizes the custodial services of AssetMark Trust Company, Pershing, and TD Ameritrade. The specific custodial arrangement is established under an agreement between the customer and the custodian, separate from the customer’s agreement with AssetMark. This program is closed to new investors. Saratoga Advantage Trust ("Saratoga") Saratoga offers objective setting and asset allocation services. EFA, through its advisory representatives, prepares asset allocation recommendations for each client based on an investor profile questionnaire. Saratoga Capital Management, LLC, selects the sub-advisors for the various funds, recommends portfolio models based on the investor profile questionnaire, and provides detailed quarterly performance reports to the IARs and clients. Saratoga changes model allocations based on their capital market 1 EFA and FIWA are not affiliated. ES0408(0326) 5  assumptions. Clients determine whether or not to follow the model recommendations made by Saratoga Capital Management, LLC. EFA acts as advisor, and shares in the fees collected by Saratoga. Custodial services are provided by First National Bank for IRA assets, and by BNY Mellon for all other accounts. This program is closed to new investors. Schwab Retirement Advisor Services (“SRAS”) SRAS is a retirement plan platform. Custodial services are provided by Charles Schwab Trust Bank and brokerage services are provided through Charles Schwab & Co., Inc. (“Schwab”) SRAS provides clients with access to mutual fund and ETF investments for use in their retirement portfolio. Working through SRAS, clients will establish an investment strategy consistent with their investment objectives and risk tolerance based on a questionnaire and client profile. Once an investment strategy is established, assets are invested through Schwab. Clients have the option of selecting their own investments, without the assistance of a professional asset manager, or they have the option of selecting a professional discretionary asset manager from a list provided through SRAS. Minimum investments will vary, depending on the plan sponsor. SEI Investments ("SEI") SEI offers objective setting and asset allocation services. Working with SEI, EFA, through its advisory representatives, assists clients in establishing an investment strategy consistent with their investment objectives and risk tolerance based on a questionnaire and client profile. SEI acts as sponsor, and SEI Investments Management Corporation is the discretionary investment manager for both the Managed Account Program and the Integrated Managed Account. SEI selects the sub-advisors for the various mutual funds, initiates quarterly portfolio re-balancing, and provides detailed quarterly performance reports to the clients and IARs. EFA acts as co-adviser, and shares in the fees collected by SEI. SEI Private Trust Company acts as custodian for the assets. There is no minimum investment. Item 5 – Fees and Compensation Fee-Based Accounts When making the determination of whether one of EFA's advisory programs is appropriate for their needs, clients should bear in mind that fee-based accounts, when compared with commission-based accounts, often result in lower transaction costs during periods when trading activity is heavier, such as the year an account is established. However, during periods when trading activity is lower, fee-based accounts may result in a higher annual cost to the client than a traditional brokerage account. Thus, depending on a number of factors, the difference in total cost of a fee-based account compared to a commission-based account can vary significantly. Factors which affect the cost of a fee-based account include the account size, as well as the investment advisory fee you have negotiated with your Advisor. Factors which affect the cost of a commission-based account that charges transaction fees include the number of transactions in the account, the types and quantities of securities purchased or sold and commission rates. Clients should discuss any proposed program with their advisory representative and read this Brochure carefully, as it explains the programs in detail. The specific manner in which fees are charged by EFA is established in a client’s written agreement with EFA. EFA will generally bill its fees on a quarterly basis. Clients are charged for advisory services either in advance or arrears, each calendar quarter, depending on which advisory program they choose. Clients authorize the appropriate custodian to directly debit fees from their accounts, which are then paid to EFA for services provided. Advisory fees for each program are described below. Program sponsors establish the minimum and maximum fee ranges associated with each of their respective programs. These ranges vary between programs and create a conflict to representatives in that there is an incentive to recommend programs with higher minimum investments and/or maximum allowable fees to generate higher fees. On a quarterly basis, a portion of the fee for service (typically between 50%-85% of the fee) is paid to the IAR according to their compensation agreement with EFA. The total advisory fee is exclusive of brokerage commissions, transaction fees, and other related costs and expenses which are incurred by the client. Clients incur certain charges imposed by custodians, brokers, third-party investment managers, and other third parties, such as: advisory fees, custodial fees, deferred sales charges, odd-lot differentials, ES0408(0326) 6  transfer taxes, wire transfer and electronic fund fees, IRA fees, and other fees and taxes on brokerage accounts and securities transactions. Such expenses may be avoided through the selection of mutual fund share classes which do not include such fees, provided the funds make these share classes available. Mutual funds and ETFs also charge internal management fees, which are disclosed in each fund’s prospectus. Clients may incur deferred sales charges on previously purchased mutual funds. Clients have the ability to purchase mutual fund shares directly from fund companies, without utilizing the services of an adviser. Doing so could provide clients with similar market exposure without paying advisory fees. Fees and Expenses: 12b-1 Fees Third-party managers, in their sole discretion, have the ability to utilize funds that pay additional compensation to ESI, such as 12b-1 (trail) fees. Other available funds do not pay ESI 12b-1 fees. This creates a conflict of interest, because it creates a financial incentive, specifically the receipt of additional compensation, for ESI to recommend mutual funds with greater expenses. Fees and Expenses: No-Transaction Fee (“NTF”) Funds and Transaction Fee (“TF”) Funds TPAMs have the ability to use certain funds that do not incur transaction fees when traded, commonly referred to as no-transaction fee (NTF) funds. However, compared to other comparable funds, NTF funds typically have higher internal expenses, charged as a percentage of the assets in the fund and deducted from its value. Accordingly, these higher internal expenses reduce the returns of NTF funds. Third-party managers may or may not include the use of NTF funds, based on each individual portfolio manager’s discretion. If clients are uncomfortable with the use of NTF funds in their portfolio, and would prefer to pay transaction fees, they should work with their advisory representative to ensure their chosen program addresses their concerns. Sometimes, but not always, clients could save money by paying transaction fees instead of investing in more expensive NTF funds. Clients should review the Form ADV Part 2A of any third-party manager being considered, to learn about their use of NTF funds. Clients may or may not be able to restrict the third-party manager’s use of NTF funds. Therefore, clients who are uncomfortable with the use of NTF funds in their portfolio, and would prefer to pay transaction fees, but are unable to prevent their use, should talk to their advisor regarding other advisory program options. Other Revenue Revenue Sharing Arrangements The Firm has revenue sharing agreements with selected third-party asset managers (“TPAM”), collectively referred to as Strategic Partners, which pay additional material compensation in the form of a set amount or a percentage of assets under management. As a result, the Firm faces a conflict of interest in that it has an incentive to promote certain programs that provide additional compensation over others which do not, but which offer similar services. Certain other fund sponsors and/or TPAMs that do not participate in the Strategic Partners program, but whose funds may be used in advisory accounts, make marketing payments to ESI to sponsor certain meetings or events. These include American Funds, AssetMark, BlackRock Funds, LiveWell, PIMCO, Symmetry, and Vanguard. As such, the Firm has an incentive to promote use of these funds, over other available funds, in programs in which the IAR acts as the portfolio manager, specifically Flagship Select, ESI Directions, and ESI Compass, as described in the Firm’s Form ADV Part 2A-Appendix 1 brochure. Compensation From Securities and Other Investments ESI, acting in its capacity as a broker-dealer, sells various securities and investment products from a number of different product sponsors, including ESI’s affiliates, National Life and LSW. These products include mutual funds, variable annuities, alternative investment products, Real Estate Investment Trusts (REITs), structured CDs, variable universal life insurance, options, municipal bonds, 529 college savings plans, and fixed indexed annuities. Fixed indexed annuities are not securities products, and ESI sells these products through registered representatives, who may be dually registered as IARs, in their capacity as insurance agents. Through its Strategic Partner program, ESI has established relationships with various participating product providers which pay additional compensation to ESI based on sales of their products. ES0408(0326) 7  When an IAR sells one of these products, ESI and the IAR can receive additional compensation from the transaction. This creates a conflict of interest in that there is an incentive to sell products for which the Firm and the advisory representative receive more compensation. The Firm reviews potential conflicts of interest as part of its due diligence review of new and existing programs and product offerings. To mitigate this conflict, ESI has policies and procedures to ensure that recommendations made are in our clients’ best interest. For a detailed description of fees, expenses, and revenue from the sale of these products, please see ESI’s Regulation Best Interest disclosure document at www.equity-services.com. How Accounts Are Billed The following section details the fee schedules for EFA’s direct co-advised programs. Please note that advisory fees (those charged for services provided by the IAR) are subject to negotiation and often differ between clients, depending on the level of services provided, as long as the actual fee is not above the maximum in the stated fee schedule. American Funds Retirement Plan Solutions Clients are charged a quarterly asset management fee by EFA, based on the value of the plan’s holdings at the end of each calendar quarter. Billing is in arrears and subject to the following maximum fee schedule: Plan Market Value Quarterly Fee Total Annual Fee Annual Flat Fee (assessed quarterly) $1 to $1,000,000 Not more than 0.25% 0.25% X 4 = 1.00% $10,000 $1,000,001 to $2,500,000 Not more than 0.1875% 0.1875% X 4 = 0.75% $18,750 $2,500,001 to $4,999,999 Not more than 0.15% 0.15% X 4 = 0.60% $30,000 $5,000,000 to $10,000,000 Not more than 0.125% 0.125% X 4 = 0.5% $50,000 $10,000,001 or more Not more than 0.0875% 0.0875% X 4 = 0.35% $3,500 per million to (rounding up nearest million) The actual fee charged is specified in the advisory agreement and, upon the agreement of all parties, the actual fee charged to a client may be lower than the fee schedule above. Limits are imposed based on the value of the Plan Market Value at the time your Agreement is signed. Any future fee reduction, including a reduction based upon an increase in value of the Plan Market Value, must be subsequently agreed to by the Financial Advisor and the Plan Sponsor, documented in writing, and transmitted to and accepted by American Funds Retirement Plan Solutions. Plan Market Value includes only the assets within the American Funds Retirement Plan Solution, and not other assets of the Plan. Should an account close during a quarter, a pro-rata fee is deducted from the account. This pro-rata fee will reflect the number of days in the quarter that the assets were managed. AssetMark (Advisor Model) Fees are payable in advance and are calculated based on the average daily balance of the previous quarter. Advisory fees are negotiated with the advisor (not to exceed 1.5%) and are assessed in accordance with the client’s AssetMark advisory agreement. Clients who close their AssetMark account before the end of a quarter shall be reimbursed for those days remaining in the quarter for which asset management services will not be provided. Saratoga Clients are charged a quarterly asset management fee by EFA, based on the value of the client’s holdings at the end of each calendar quarter. Billing is in advance and is based on the advisory fee schedule outlined in the advisory agreement. Upon the agreement of all parties, the actual fee charged to a client ES0408(0326) 8  may be higher or lower from the stated fee schedule, as long as the actual fee is not above the maximum fee of 2.00%. Clients who close their Saratoga account before the end of a quarter shall be reimbursed for those days remaining in the quarter for which asset management services will not be provided. Schwab Retirement Advisor Services Clients are charged a quarterly asset management fee by EFA, based on the value of the plan’s holdings at the end of each calendar quarter. Billing is in arrears and based on the following fee schedule: Plan Market Value Quarterly Fee Total Annual Fee Annual Flat Fee (assessed quarterly) $1 to $1,000,000 Not more than 0.25% 0.25% X 4 = 1.00% $10,000 $1,000,001 to $2,500,000 Not more than 0.1875% 0.1875% X 4 = 0.75% $18,750 $2,500,001 to $4,999,999 Not more than 0.15% 0.15% X 4 = 0.60% $30,000 $5,000,000 to $10,000,000 Not more than 0.125% 0.125% X 4 = 0.5% $50,000 $10,000,001 or more Not more than 0.0875% 0.0875% X 4 = 0.35% $3,500 per million to (rounding up nearest million) The actual fee charged is negotiable and is specified in the advisory agreement. Upon the agreement of all parties, the actual fee charged to a client may be lower than the fee schedule above but may not exceed the maximum stated above. Clients who close their account during a quarter will have a pro-rata fee deducted. This pro-rata fee will reflect the number of days in the quarter for which asset management services were provided. SEI Clients are charged a quarterly asset management fee by EFA, based on the value of the client’s holdings at the end of each calendar quarter. Upon the agreement of all parties, the actual fee charged to a client may be higher or lower from the stated fee schedule, as long as the actual fee is not above the maximum fee of 1.75%. Additionally, EFA charges 5 basis points (0.05%) for administrative costs associated with SEI accounts. Billing is in arrears and based on the advisory fee schedule outlined in the advisory agreement. Clients who close their account during a quarter will have a pro-rata fee deducted from the account. This pro-rata fee will reflect the number of days in the quarter for which asset management services were provided. SEI Private Client Model accounts have a lower administrative fee, compared to other programs offered by EFA. This creates a conflict of interest for representatives in that they retain more of the advisory fee associated with SEI accounts than with those in other available programs. Conversely, EFA is conflicted in that it is incented to promote programs other than SEI which might otherwise generate more revenue to the Firm. Financial Planning/Consulting Services Fees for financial planning/consulting services are negotiable, and are based on various factors including, but not limited to: the types of services provided, the complexity of the client’s finances, and time involved in plan development. In no case will EFA accept advance fees for financial planning/consulting services that are greater than $1,200, unless the parties agree that all services will be completed within six months from the receipt of such payment. Financial Planning Clients may choose to obtain a single financial plan, or to obtain financial plans on a recurring basis. Clients who engage with an advisor for a single financial plan agree with their advisor to pay a fixed fee for the plan. Clients may pay for all or part of their financial plan when they sign the financial planning agreement, and/or they may pay for all or part of their financial plan when it is delivered, according to the ES0408(0326) 9  payment arrangement decided upon with the advisor. Clients retain the right to terminate the financial planning agreement prior to the delivery of the financial plan by notifying EFA per the terms of the financial planning agreement. Clients selecting this option who pre-pay fees but terminate a financial planning agreement prior to the client delivery of a financial plan will receive a refund of fees paid, minus a prorated amount (as determined by EFA) for services provided prior to the termination. Alternatively, clients may elect to receive a financial plan on a recurring basis. Under this option, clients will generally receive an updated financial plan on the anniversary of their original agreement for the same fee. The client’s method of payment will be billed when they sign a financial planning agreement, as the first of equal monthly or quarterly installments until the fee for the plan is paid. The client will receive an updated financial plan each year and will pay for the subsequent financial plans in the same manner, until the agreement is terminated. A client that chooses a recurring financial plan may terminate the agreement at any time, including after the delivery of a plan, in which case billing will stop when the last delivered plan has been fully paid for. The initial plan and updated plans, thereafter, will generally be delivered within four months, and in no event more than six months, from the execution or anniversary date of the financial planning agreement, as applicable. If the plan due is not delivered within six months, all fees that EFA received for the associated plan will be refunded. Financial Consulting Financial consulting agreements may be paid in full upon completion of services. Alternatively, fees for consulting services may be paid in whole or in part in advance. Clients may pay all or a portion of the fee, as agreed to with the IAR, upon signing the financial consulting agreement but before services are delivered, with the balance due and payable upon the completion of services. If the client agrees to this method of payment, the entire payment will become due when services are completed. Financial consulting services are not eligible for monthly or quarterly installment payment plans. Clients retain the right to terminate their financial consulting agreement prior to the delivery of services by notifying EFA per the terms of the financial consulting agreement. Clients who pre-pay fees but terminate a financial consulting agreement prior to the final delivery of services will receive a refund of fees paid, minus a prorated amount (as determined by EFA) for services provided prior to the termination. Financial Planning/Consulting Fees Advisory representatives are permitted to charge a fee for services provided, based on an analysis of multiple factors and subject to the agreement, and will generally not exceed a total of $15,000 per agreement. For a discussion of how the Firm identifies and addresses potential conflicts of interest which arise from fees and compensation, please refer to Item 11 (Code of Ethics). Additional detail regarding EFA’s brokerage relationships is available under Item 12 (Brokerage Practices), as well. Item 6 – Performance-Based Fees and Side-By-Side Management EFA does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 – Types of Clients EFA provides portfolio management services to individuals, corporations, trusts, estates, charitable organizations, and retirement plans including pension and profit-sharing plans. Most asset management programs offered by EFA have minimum account sizes to open/maintain an account ranging from $10,000 to $750,000. Details on these minimums are explained by the various asset managers’ program description materials. The Firm reserves the right to prohibit anyone or any account type from investing in any of its advisory programs if it believes the recommended program is not an appropriate investment strategy for the client. ES0408(0326) 10  Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss EFA’s advisory representatives generally use technical and/or fundamental analysis when analyzing securities. Technical analysis generally involves studying trends and movements in a security’s price, trading volume, and other market-related factors in an attempt to discern patterns. Fundamental analysis generally involves assessing a company’s or security’s value based on factors such as sales, assets, markets, management, products and services, earnings, and financial structure. Sources of information for analysis include research material acquired from outside vendors, financial newspapers and magazines, annual reports, prospectuses, filings with the SEC and company press releases. Investment strategies used to implement investment advice to clients include: long term purchases (securities held at least a year), short term purchases (securities sold within a year), trading (securities sold within 30 days), margin transactions, and/or option writing. EFA will utilize certain asset allocation tools and investment research materials prepared by third-party investment advisers in constructing an appropriate asset allocation for a client and in monitoring the performance of the investment portfolio selected. Clients can learn more about the methods of analysis, investment strategies, and risk of loss associated with the advisory platform providers offered by EFA by reviewing the Form ADV Part 2A of those advisers. Investing in securities involves several risks of which clients should be informed, and prepared to bear, prior to investing. The list below explains the various forms of risk associated with investing in securities. Common stocks may decline significantly in price over short or extended periods of time. Price changes may occur in the market as a whole, or they may occur in only a particular country, company, industry, or sector of the market. In addition, the types of stocks in which a particular fund invests, such as value stocks, growth stocks, large-capitalization stocks, mid-capitalization stocks, small-capitalization stocks and/or micro-capitalization stocks, may underperform the market as a whole. In addition, growth stocks can be more volatile than other types of stocks. Value stocks can continue to be undervalued by the market for long periods of time. Additionally, dividends paid on common stocks can vary significantly over the short-term and long-term. Dividends on common stocks are not fixed but are declared at the discretion of an issuer’s board of directors. There is no guarantee that the issuers of common stocks in which a portfolio invests will declare dividends in the future or that if declared they will remain at current levels or increase over time. Fixed income risks include credit risk, interest rate risk, and high yield risk. Liquidity risk is the risk that an investor may not be able to sell shares at an advantageous time or price. Interval funds, for example, offer investors the opportunity to generate income but only offer liquidation of shares on a limited basis (for example: redemptions may be limited to a maximum of 5% of the fund’s assets) and only during defined time periods. Additionally, there is no secondary market for interval fund shares. Credit risk is the risk that an issuer of a debt security will be unable to make interest and principal payments when due and the related risk that the value of a security may decline because of concerns about the issuer’s ability to make such payments. Credit risk may be heightened for portfolios that invest in “high yield” securities. Interest rate risk is the risk that the value of a portfolio will decline because of rising interest rates. Interest rate risk is generally lower for shorter-term investments and higher for longer-term investments. Duration is a common measure of interest rate risk. Duration measures a bond’s expected life on a present value basis, taking into account the bond’s yield, interest payments and final maturity. The longer the duration of a bond, the greater the bond’s price sensitivity to changes in interest rates. High yield, or below investment grade securities may be more susceptible to real or perceived adviser economic conditions than investment grade securities. In addition, the secondary trading market for below investment grade securities may be less liquid. High yield securities generally have more volatile prices ES0408(0326) 11  and carry more risk to principal than investment grade securities. International Investing Risk is the risk associated with investing in securities or issuers in markets other than the United States. Foreign issuers may be subject to risks not typically associated with U.S. companies, such as: currency risk, risks of trading in foreign securities markets, and political and economic risks. Currency Risk is associated with the trading of securities in currencies other than the U.S. dollar. Because foreign securities generally trade in currencies other than the U.S. dollar, changes in currency exchange rates will affect an account's value, the value of dividends and interest earned, and gains and losses realized on the sale of securities. A strong U.S. dollar relative to these other currencies will adversely affect the value of an account. Foreign Securities Market Risk is the risk that securities of many non-U.S. companies or U.S. companies with significant non-U.S. operations may be less liquid and their prices more volatile than securities of comparable U.S. companies. Securities of companies traded in many countries outside the U.S., particularly emerging markets countries, may be subject to further risks due to the inexperience of local investment professionals and financial institutions, the possibility of permanent or temporary termination of trading, and greater spreads between bid and asked prices for securities. In addition, non-U.S. stock exchanges and investment professionals are subject to less governmental regulation, and commissions may be higher than in the U. S. Also, there may be delays in the settlement of non-U.S. stock exchange transactions. Political and Economic Risks are a factor when investing in international companies due to varying levels of stability in political, social, or economic factors in the country of the issuer of a security, the difficulty of predicting international trade patterns, the possibility of the imposition of exchange controls, expropriation, limits on removal of currency or other assets, and nationalization of assets. Acting in their discretionary authority, unaffiliated third-party asset managers (TPAMs) retain the ability, outside EFA’s control, to implement changes to their managed portfolios. For example, a TPAM may determine to convert a portfolio’s holdings from a mixture of mutual funds to solely the use of ETFs to lower expenses. While such changes must be within the parameters of their investment mandate and must align with their fiduciary responsibility, they can, on occasion, result in a taxable event for shareholders. Additionally, income from foreign issuers may be subject to non-U.S. withholding taxes. Non-U.S. companies generally are not subject to uniform accounting, auditing, and financial reporting standards or to other regulatory requirements that apply to U.S. companies; therefore, less information may be available to investors about non-U.S. issuers. In addition, some countries restrict foreign investment in their securities markets, which may limit or preclude investment in certain countries or may increase the cost of investing. The above risks may be particularly significant in emerging markets countries. To the extent an account invests in depositary receipts, it will be subject to the same risks as when investing directly in foreign securities. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to an evaluation of the Firm or the integrity of its management. ESI is a registered broker/dealer as well as a federally registered investment adviser doing business as EFA. Pursuant to the Securities Exchange Commission’s (“SEC”) Share Class Selection Disclosure initiative, Equity Services, Inc. (“ESI”) self-reported its use of mutual funds that made payments of fees to EFA pursuant to Rule 12b-1 of the Investment Company Act of 1940, in several of its advisory programs. Subsequently, the SEC alleged that, during the period of January 1, 2014 to July 7, 2017, ESI did not adequately disclose to its clients its receipt of, nor the conflict of interest ES0408(0326) 12  created by, 12b-1 fee revenue and/or its selection of mutual fund share classes that resulted in 12b-1 revenue to ESI. Without admitting or denying the findings, ESI agreed to an order from the SEC which imposed the following terms: (1) cease and desist from committing or causing any further violations of Section 206(2) of the Advisors Act of 1940; (2) censure by the SEC; and (3) disgorgement of fees and prejudgment interest to affected clients totaling $587,017.22. The settlement was accepted by the SEC on September 30, 2019. Item 10 – Other Financial Industry Activities and Affiliations ESI is registered as a broker-dealer with the SEC, FINRA and all fifty states. ESI devotes a substantial portion of its time and derives a substantial portion of its revenue from its operations as a broker-dealer. As a broker-dealer, ESI offers the following investment and insurance products: general securities, mutual funds, fixed income securities, alternative investment products, unit investment trusts, variable annuities and variable life products, indexed annuity products, direct participation programs, real estate investment trusts, and structured CDs. EFA is under common control with NLG Capital, LLC, a registered investment adviser. EFA is an affiliate of National Life. Most of EFA’s advisory representatives are also life insurance agents of National Life. National Life provides space and certain other services to EFA. LSW is another affiliated insurance company that offers fixed annuity products. Many of EFA’s advisory representatives are appointed with LSW to sell fixed products. EFA and its advisory representatives can offer affiliated products or services to advisory clients in order to execute certain transactions recommended within a financial plan. Clients are free to execute transactions recommended as part of a financial plan through any broker-dealer or product issuer they choose. If the purchase or sale of financial products recommended as a part of a financial plan is executed with an affiliate of EFA, EFA and the advisory representative receive compensation, including commissions and other compensation, in addition to the advisory fee paid. EFA and its affiliates receive, in the aggregate, more revenue in connection with the sale of affiliated products than with unaffiliated products. This additional revenue often comes in the form of shared revenue based on assets under management, administrative, distribution, and/or other fees for services provided by affiliates of EFA in support of affiliated products. Thus, EFA has an incentive to offer affiliated products over unaffiliated products. As a result, the Firm faces a conflict of interest to the extent that it has an incentive to promote certain programs which use affiliated products over other programs which don’t use affiliated products or use affiliated products to a lesser extent. In some relationships, investment advisers or TPAMs pay EFA for client referrals. The nature of relationships between the TPAM, EFA, and the client is more fully described in the contracts entered into with each TPAM. In each relationship, EFA will receive a portion of the fee charged (commonly referred to as the “promoter fee”). EFA provides the TPAM’s Form ADV Part 2A (or similar disclosure brochure) and a Promoter’s Disclosure to the client. The promoter fee paid to EFA varies by TPAM. Accordingly, EFA faces a conflict of interest in that it has an incentive to refer clients to programs from which it would receive higher compensation. EFA receives payments from firms or persons that offer asset management or separate account products or services which are included in a preferred list of product providers (referred to as "Strategic Partners"). These payments take the form of conference, program, or event attendance; participation or exhibition fees; educational and training fees; or fees linked to program participation or specific marketing initiatives within an existing program. None of these additional payments are paid or directed to any advisory representative who sells these products. Nonetheless, when recommending an asset management program to their clients these marketing payments and educational opportunities present a conflict of interest to the extent that such payments incentivize advisory representatives to recommend Strategic Partners, as opposed to other advisers that do not make such payments. Among its advisory programs, ES0408(0326) 13  EFA's Strategic Partners are: AssetMark, Brinker Capital, Fidelity Institutional Wealth Advisors, Freedom Advisors, Maple Capital Management, Summit Global Investors, and Touchstone Advisors. Many IARs own and operate their own independent companies separate from EFA. Such IARs provide one or more services through these unaffiliated companies including, but not limited to, accounting/tax services, business consulting and insurance brokerage services. If a client engages an IAR to provide any such services, these services are offered and performed solely in the IAR’s private and/or professional capacity, and not as a representative of the Firm. For additional discussion of how the Firm identifies and addresses potential conflicts of interest, please refer to Item 11 (Code of Ethics). Item 11 – Code of Ethics EFA has adopted a Code of Ethics (“the Code”) that mandates high standards of business conduct and professionalism. EFA, through its advisors, will provide a copy of its Code of Ethics to any client or prospective client upon request. In general, the Code addresses certain groups of persons: Supervised Persons and Access Persons. The term “Supervised Persons” refers to any partner, officer, director, employee, or IAR of the Firm. “Access Persons” represent a subset of this population and refers specifically to those individuals who have access to (1) nonpublic information regarding any clients’ trading activity, (2) nonpublic information regarding the portfolio holdings of any reportable fund, or (3) those who are involved in making securities recommendations to clients or who have access to such recommendations that are nonpublic. The Code prohibits EFA's Supervised Persons from purchasing initial public offerings (“IPOs”) or trading on material non-public information. Additionally, the Firm’s Access Persons are required to report their securities holdings upon initial hire, and again annually. Quarterly reporting of personal securities transactions is also required for Access Persons. EFA’s Supervised Persons must acknowledge the terms of the Code annually. The Code requires that advisory representatives render disinterested and impartial advice and make appropriate recommendations to clients based on an analysis of their needs. Conflicts of interest arise when a recommendation could result in additional compensation to the Firm and/or the advisory representative through the Firm’s business relationships or through the execution of commissionable transactions. Such conflicts are a consideration for the Firm’s Principal Compliance Analysts in their review of new accounts and transactions. The Firm addresses conflicts of interest and potential conflicts of interest by periodically reviewing them during EFA’s senior management meetings, and through disclosure to its clients, such as that contained in this Brochure. Additionally, the Firm and the advisory representative can face conflicts of interest when providing services to retirement accounts. This occurs when an advisory representative recommends that you transfer your retirement account from a different financial institution to our firm, because doing so will result in the Firm and the advisory representative receiving compensation that we would not otherwise receive. Conflicts of interest can also arise with existing customers when an advisory representative recommends a new type of account that has a different compensation structure that will increase compensation. For example, this could occur if an advisory representative recommends: 1) Transferring assets in a brokerage account (which generates compensation when a transaction is made) to an advisory account (which charges an annual fee for ongoing management), 2) Taking money from a qualified plan and doing an IRA rollover, 3) Transferring assets from an IRA to a qualified plan, 4) Transferring an IRA account to a new IRA, 5) Transferring qualified plan assets to a new investment provider, or 6) Changing the type of account being used for an IRA (such as recommending that a commission- based account be changed to a fee-based account). All Supervised Persons whose activities could encompass the solicitation of government clients are required to pre-clear political contributions to local or state candidates, or candidates for federal office ES0408(0326) 14  who currently hold a state or municipal office, to state and local political parties, or to political action committees. Advisory representatives occasionally buy, hold, or sell securities for their own accounts that are also recommended to, or bought or sold for, their clients at the same time or at different times as clients are trading in these securities. However, neither EFA nor any employee may receive preferential treatment over clients. It is EFA’s policy that the Firm will not affect any principal or agency cross transactions for client accounts. EFA will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser (that is, an advisory firm), acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions arise when an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Cross trades occur where an adviser causes a client account to sell a security to another client account, whether or not a commission is charged in the transaction. EFA and its affiliates also contribute amounts to various non-cash and cash incentives paid to EFA’s advisory representatives based on the achievement of specified sales goals for certain securities, as described in Item 14 (Client Referrals and other Compensation). Incentive programs are reviewed by EFA’s Compliance Department. The review of such programs seeks to ensure that all such incentives adhere to applicable rules. Conflicts of interest are managed through public disclosure to clients and prospective clients, and on the Firm’s public website. Unaffiliated TPAMs occasionally pay travel, meal and other expenses for advisory representatives and others who visit the TPAM’s offices or other locations (including hotels and conference centers) to learn about its products and services. This creates a conflict of interest for IARs who may be incented to favor doing business with certain TPAMs over others, on the basis of benefits received in conjunction with such visits. EFA’s advisory representatives have an incentive to choose certain programs based on the maximum fee that can be charged given the asset value of the account, as well as whether the advisory representative bears additional program charges. This creates a conflict of interest for the advisory representative, as they generally retain more of the revenue generated by fees in programs that do not include platform fees or other administrative fees as part of the overall advisory fee. The Firm reviews potential conflicts of interest as part of its due diligence review of new and existing programs. The Firm provides disclosure to clients and potential clients of its fee structure and revenue agreements in this Brochure, as well as through the revenue sharing disclosure documents posted on its public website (www.equity-services.com). Item 12 – Brokerage Practices EFA and its advisory representatives offer brokerage services to advisory clients in order to execute certain transactions recommended within a financial plan. Clients are free to execute securities transactions recommended as part of a financial plan through any broker-dealer they choose. If ESI is the broker-dealer selected to execute the purchase or sale of financial products recommended as a part of a financial plan, ESI and the advisory representative will receive additional compensation (including commissions, 12b-1 fees, and NTF revenue sharing, as applicable) in addition to the financial planning fee paid. EFA generally has written agreements whereby clients agree that all brokerage transactions will be executed through NFS, unless otherwise directed by the client. EFA is also a registered broker dealer, doing business as Equity Services, Inc. ("ESI"). ESI has entered into a clearing arrangement with NFS. ESI will, therefore, be viewed as recommending itself to clients as a broker-dealer in these situations. ESI acts as the introducing broker-dealer in this arrangement and can receive transactional compensation. Under certain circumstances, ESI will forego ES0408(0326) 15  seeking and obtaining more favorable prices and lower commission rates or other charges, when executing trades through NFS, than ESI may otherwise be able to obtain by negotiating better prices or lower rates of commission with certain other broker-dealers. However, executing transactions through NFS can benefit clients when NFS aggregates client trades with orders from its other clients. This aggregation can provide savings on execution costs through volume discounts that ESI would not otherwise be able to negotiate or obtain for other clients who do not execute trades through NFS. ESI regularly reviews pricing and execution through the use of various reports received, which detail comparative execution data. Such reports are periodically reviewed by senior management. ESI, in its capacity as a broker-dealer, often executes securities transactions for its advisory clients, including, but not limited to, transactions in securities distributed or underwritten by an affiliate. ESI’s fully disclosed clearing relationship with NFS provides for the offering of stock, bond and options trading. EFA and its advisory representatives generally receive compensation, including commissions on transactions for which ESI acts as broker-dealer, in addition to that which is received for the performance of advisory- related services. Item 13 – Review of Accounts Each advisory representative and his/her client will individually determine the frequency of reviews for the account(s) governed by an investment advisory agreement between the client and EFA. Factors triggering such a review will include but are not limited to: changing circumstances in the client's financial and personal life; the performance of the portfolio in both absolute terms, and relative to the client's goals, objectives and risk tolerance; and at the request of the client. In most cases, the review will be conducted by the advisory representative who performed the initial investment advisory services. EFA utilizes software tools and/or review either exception reports or statements for accounts on which EFA is adviser or co-adviser, to detect and make recommendations to correct variations from client mandates that are beyond variance tolerances established by the Firm. In addition to review by advisory representatives, client accounts are reviewed by EFA Principal Compliance Analysts and/or other home office staff members. Advisory programs offered by EFA provide, at a minimum, quarterly statements from the account custodian showing transactions for the prior quarter, fees, and current asset allocations, and may receive other reports as set forth in their account documentation. Item 14 – Client Referrals and Other Compensation EFA pays individuals or entities, acting as bona fide promoters, a portion of the advisory fee paid to EFA by the client if the client is referred to EFA by the promoter. All such promoter arrangements will conform to the requirements set forth in Rule 206(4)-1 of the Investment Advisers Act of 1940. In addition to the revenue sharing payments from NFS discussed above, ESI (acting in its capacity as broker/dealer) also receives additional compensation as a broker-dealer for the sales of securities issued and/or distributed by members of its Strategic Partners program. The Strategic Partners Program currently includes the following issuers: Investment Trusts: BlackRock Funds, LiveWell, • Mutual Funds/Interval Funds/Unit PIMCO, Touchstone Advisors • Variable Annuities: Allianz, Brighthouse, Corebridge, Equitable, Jackson National, • Lincoln National, Pacific Life, Prudential, Transamerica Indexed Annuities: Allianz, American National Life, Lincoln National, Nationwide, North American, One America, The Standard, US Life Insurance Company • Direct Participation Programs: RREEF Property Trust Marketing and Training Support Certain product sponsors may make other payments to EFA intended to reimburse the firm's representatives for marketing expenses, such as client seminars, marketing materials, etc. Marketing ES0408(0326) 16  reimbursements from sponsors are directed to EFA and subsequently paid by EFA to the representative. Certain product sponsors and investment advisers may incur expense and/or provide reimbursement for educational and training programs. Training and education expenses and reimbursements are paid out of the adviser or affiliate's assets, not from the account assets, and are made to EFA in addition to annual service fees, and other fees and expenses disclosed in the adviser's Form ADV Part 2A, which is available on request from the investment adviser firm. EFA and its affiliates also contribute amounts to various non-cash and cash incentives paid to EFA’s advisory representatives based on the achievement of specified sales goals for securities, including (1) sponsoring sales contests and/or promotions in which participants receive awards or incentives such as travel, merchandise, computer hardware and/or software; (2) paying for occasional meals, lodging and/or entertainment; (3) making cash payments in lieu of business expense reimbursements; (4) making and forgiving business-related loans; (5) cash bonuses and/or; (6) employee benefits, such as health insurance, Social Security contributions, etc. Current information regarding EFA’s Strategic Partners program is found at www.Equity-Services.com or by calling (800) 344-7437. For a discussion of how the firm identifies and addresses potential conflicts of interest which arise from its various business relationships, please refer to Item 11 (Code of Ethics). Item 15 – Custody EFA does not take custody of client funds or securities. Client funds and securities are held with a qualified custodian. Clients should receive, at a minimum, quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s investment assets. Clients should review their statements carefully and compare them to statements or reports they receive from EFA and/or their TPAM. Item 16 – Investment Discretion EFA does not permit its IARs to obtain discretionary trading authority in the American Funds, Assetmark, Saratoga, SRAS, or SEI programs described in this Brochure. Neither EFA nor the IAR have authority to choose or change the client’s investment objective. Item 17 – Voting Client Securities As a matter of firm policy and practice, EFA does not have any authority to, and does not, vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Upon request of the client, EFA may provide advice to clients regarding the clients’ voting of proxies. Item 18 – Financial Information EFA does not require prepayment of more than $1,200 in fees from clients for services that are not required to be completed six months or more in advance and thus has not provided a balance sheet for its most recent fiscal year. EFA does accept payment of financial planning/consulting fees prior to the delivery of the financial plan or service. EFA is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients, nor has EFA been the subject of a bankruptcy petition at any time during the past ten years. ES0408(0326) 17 

SEC File No. 801-41722 ESI Financial Advisors • One National Life Drive • Montpelier, VT 05604 • • (800) 344-7437 • www.equity-services.com ESI Illuminations Form ADV, Part 2A - Appendix 1 March 30, 2026 This wrap fee program brochure (“Brochure”) provides information about the qualifications and business practices of Equity Services, Inc. doing business as ESI Financial Advisors. If you have any questions about the contents of this Brochure, please contact us at 1-800- 344-7437 and/or ESICompliance@nationallife.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about ESI Financial Advisors also is available on the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons affiliated with ESI Financial Advisors who are registered as investment adviser representatives of ESI Financial Advisors. ESI Financial Advisors is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an adviser provide you with information about which you determine to hire or retain an adviser. ES0408A(0326) Cat. No. 51938  Item 2 – Material Changes Effective January 26, 2026 ESI Financial Advisors (“EFA”) completed the conversion of its proprietary advisory program to Fidelity Institutional Wealth Adviser, LLC (“FIWA”) whereby ESI utilizes FIWA’s Fidelity Managed Account Xchange (“FMAX”) platform. This change constituted an assignment of existing clients’ advisory agreements to FIWA and made FIWA a co-advisor with EFA. In conjunction with this change, all ESI Illuminations programs are only offered as wrap fee programs. Item 4 (Services, Fees and Compensation) of this Brochure provides a detailed explanation of advisory programs and account billing following this change. ES0408A(0326) ii  Item 3 -Table of Contents Item 2 – Material Changes ....................................................................................................... ii Item 3 -Table of Contents ....................................................................................................... iii Item 4 – Services, Fees and Compensation ............................................................................ 4 Item 5 – Account Requirements and Types of Clients ........................................................... 11 Item 6 – Portfolio Manager Selection and Evaluation ............................................................ 11 Item 7 – Client Information Provided to Portfolio Managers .................................................. 13 Item 8 – Client Contact with Portfolio Managers ................................................................... 13 Item 9 – Additional Information ............................................................................................. 13 ES0408A(0326) iii  Item 4 – Services, Fees and Compensation Equity Services, Inc. (“ESI”) is a registered broker/dealer, as well as a federally registered investment adviser, doing business as ESI Financial Advisors (“EFA” or “the Firm”). ESI was founded in 1968 as an affiliate of National Life Insurance Company (“National Life”), which began doing business in 1848. NLV Financial Corporation is the sole shareholder of ESI, and the National Life Group companies, which includes National Life and Life Insurance Company of the Southwest (“LSW”). EFA provides financial planning/consulting services and asset management services to individuals, corporations, trusts, estates, charitable organizations, and retirement plans including pension and profit-sharing plans. EFA has been registered with the SEC since 1992. As of 12/31/2025, the Firm managed approximately $1.6 billion in non- discretionary assets and approximately $1.1 billion in discretionary assets across its advisory programs. Before investing in an advisory program, clients should decide if they are comfortable delegating the day- to-day management of their account(s). Investors in advisory programs typically: • Desire advice and guidance when making investment decisions; • When working with a discretionary manager, are at ease with a financial professional making their day-to-day investment decisions; • Are willing to follow a disciplined investment strategy; • Are comfortable paying quarterly, asset-based (percentage) fees for investments and advice rather than individual commissions or sales charges. EFA, through its Investment Adviser Representatives (“IAR” or “advisory representative”), offers asset management programs intended to meet individuals’ needs and goals based on an analysis of their liquidity needs, time frame, and income and tax bracket, as well as an evaluation of their risk tolerance and investment objectives. The client’s advisory representative will seek to review and update this information at least annually, or at the client’s request. EFA asset management programs use different investment vehicles to meet a client’s needs and goals. Depending on the selected program, the following types of investments are used: oil and gas U.S. government securities Certificates of deposit Options Cash equivalents Over-the-counter securities Interests in partnerships (real estate, interests, equipment leasing) Exchange-listed securities Corporate debt securities Municipal securities Mutual fund shares Interval fund shares Recommended investment strategies are primarily long-term strategies. However, based on the client’s needs and goals, short-term strategies and trading may be suitable, as well as margin transactions or option writing (including covered options, uncovered options, or spreading strategies). Clients have the ability to impose restrictions on investing in certain securities or types of securities, subject to the discretionary manager’s ability to comply with the request. Clients should ensure they understand the nature of their advisory agreement with EFA and any other third-party asset manager (“TPAM”) they engage to provide asset management services. ESI Illuminations Working with Fidelity Institutional Wealth Advisors (“FIWA”)1, EFA offers a customized investment management platform called ESI Illuminations (“Illuminations”) through FIWA’s advisory platform, Fidelity Managed Account Xchange, or “FMAX”. EFA offers the following asset management programs on the ESI Illuminations platform: Third-Party Strategist, Multi-Manager Accounts, Unified Managed Accounts, Separately Managed Accounts and Advisor-as-Portfolio Manager. Clients work with their advisory representative to determine an appropriate investment model to address their risk tolerance and investment objectives. 1 EFA and FIWA are not affiliated. ES0408A(0326) 4  Custody of client assets is maintained by National Financial Services, LLC ("NFS") with accounts registered in the client's name. A copy of this Brochure and of FIWA’s Form ADV Part 2A is given to Illuminations clients. Additionally, clients choosing a third-party manager on the Illuminations platform will receive a Form ADV Part 2A for the chosen manager. EFA and its advisory representatives do not have authority to implement investment transactions on a discretionary basis, except as noted below (see “Discretion”). Unless a third-party Strategist, other separate account managers, or the advisory representative have been given discretionary authority by the client, all transactions must be approved by the client. Clients have the ability to place reasonable restrictions on the investments within the Illuminations programs. This also includes the ability to place reasonable restrictions on the investments purchased through separate account manager(s). Contact your advisory representative for assistance with facilitating these restrictions. Third-Party Strategist Programs In the Third-Party Strategist program, FIWA makes available various asset management firms (“Strategists”) to offer actively managed portfolios, comprised of mutual funds or exchange-traded funds. These Strategists manage accounts on a discretionary basis. FIWA manages the programs pursuant to trade and rebalancing instructions provided by the Strategist. Each Strategist establishes their own minimum investment requirement(s) but reserves the right to permit initial investments below the stated minimum, at their discretion. Unified Managed Accounts (“UMA”) The Illuminations UMA program gives clients the ability to utilize the services and strategies of multiple managers within one brokerage account. EFA, through its IARs, builds and recommends UMA portfolios, which provide diversification among strategies and/or third-party managers, as well as Separate Account Managers. The IAR has the ability to recommend and manage up to 30% of the account in mutual funds, ETFs, and/or general securities. IARs who are approved for use of the Firm’s APM programs (described below,) if you authorized them to do so, have the ability to exercise the same discretion for which they are authorized in the APM programs in managing this portion of the account. Those who are not approved for use of APM programs must obtain client consent prior to executing trades. Ask your advisory representative if they are approved for discretion in this program. As the administrator, FIWA executes trading activity, as instructed by the various third-party managers, and maintains the allocation in accordance with the client’s Statement of Investment Selection (“SIS”). The platform technology provides the ability to unify multiple strategies and apply ongoing re-balancing within one account. Strategist Managed UMA programs give clients the ability to select a Strategist to build and manage diversified UMA portfolios, which can incorporate general securities, as well as investment models managed by other third-party Strategists. As the overlay manager, FIWA executes trading activity, as instructed by the Strategist, who builds and manages the account on a discretionary basis, in accordance with the client’s SIS. Separately Managed Accounts (“SMA”) are available under the UMA program. SMAs give clients the ability to invest in specific sectors and/or asset classes. The SMA manager is the discretionary manager and often uses general securities but also has the option of utilizing mutual funds or ETFs. Clients utilizing a SMA in their UMA portfolio have the ability to use additional overlay services, at an additional cost, such as tax management and impact overlay, which allows the investor to incorporate certain policies, such as Environmental and Social Governance (ESG), into their portfolio. Advisor as Portfolio Manager (“APM”) The Illuminations platform offers three programs in which IARs act as the portfolio manager: Flagship Select, ESI Directions, and ESI Compass. Advisors who want to offer APM as a service to their clients are subject to review and approval by the Firm prior to being granted access to these programs. Depending on their qualifications, IARs may be restricted in which program(s) they can offer. ES0408A(0326) 5  When selecting an APM program, the client and the IAR compile pertinent financial and other information to develop an investment portfolio designed to meet the client’s goals and objectives. The advisory representative uses a system provided through FMAX to build an appropriate asset allocation strategy, called an “investment model”. The investment model is based on the client’s needs, objectives, investment time horizon, risk tolerance and other factors relevant to the client, as applicable. The advisory representative builds and recommends an investment model in accordance with the parameters of the selected program. Advisory representatives may make different recommendations for similar investment strategies. The Firm retains the option to waive advisory fees on load mutual fund positions transferred into the program from other existing positions for certain periods of time, depending on the holding period of the transferred position. Flagship Select is an asset allocation program where the advisory representative will recommend appropriate mutual funds, exchange-traded funds (“ETFs”), and/or money market funds to build the portfolios, and the client may choose to purchase the recommended securities. ESI Directions is an asset allocation program similar in structure to Flagship Select, but differs in that, in addition to the asset classes available through Flagship Select, the advisory representative can recommend appropriate stocks, bonds, options, unit investment trusts, certificates of deposit, structured products, and cash equivalents. ESI Compass is an asset allocation program where the advisory representative will recommend appropriate assets such as stocks, bonds, options, mutual funds, exchange-traded funds (“ETFs"), unit investment trusts, certificates of deposit, structured products, and cash equivalents. ESI Compass differs from the Firm’s other advisor-as-portfolio programs in that clients assign full discretionary trading authority to their advisor. For discretionary accounts (described under “Discretion” below), model portfolios are constructed and rebalanced by EFA and its advisory representatives in accordance with the client’s Advisory Agreement. For non-discretionary accounts, the client must provide consent, prior to execution, for any transactions in their account. EFA reserves the right to waive minimum investment requirements for accounts in the APM programs. Discretion ESI Flagship Select and ESI Directions accounts established prior to March 30, 2016 did not grant the Firm nor its advisory representatives the authority to exercise investment discretion (unless the client subsequently granted this authority to their advisory representative in writing). The owner(s) of such accounts can grant discretion, under the parameters listed below, by providing written authorization in a form acceptable to the Firm at any time. ESI Flagship Select and ESI Directions accounts established on or after March 30, 2016 grant the Firm discretionary trading authority, which acts as an instruction from the client to the advisory representative and the Firm to trade securities in the account, under the parameters listed below. The discretionary investment and trading authority given to EFA, meaning the authority to rebalance the existing holdings in a client’s account through purchasing and selling securities without first obtaining the client’s express permission for each transaction, is permitted in the circumstances described below: • Executing transactions in the account for the purpose of rebalancing the portfolio back to within the client’s risk tolerance; • Executing transactions when concerned that a variance may result because an account’s risk score has changed; • Using discretion as to the time the Firm will make a trade in the account and the price paid for securities in accordance with the Firm’s obligation to seek best execution. Neither EFA nor the IAR are permitted to introduce new holdings to the portfolio without the client’s express permission. ES0408A(0326) 6  Clients who choose to invest in the ESI Compass program sign an advisory agreement which grants EFA and the IAR discretionary trading authority in the account. Under the Agreement, discretionary trading authority includes any and all of the following: • Selecting the investments for the account; • Removing investments from the account; • Replacing an investment in the account with another investment; • Where circumstances require, utilizing a transition fund, which is a short-term money market vehicle, to facilitate an investment replacement. The decision to use a transition fund is solely in the Firm’s discretion; • Determining the asset allocations and changing an asset allocation at any time; • Adding and removing asset allocation categories, which could result in the purchase or sale of individual securities; • Using discretion as to the time EFA will make a trade in their account and the price paid for investments in accordance with the Firm’s obligation of best execution; Investing funds and reinvesting all dividends and proceeds earned by the account; • Aggregating trades; • • Automatically buying and selling securities to rebalance the account to the target asset allocation when determined necessary by EFA; • Deducting cash or selling money market shares and other assets for Program Fees and deducting the proceeds from the account to pay EFA the advisory fee; • Determining the appropriate mutual fund share classes for the account, which may not be the lowest-priced share class in the particular mutual fund; • Exchanging mutual fund shares into another mutual fund share class; • Converting mutual fund shares from an existing share class to a share class available outside of the ESI Compass account if the advisory agreement is terminated; and Implementing any reasonable restrictions. • The discretionary investment and trading authority given to EFA can be exercised by the Firm and/or the client’s IAR at any time and without prior notice to the client of each specific transaction. In no instance do EFA or the IAR have authority to choose or change the client’s investment objective. All clients receive quarterly statements from National Financial Services, LLC (“NFS”), detailing activity in their account(s). Clients should carefully review their statements upon receipt. Questions regarding trading activity should be directed to the IAR. Services Illuminations provides clients with a range of investment advisory services. EFA, the advisory representative, and FIWA each provide certain services through the platform. These services include: • Assessment of the client’s investment needs and objectives; • Recommendation of an investment model; • Development and recommendation of an asset allocation model designed to meet the client’s objectives; • Evaluation of securities meeting the investment model and allocation criteria; • Periodic reviews to ensure accounts adhere to policy guidelines and asset allocation; • Recommendations for account rebalancing, if necessary; • Online and paper reporting of account performance; and • Custody services, trade execution, and confirmation and statement generation, through NFS. Though all of the above-referenced services may be offered, the client can select one or more of the services. EFA does not require the client to utilize all services offered above. However, all Illuminations assets are custodied at NFS. Advisory representatives recommend securities to clients on the basis of the client’s individual financial situation. Each client selects the account’s investment objective and has the opportunity to impose ES0408A(0326) 7  reasonable restrictions on the recommendations the advisory representative makes to the client. On a quarterly basis, they are reminded to confirm the accuracy of their information, and to determine if there are any changes to their investment objectives or restrictions. The advisory representative is available to answer any questions, and to implement any changes the client requests as a result of changes in their finances, personal circumstances, or the financial markets. What Clients Should Know About Advisory Accounts When making the determination of whether an Illuminations account is appropriate for their needs, clients should bear in mind that fee-based accounts (commonly referred to as “advisory” accounts), when compared with commission-based accounts (such as brokerage accounts), often result in lower transaction costs during periods when trading activity is heavier, such as the year an account is established. However, during periods when trading activity is lower, fee-based accounts may result in a higher annual cost to the client than a traditional brokerage account. Thus, depending on a number of factors, the total cost under a fee-based account, versus a commission-based account, can vary significantly. Factors which affect the cost of maintaining an account include account size, amount of turnover within the account, type and quantities of securities purchased or sold, commission rates, and the client’s tax situation. In a wrap fee program, such as Illuminations, internal expenses, trading costs, and other administrative expenses are included in the total fee paid by the client. As such, the advisory fee you negotiate with your IAR may be higher for an account in a wrap fee program than it might be for accounts in other advisory programs that offer similar services, but which do not offer a bundled approach to pricing. Clients should ensure they understand the services and product features being provided for the fee they agree to pay, and are free to accept or decline any program offered by EFA and/or the advisory representative. Clients should discuss their program with their advisory representative and read this Brochure carefully, as it explains the various offerings available on the Illuminations platform in detail. Asset-Based Pricing (“ABP”) Under ESI’s fully disclosed clearing agreement with NFS, ESI pays NFS a fee, based on the amount of assets on the platform, for custodial and brokerage services for advisory accounts. This fee decreases as more assets are placed on the platform. Therefore, ESI has a financial incentive to place more assets with NFS to reduce its costs and increase its profit. Because ESI pays this asset-based fee to NFS, NFS does not charge ESI fees commonly called “transaction fees”, which are fees typically charged each time there is a purchase or sale of most mutual funds, bonds, equities or options. Therefore, ESI will generally not charge transaction fees to accounts using ABP. However, ESI will still charge account service fees in conjunction with providing certain services. For a comprehensive list of transaction and service fees, please consult your brokerage agreement or ESI’s website (www.equity-services.com). NFS does not charge ESI the asset-based fee on no transaction fee2 funds, Fidelity retail funds, cash and cash equivalents, and non-standard assets (which include: foreign securities, alternative investments, and non-marketable securities). However, when these funds or programs are used in our programs, ESI’s program fee under ABP remains the same. Therefore, ESI has an incentive to use these funds or programs, because EFA will make more profit when they are used. Fees and Expenses: 12b-1 Fees Third-party managers, in their sole discretion, have the ability to utilize funds that pay additional compensation to ESI, such as 12b-1 (trail) fees. Additionally, certain funds available on the Illuminations platform pay additional compensation to the Firm, such as 12b-1 (trail) fees. Other funds available through the Illuminations platform do not pay the Firm 12b-1 fees. This creates a conflict of interest, because it creates a financial incentive, specifically the receipt of additional compensation, for ESI to recommend mutual funds with greater expenses. To eliminate this conflict, 12b-1 fees charged to accounts on the Illuminations platform are credited back to 2 No Transaction Fee (“NTF”) funds do not charge a separate transaction fee for trading activity. ES0408A(0326) 8  the customer by the custodian (i.e. NFS). Therefore, the Firm does not retain 12b-1 revenue from accounts on the Illuminations platform. Fees and Expenses: No-Transaction Fee (“NTF”) Funds and Transaction Fee (“TF”) Funds TPAMs have the ability to use certain funds which are transacted without a separate charge by custodians for each purchase or sale, commonly referred to as no-transaction fee (NTF) funds. Nevertheless, compared to other comparable funds, NTF funds typically have higher internal expenses, charged as a percentage of the assets in the fund and deducted from its value. Accordingly, these higher internal expenses reduce the returns of NTF funds. The Firm restricts the use of NTF funds in its Advisor-as-Portfolio Manager programs because, under the ABP structure, a “platform fee,” which is a small percentage of the assets in your account, is charged instead of separate charges by the custodian for each transaction. However, when acting as a discretionary manager, TPAMs have the ability to use NTF funds in their portfolios. Clients who are not comfortable with the fees and expenses associated with NTF funds (when compared to less expensive alternatives) should instruct their IAR to not recommend a manager that uses NTF funds. Investor Fees Under ABP, the total Investor Fee is comprised of: 1) the Platform Fee; 2) the Intermediary, or “Advisory”, Fee (negotiated between the client and the IAR); 3) the third-party Manager’s Fee (if using a Strategist manager). The Platform Fee to use asset-based pricing ranges between 0.08% and 0.26%, based on the assets under management and the selected program. EFA retains the Platform Fee. Accounts on the Illuminations platform are subject to a minimum annual platform fee which ranges between $15-$50, depending on the selected program. In the event an account balance falls below the initial minimum investment, the minimum annual platform fee can represent more than 2.00% (the Firm’s maximum allowable Advisory Fee) of the account’s billable assets, depending on the actual account balance at the time of billing. If the account balance falls to a level at which the annual platform fee represents more than the Firm’s maximum Advisory Fee, clients should consult with their advisory representative to consider their options. Annually, eligible IARs receive a portion of the Platform Fee that was paid to the Firm, based on the average monthly amount of total client assets they had on the Illuminations platform over the previous year. Specifically, IARs receive payments according to the following schedule: Average Monthly Balance on ESI Illuminations Platform $0 – $4,999,999 $5,000,000 - $25,000,000 $25,000,001 - $50,000,000 $50,000,001 - $75,000,000 $75,000,001 - 100,000,000 $100,000,001+ Credit 0% 0.01% 0.015% 0.02% 0.025% 0.03% For illustrative purposes, under this model, an advisor whose average monthly AUM is $10 million would receive $1,000 (or 0.01%) from EFA. This income is paid to the advisor out of the revenue that would otherwise be retained by the Firm and does not result in an increased fee to your account. However, this incentive creates a conflict of interest in that the advisor receives more compensation for placing assets on the Illuminations platform than they might otherwise receive by using another asset management provider. If you are not comfortable with this, you can select another advisory program offered by EFA that is not on the Illuminations platform. The Advisory Fee can range from 0%–2.00%. On a quarterly basis, a portion of the Advisory Fee (typically between 50%-85%) is paid to the IAR according to their compensation agreement with EFA. The remaining portion of the Advisory Fee is retained by EFA and/or the IAR’s supervisor, depending on the IAR’s ES0408A(0326) 9  compensation schedule. The Advisory Fee is negotiable and assessed on an individual basis according to methods disclosed to and agreed upon in advance with the client via the Statement of Investment Selection (“SIS”). When determining the Advisory Fee, the advisory representative considers, among other factors, the complexity of the work performed, time involved, degree of responsibility of the advisory representative, special needs and characteristics of the client, and the types of investments. To the extent that the client engages one or more third-party asset managers through the Strategist, UMA or SMA programs, those managers charge a separate management fee for services provided, which is included in the total Investor Fee. The Investor Fee is provided to the client in the SIS, which is provided to and signed by the client at the time the account is opened. The quarterly Investor Fee is billed at the beginning of the quarter in which services will be provided, based on the account’s average daily balance over the quarter that just ended. If a client chooses to close their Illuminations account before the end of a quarter, they will receive a reimbursement of fees paid, prorated for the number of days remaining in the quarter for which asset management services will not be provided. Certain accounts established prior to February 15, 2021 bill fees in arrears based on the average daily balance of the account at the end of the quarter for which services were provided. Clients who choose to close such an account before the end of a quarter will be charged a prorated advisory fee for the number of days in the quarter for which services were provided. New accounts opened during the first or second month of the quarter are billed initially for the days from inception to the end of the quarter, based on the initial value. New accounts opened during the last month of the quarter are initially billed for the days from inception to the end of the month, plus the next full quarter. The initial payment will become due in full on the date the account is accepted and will be based on the account asset value as of that date. Subsequent quarterly investor fees will be calculated based upon the account’s average daily balance over the quarter that just ended. Investor fees may be more or less than if a client paid separately for investment advice, brokerage and other services, or when compared to other available programs, subject to a number of factors, such as: the level of trading in a client’s account and the cost of services, if provided separately. The compensation received by the advisory representative through ESI Illuminations may be more or less than the compensation they would have received if the client had participated in other programs or paid separately for advice, brokerage, and other services. Accordingly, the IAR could have a financial incentive to recommend a wrap fee program over other programs or services. Fee adjustments for withdrawal of funds in one quarter will be made in the following quarter. Any fee owed pursuant to the terms of the SIS will be deducted, by the custodian, from the client’s account. All fees paid will be reported to the client on the quarterly statements. If NFS is the custodian of the client’s account, cash balances in taxable accounts will be held in Fidelity Government Money Market Fund (SPAXX) and cash balances in retirement accounts will be held in Fidelity Cash Reserves (FDRXX), unless a different election is made by the client. Additional Charges The Platform Fee does not cover certain charges associated with securities transactions in clients’ accounts, including: (1) dealer markups, markdowns or spreads charged on transactions in over- the-counter securities; (2) costs relating to trading in certain foreign securities; (3) the fees and expenses imposed by mutual funds and closed-end funds, unit investment trusts, exchange- traded funds or real estate investment trusts (such as operating expenses, management fees, redemption fees, 12b-1 fees and other fees and expenses as stated in the fund’s prospectus or offering document); (4) the charge to carry tax lot information on transferred mutual funds or other pooled funds, postage and handling charges, returned check charges, transfer taxes; stock exchange fees or other fees mandated by law, and (5) any brokerage commissions or other charges, including contingent deferred sales charges (“CDSC”), imposed upon the ES0408A(0326) 10  liquidation of “in-kind assets” that are transferred into the program. Liquidation of in-kind assets can result in tax consequences. Clients should consult their tax advisor accordingly. The Platform Fee does not cover certain fees that are charged to clients by the custodian. Clients generally also pay for specific account services, such as ACAT transfers, electronic fund and wire transfer charges, and for other optional services elected by clients. The Platform Fee does not cover certain non-brokerage- related fees such as individual retirement account (“IRA”) trustee or custodian fees, tax-qualified retirement plan account fees, and annual or termination fees for retirement accounts (such as IRAs). Clients often incur redemption fees when the advisory representative and the client determine to sell shares of a security before the expiration of the security’s minimum holding period. Depending on the length of the redemption period, the particular investment strategy, and/or market circumstances, the advisory representative and the client may be able to minimize any redemption fees when it is reasonable to allow a client to remain invested in a security until the minimum holding period expires. Please see the specific mutual fund’s prospectus for detailed information regarding such fees. Certain applicable fees can be avoided through the selection of mutual fund share classes which are not subject to such applicable fees, if clients are eligible for such reduced fee share classes. Item 5 – Account Requirements and Types of Clients The minimum account size to participate in programs offered on the Illuminations platform is generally $50,000. The minimum account size is subject to review, at EFA’s discretion, based upon the circumstances of each client. Certain programs, such as Strategist Managed UMAs, are designed for high-net worth clients and generally maintain higher minimum initial investments. Clients include individuals, corporations and other business entities, pension and profit-sharing plans, trusts, estates and charitable organizations. The Firm does not permit municipal entity clients on the Illuminations platform. The Firm reserves the right to prohibit anyone or any account type from investing in any of its advisory programs if it believes the recommended program is not an appropriate investment strategy for the client. Item 6 – Portfolio Manager Selection and Evaluation EFA has contracted with FIWA to provide performance reporting, fee calculation and billing, and to generate suggested rebalancing trades for the client’s account. FIWA generates a Time Weighted Rate of Return (“TWRR”), calculated net of all fees, for each account. This information is included on the client’s Quarterly Performance Report. EFA does not calculate investment performance on a uniform basis. EFA does not monitor or review performance data provided from FIWA for accuracy. Performance-Based Fees and Side-By-Side Management EFA does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Methods of Analysis, Investment Strategies and Risk of Loss EFA’s advisory representatives generally use technical and/or fundamental analysis when analyzing securities. Technical analysis generally involves studying trends and movements in a security’s price, trading volume, and other market-related factors in an attempt to discern patterns. Fundamental analysis generally involves assessing a company’s or security’s value based on factors such as sales, assets, markets, management, products and services, earnings, and financial structure. Sources of information for analysis include research material acquired from outside vendors, financial newspapers and magazines, annual reports, prospectuses, filings with the SEC and company press releases. Investment strategies used to implement investment advice to clients may include: long term purchases (securities held at least a year), short term purchases (securities sold within a year), trading (securities sold within 30 days), margin transactions, and option writing. The IAR will utilize certain asset allocation tools and investment research materials prepared by third-party ES0408A(0326) 11  investment advisers in constructing an appropriate asset allocation for a client and in monitoring the performance of the investment portfolio selected. Investing in securities involves several risks of which clients should be informed, and prepared to bear, prior to investing. The list below explains the various forms of risk associated with investing in securities: Common stocks may decline significantly in price over short or extended periods of time. Price changes may occur in the market as a whole, or they may occur in only a particular country, company, industry, or sector of the market. In addition, the types of stocks in which a particular fund invests, such as value stocks, growth stocks, large-capitalization stocks, mid-capitalization stocks, small-capitalization stocks and/or micro-capitalization stocks, may underperform the market as a whole. In addition, growth stocks can be more volatile than other types of stocks. Value stocks can continue to be undervalued by the market for long periods of time. Additionally, dividends paid on common stocks can vary significantly over the short-term and long-term. Dividends on common stocks are not fixed but are declared at the discretion of an issuer’s board of directors. There is no guarantee that the issuers of common stocks in which a portfolio invests will declare dividends in the future or that if declared they will remain at current levels or increase over time. Fixed income risks include credit risk, interest rate risk, and high yield risk. Liquidity risk is the risk that an investor may not be able to sell shares at an advantageous time or price. Interval funds, for example, offer investors the opportunity to generate income but only offer liquidation of shares on a limited basis (for example: redemptions may be limited to a maximum of 5% of the fund’s assets) and only during defined time periods. Additionally, there is no secondary market for interval fund shares. Credit risk is the risk that an issuer of a debt security will be unable to make interest and principal payments when due and the related risk that the value of a security may decline because of concerns about the issuer’s ability to make such payments. Credit risk may be heightened for portfolios that invest in “high yield” securities. Interest rate risk is the risk that the value of a portfolio will decline because of rising interest rates. Interest rate risk is generally lower for shorter-term investments and higher for longer-term investments. Duration is a common measure of interest rate risk. Duration measures a bond’s expected life on a present value basis, taking into account the bond’s yield, interest payments and final maturity. The longer the duration of a bond, the greater the bond’s price sensitivity to changes in interest rates. High yield, or below investment grade securities may be more susceptible to real or perceived adviser economic conditions than investment grade securities. In addition, the secondary trading market for below investment grade securities may be less liquid. High yield securities generally have more volatile prices and carry more risk to principal than investment grade securities. International Investing Risk is the risk associated with investing in securities or issuers in markets other than the United States. Foreign issuers may be subject to risks not typically associated with U.S. companies, such as: currency risk, risks of trading in foreign securities markets, and political and economic risks. Currency Risk is associated with the trading of securities in currencies other than the U.S. dollar. Because foreign securities generally trade in currencies other than the U.S. dollar, changes in currency exchange rates will affect an account’s value, the value of dividends and interest earned, and gains and losses realized on the sale of securities. A strong U.S. dollar relative to these other currencies will adversely affect the value of account. Foreign Securities Market Risk is the risk that securities of many non-U.S. companies, or U.S. companies with significant non-U.S. operations, may be less liquid, and their prices more volatile, than securities of comparable U.S. companies. Securities of companies traded in many countries outside the U.S., particularly emerging markets countries, may be subject to further risks due to the inexperience of local investment professionals and financial institutions, the possibility of permanent or temporary termination of trading, and greater spreads between bid and asked prices for securities. In addition, non-U.S. stock exchanges and investment professionals are subject to less governmental regulation, and commissions may be higher than ES0408A(0326) 12  in the U.S. Also, there may be delays in the settlement of non-U.S. stock exchange transactions. Political and Economic Risks are a factor when investing in international companies due to varying levels of stability in political, social, or economic factors in the country of the issuer of a security, the difficulty of predicting international trade patterns, the possibility of the imposition of exchange controls, expropriation, limits on removal of currency or other assets, and nationalization of assets. Income from foreign issuers may be subject to non-U.S. withholding taxes. Non-U.S. companies generally are not subject to uniform accounting, auditing, and financial reporting standards or to other regulatory requirements that apply to U.S. companies; therefore, less information may be available to investors about non-U.S. issuers. In addition, some countries restrict foreign investment in their securities markets, which may limit or preclude investment in certain countries or may increase the cost of investing. Acting in their discretionary authority, unaffiliated TPAMs retain the ability, outside EFA’s control, to implement changes to their managed portfolios. For example, a TPAM may determine to convert a portfolio’s holdings from a mixture of mutual funds to solely the use of ETFs to lower expenses. While such changes must be within the parameters of their investment mandate and must align with their fiduciary responsibility, they can, on occasion, result in a taxable event for shareholders. The above risks may be particularly significant in emerging markets countries. To the extent an account invests in depositary receipts, it will be subject to the same risks as when investing directly in foreign securities. Voting Client Securities As a matter of firm policy and practice, EFA does not have authority to and does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Upon request of the client, EFA may provide advice to clients regarding the clients’ voting of proxies. Item 7 – Client Information Provided to Portfolio Managers EFA does not separately communicate information about our clients to portfolio managers. Item 8 – Client Contact with Portfolio Managers There are no restrictions placed on a client’s ability to contact their advisory representative. Item 9 – Additional Information Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to an evaluation of EFA or the integrity of EFA’s management. Pursuant to the Securities Exchange Commission’s (“SEC”) Share Class Selection Disclosure initiative, Equity Services, Inc. (“ESI”) self-reported its use of mutual funds that paid fees to ESI pursuant to Rule 12b-1 of the Investment Company Act of 1940, in several of its advisory programs. Subsequently, the SEC alleged that, during the period of January 1, 2014 to July 7, 2017, ESI did not adequately disclose to its clients its receipt of, nor the conflict of interest created by, 12b-1 fee revenue and/or its selection of mutual fund share classes that resulted in 12b-1 revenue to ESI. Without admitting or denying the findings, ESI agreed to an order from the SEC which imposed the following terms: (1) cease and desist from committing or causing any further violations of Section 206(2) of the Advisors Act of 1940; (2) censure by the SEC; and (3) disgorgement of fees and prejudgment interest to affected clients totaling $587,017.22. The settlement was accepted by the SEC on September 30, 2019. ES0408A(0326) 13  Other Financial Industry Activities and Affiliations ESI is registered as a broker-dealer with the SEC, FINRA and all fifty states. ESI devotes a substantial portion of its time and derives a substantial portion of its revenue from its operations as a broker-dealer. As a broker-dealer, ESI offers the following investment and insurance products: mutual funds, alternative investment products, unit investment trusts, variable annuities and variable life products, indexed annuity products, direct participation programs, real estate investment trusts, and structured CDs. ESI also acts as the distributor of variable insurance products underwritten and issued by National Life. The Firm is under common control with NLG Capital, LLC, a registered investment adviser. The Firm is an affiliate of National Life. Most of the Firm’s advisory representatives are also life insurance agents of National Life. National Life provides space and certain other services to the Firm. LSW is an affiliated insurance company that offers fixed annuity products. Many of the Firm’s advisory representatives are appointed with LSW to sell fixed products. The Firm and its affiliates receive, in the aggregate, more revenue in connection with the sale of affiliated products than with unaffiliated products. This additional revenue often comes in the form of shared revenue based on assets under management, administrative, distribution, and/or other fees for services provided by affiliates of EFA in support of affiliated products. Thus, EFA has an incentive to offer affiliated products over unaffiliated products. As a result, the Firm faces a conflict of interest to the extent that it has an incentive to promote certain programs which use affiliated products over other programs which don’t use affiliated products (or use affiliated products to a lesser extent). The Firm receives payments from firms or persons that offer asset management or separate account products or services which are included in a preferred list of product providers (referred to as “Strategic Partners”). These payments take the form of conference, program, or event attendance; participation or exhibition fees; educational and training fees; or fees linked to program participation or specific marketing initiatives within an existing program. None of these additional payments are paid or directed to any advisory representative who sells these products. Nonetheless, when recommending an asset management program to their clients these marketing payments and educational opportunities present a conflict of interest to the extent that such payments incentivize advisory representatives to recommend Strategic Partners, as opposed to other advisers that do not make such payments. EFA has a selling agreement with Brinker Capital Management (“Brinker”) through which IARs solicit and recommend accounts held directly with and managed by Brinker. EFA also offers Brinker’s management services as a third-party Strategist on the Illuminations platform. Brinker accounts established through the Illuminations platform enjoy certain benefits, including consolidated account statements and reporting (beneficial to those using more than one Strategist), as well as added flexibility in changing and allocating assets amongst Strategists on the platform, but are subject to the Platform Fee that comes with utilizing the Illuminations platform. Accounts that are established directly with Brinker, through EFA’s promoter relationship, are not subject to a separate platform fee. Accordingly, an IAR can retain more of your fee if paying a program fee is not required. So, accounts held directly with Brinker generally experience a lower overall management fee than those that are established on the Illuminations platform (subject to the billing practices of each IAR). This also creates a conflict for EFA in that, regardless of your advisory fee, it receives more revenue from accounts established on the Illuminations platform than it does from those established directly with Brinker. If you are considering Brinker as a third-party manager, we encourage you to consult with your advisor regarding which program (i.e. Third-Party Strategist through Illuminations or directly with the manager) best suits your needs. EFA offers advisory services through SEI, an independent registered investment adviser (see EFA’s Form ADV 2A for a description of their services) on a co-advised basis. SEI’s Private Client Model accounts have a lower administrative fee, compared to other offerings, such as those on the Illuminations platform. This creates a conflict of interest for representatives in that they retain more of the advisory fee associated with SEI accounts than with those in other available programs. Conversely, EFA is conflicted in that it is incented to promote programs other than SEI which might otherwise generate more revenue to the Firm. ES0408A(0326) 14  ESI in its capacity as a broker-dealer often executes securities transactions for its advisory clients, including, but not limited to, transactions in securities distributed or underwritten by an affiliate. ESI has a fully disclosed clearing relationship with NFS (an affiliate of Fidelity) for the purpose of offering stock, bond and option trading. ESI marks up the actual service and IRA fees charged in NFS brokerage accounts associated with the Illuminations platform. ESI’s brokerage fee schedule can be viewed on its public website (www.equity- services.com). Block Trades TPAMs available on the FMAX platform, acting in their capacity as discretionary advisers, have the ability to place certain transactions in the same security purchased for multiple advisory accounts at the same time. This practice is commonly referred to as “block trading” and is often used to obtain optimal execution for clients. Once executed, the TPAM allocates the execution costs and the shares to participating accounts pursuant to their internal policies. Accounts owned by IARs associated with our Firm but managed by TPAMs will be allocated securities and costs from block trading in a manner that is consistent with the treatment provided other client accounts. Block trading is not permitted in the Firm’s Advisor-as-Portfolio Manager programs. NFS Business Development Credit ESI’s fully disclosed clearing agreement with NFS includes the payment of a Business Development Credit, which is solely reliant on ESI’s compliance with the terms and conditions of the clearing agreement and is not shared with IARs. The Business Development Credit is an annual credit paid to ESI in five installments over the course of a 12-month period, and is not related to the sale or offer of products or services, nor is it dependent upon assets under management. NFS Net Flows Credit NFS pays additional compensation to ESI based upon whether it has added more assets (exclusive of increases based on market performance) to the NFS platform, as compared to withdrawals from the platform, over a 12-month period. This creates an incentive for ESI to recommend Illuminations versus other advisory programs that are not on the NFS platform. Additionally, this creates an incentive to recommend that clients maintain their Illuminations account instead of using another advisory program not on the NFS platform. This credit is not shared with the advisory representative. FMAX Transition Credit ESI’s fully disclosed clearing agreement with NFS includes periodic payments for transitioning the Firm’s proprietary advisory program (ESI Illuminations) to Fidelity’s FMAX platform. Payments are reliant on ESI’s compliance with the terms and conditions of the clearing agreement and end on the second anniversary of the transition’s effective date. These payments are not shared with IARs, nor do they depend upon the total amount of assets under management or the number of accounts on the platform. Outside Business Activities Many IARs own and operate their own independent companies separate from EFA. Such IARs provide one or more services through these unaffiliated companies including, but not limited to, accounting/tax services, business consulting, and insurance brokerage services. If a client engages an IAR to provide any such services, these services are offered and performed solely in the IAR’s private and/or professional capacity, and not as a representative of the Firm. For additional discussion of how the Firm identifies and addresses potential conflicts of interest, please refer to “Code of Ethics, Participation or Interest in Client Transactions and Personal Trading”, below. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading EFA has adopted a Code of Ethics (“the Code”) that mandates high standards of business conduct and professionalism. EFA, through its advisers, will provide a copy of its Code of Ethics to any client or prospective client upon request. ES0408A(0326) 15  In general, the Code addresses certain groups of persons: Supervised Persons and Access Persons. The term “Supervised Persons” refers to any partner, officer, director, employee, or IAR of the Firm. “Access Persons” represent a subset of this population, and refers specifically to those individuals who have access to (1) nonpublic information regarding any clients’ trading activity, (2) nonpublic information regarding the portfolio holdings of any reportable fund, or (3) those who are involved in making securities recommendations to clients or who have access to such recommendations that are nonpublic. The Code prohibits EFA's Supervised Persons from purchasing initial public offerings (“IPOs”) or trading on material non-public information. Additionally, the Firm’s Access Persons are required to report their securities holdings upon initial hire, and again annually. Quarterly reporting of personal securities transactions is also required for Access Persons. EFA’s Supervised Persons must acknowledge the terms of the Code annually. The Code requires that advisory representatives render disinterested and impartial advice and make appropriate recommendations to clients based on an analysis of their needs. Conflicts of interest arise when a recommendation could result in additional compensation to the Firm and/or the advisory representative through the Firm’s business relationships or through the execution of commissionable transactions. Such conflicts are a consideration for the Firm’s Principal Compliance Analysts in their review of new accounts and transactions. The Firm addresses conflicts of interest and potential conflicts of interest by periodically reviewing them during EFA’s senior management meetings, and through disclosure to its clients, such as that contained in this Brochure. The Firm and the advisory representative can face conflicts of interest when providing services to retirement accounts. This occurs when an advisory representative recommends that a client transfer their retirement account from a different financial institution to our firm, because doing so will result in the Firm and the advisory representative receiving compensation that we would not otherwise receive. Conflicts of interest can also arise with existing customers, when an advisor recommends a new type of account that has a different compensation structure that will increase compensation. For example, this could occur if an advisory representative recommends: 1) Transferring assets in a brokerage account (which generates compensation when a transaction is made) to an advisory account (which charges an annual fee for ongoing management), 2) Taking money from a qualified plan and doing an IRA rollover, 3) Transferring assets from an IRA to a qualified plan, 4) Transferring an IRA account to a new IRA, 5) Transferring qualified plan assets to a new investment provider, or 6) Changing the type of account being used for an IRA (such as recommending that a commission- based account be changed to a fee-based account). All Supervised Persons whose activities could encompass the solicitation of government clients are required to pre-clear political contributions to local or state candidates, or candidates for federal office who currently hold a state or municipal office, to state and local political parties, or to political action committees. Advisory representatives occasionally buy, hold, or sell securities for their own accounts that are also recommended to, or bought or sold for, their clients at the same time or at different times as clients are trading in these securities. However, neither EFA nor any employee may receive preferential treatment over clients. It is EFA’s policy that the Firm will not effect any principal or agency cross transactions for client accounts. EFA will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser (that is, an advisory firm), acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions arise when an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Cross trades occur where an adviser causes a client account to sell a ES0408A(0326) 16  security to another client account, whether or not a commission is charged in the transaction. EFA and its affiliates also contribute amounts to various non-cash and cash incentives paid to EFA’s advisory representatives based on the achievement of specified sales goals for certain securities, as described in “Client Referrals and other Compensation”. Incentive programs are reviewed by EFA’s Compliance Department. The review of such programs seeks to ensure that all such incentives adhere to applicable rules. Conflicts of interest are managed through public disclosure to clients and prospective clients, which are available on the Firm’s public website. Unaffiliated TPAMs occasionally pay travel, meal and other expenses for IARs and others who visit the TPAM’s offices or other locations (including hotels and conference centers) to learn about its products and services. This creates a conflict of interest for IARs who may be incented to favor doing business with certain TPAMs over others on the basis of benefits received in conjunction with such visits. EFA’s advisory representatives have an incentive to choose certain programs based on the maximum fee that can be charged given the asset value of the account, as well as whether the advisory representative bears additional program charges. This creates a conflict of interest for the IAR, as they generally retain more of the revenue generated by fees in programs that do not include platform fees, transaction charges, or other administrative fees as part of the overall advisory fee. The Firm reviews potential conflicts of interest as part of its due diligence review of new and existing programs. The Firm provides disclosure to clients and potential clients of its fee structure and revenue agreements in this Brochure, as well as through the revenue sharing disclosure documents posted on its public website (www.equity-services.com). Review of Accounts IARs will attempt to schedule advisory account reviews no less than annually, though the client and IAR may determine to meet more frequently at their discretion. Factors triggering such a review will include, but are not limited to: changing circumstances in the client’s financial and personal life; the performance of the portfolio in both absolute terms, and relative to the client’s goals, objectives and risk tolerance; and at the request of the client. In most cases, the review will be conducted by the advisory representative who performed the initial investment advisory services. EFA utilizes software tools and/or reviews either exception reports or statements for accounts on which EFA is adviser to detect, and make recommendations to correct, variations from client mandates that are beyond variance tolerances established by the Firm. For discretionary accounts, the Firm and/or the IARs are authorized to rebalance the accounts to address variances that are beyond the Firm’s tolerances and the IARs are authorized to do the same if they are concerned that a variance will result because an account’s risk score has changed. In addition to review by advisory representatives, client accounts are reviewed by EFA Principal Compliance Analysts and/or other home office staff members. Quarterly performance reports are generated and made available to clients with accounts in Illuminations programs. Also, at least quarterly, NFS provides brokerage statements for all Illuminations accounts. Client Referrals and Other Compensation EFA pays individuals or entities, acting as bona fide promoters, a portion of the fee for service paid to EFA by the client if the client is referred to EFA by the promoter. All such promoter arrangements will conform to the requirements set forth in Rule 206(4)-1 of the Investment Advisers Act of 1940. In addition to the revenue sharing payments discussed above, ESI (acting in its capacity as broker/dealer) also receives additional compensation for the sales of securities issued and/or distributed by members of its Strategic Partners program. Certain other fund sponsors and/or TPAMs that do not participate in the Strategic Partners program, but whose funds may be used in APM accounts, make marketing payments to ESI to sponsor certain meetings or events. As such, the Firm has an incentive to promote use of these funds, over other available funds, in programs in which the IAR acts as the portfolio manager. Additional information regarding ESI’s Strategic Partners program is available at www.equity-services.com. ES0408A(0326) 17  Certain funds available through the Illuminations platform pay additional compensation to ESI, such as 12b- 1 (trail) fees. Other available funds do not pay ESI 12b-1 fees. This creates a conflict of interest, because ESI has a financial incentive to recommend mutual funds that generate 12b-1 revenue to the Firm. To eliminate this conflict, 12b-1 fees charged to accounts on the Illuminations platform are credited back to the customer by the custodian (i.e. NFS). Therefore, ESI does not receive 12b-1 revenue from accounts on the Illuminations platform. Certain product sponsors may make other payments to EFA intended to reimburse the firm's representatives for marketing expenses, such as client seminars, marketing materials, etc. Marketing reimbursements from sponsors are directed to EFA and subsequently paid by EFA to the representative. Certain product sponsors and investment advisers may incur expense and/or provide reimbursement for educational and training programs. Compensation From Securities and Other Investments ESI, acting in its capacity as a broker-dealer, sells various securities and investment products from a number of different product sponsors, including ESI’s affiliates (i.e. National Life and LSW). These products include mutual funds, variable annuities, alternative investment products, Real Estate Investment Trusts (REITs), structured CDs, variable universal life insurance, options, municipal bonds, 529 college savings plans, and fixed indexed annuities. Fixed indexed annuities are not securities products, and ESI sells these products through Registered Representatives, who may be dually registered as IARs, in their capacity as insurance agents. Through its Strategic Partner program, ESI has established additional relationships with various participating product providers which pay additional compensation to ESI based on sales of their products. When your IAR sells one of these products to you, ESI and your IAR can receive additional compensation from the transaction. This creates a conflict of interest in that there is an incentive to sell products for which the Firm and the registered representative receives more compensation. Among its advisory programs, EFA's Strategic Partners are: AssetMark, Brinker Capital, Fidelity Institutional Wealth Advisors, Freedom Advisors, Maple Capital Management, Summit Global Investors, and Touchstone Advisors. Certain other fund sponsors and/or TPAMs that do not participate in the Strategic Partners program, but whose funds may be used in advisory accounts, make marketing payments to ESI to sponsor certain meetings or events. These include American Funds, BlackRock Funds, LiveWell, PIMCO, Symmetry, and Vanguard. As such, the Firm has an incentive to promote use of these funds, over other available funds, in programs in which the IAR acts as the portfolio manager, specifically Flagship Select, ESI Directions, and ESI Compass The Firm reviews potential conflicts of interest as part of its due diligence review of new and existing programs and product offerings. To mitigate this conflict, ESI has policies and procedures to ensure that recommendations made are in our clients’ best interest, which includes pre-transaction and post- transaction reviews of recommendations. For a detailed description of fees, expenses, and revenue from the sale of these products, please see ESI’s Regulation Best Interest disclosure document at www.equity- services.com. Marketing and Training Support Training and education expenses and reimbursements are paid out of the adviser or affiliate's assets, not from the account assets, and are made to EFA in addition to annual service fees, and other fees and expenses disclosed in the adviser's Form ADV Part 2A, which are available on request from the investment adviser firm. The Firm and its affiliates also contribute amounts to various non-cash and cash incentives paid to EFA’s advisory representatives based on the achievement of specified sales goals for certain securities, including (1) sponsoring sales contests and/or promotions in which participants receive awards or incentives such as travel, merchandise, computer hardware and/or software; (2) paying for occasional meals, lodging and/or entertainment; (3) making cash payments in lieu of business expense reimbursements; (4) making and forgiving business-related loans; (5) cash bonuses and/or; (6) employee benefits, such as health insurance, Social Security contributions, etc. ES0408A(0326) 18  Current information regarding EFA’s Strategic Partners program may be found at www.equity-services.com or by calling (800) 344-7437. Financial Information The Firm is not aware of any financial condition that is reasonably likely to impair its ability meet its contractual commitments to clients, nor has EFA been the subject of a bankruptcy petition at any time during the past ten years. ES0408A(0326) 19