Fifth Third Securities, Inc.

COMPASS MANAGED ACCOUNT FIRM BROCHURE (Form ADV Part 2A) 38 Fountain Square Plaza Cincinnati, OH 45263 Phone: (888) 889-1025 www.53.com/invest SEC File No. 801-63623 Date of Brochure: July 08, 2026 This Compass Managed Account Firm Brochure (“Brochure”) provides information about the qualifications and business practices of Fifth Third Securities, Inc. If you have any questions about the contents of this Brochure, please contact us at 888-889-1025. 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 Fifth Third Securities, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. This Brochure provides information about Fifth Third Securities, Inc. and the Compass Managed Account Program. You should review the information and consider all factors, including but not limited to, investment risks, fees, and conflicts of interest prior to becoming a client of the Compass Managed Account Program. Fifth Third Securities is the trade name used by Fifth Third Securities, Inc., a member FINRA/SIPC and a registered investment advisor with the U.S. Securities & Exchange Commission. Registration does not imply a certain level of skill or training. Securities and investment advisory services offered through Fifth Third Securities: Are Not FDIC Insured Offer No Bank Guarantee May Lose Value Are Not Insured By Any Federal Government Agency Are Not A Deposit 07/08/2026 Compass Managed Account Firm Brochure Page 1 of 35  Item 2 – Material Changes This document represents the initial filing of this Brochure. In the future, this section will be used to describe the material changes to the Fifth Third Securities, Inc. Brochure as updates are made to this July 8, 2026 version. a) b) c) d) Item 3 – Table of Contents ITEM 1 – COVER PAGE .................................................................................................................................... 1 ITEM 2 – MATERIAL CHANGES ..................................................................................................................... 2 ITEM 3 – TABLE OF CONTENTS ................................................................................................................... 2 ITEM 4 – ADVISORY BUSINESS ...................................................................................................................... 4 A. ABOUT FIFTH THIRD SECURITIES ............................................................................................................................ 4 B. COMPASS INVESTMENT MANAGEMENT PROGRAM ................................................................................................... 4 1) Fiduciary Duties ........................................................................................................................................... 6 2) Limitation of Products and Types of Products (FTS vs Other Broker-Dealers or Registered Investment Advisors) .......................................................................................................................................................... 6 3) Limitation of Products and Types of Products (between FTS programs and services) ............................... 6 4) Fidelity Institutional Wealth Adviser, LLC (“FIWA”) .................................................................................... 6 5) Best Execution ............................................................................................................................................. 7 6) Non-Managed Assets and Worthless Securities ......................................................................................... 7 7) Unsupervised Assets ................................................................................................................................... 7 8) Holding a Client’s Order or Instruction ....................................................................................................... 8 9) Terminating Compass Asset Management Services ................................................................................... 8 10) Class Action and Other Legal Proceedings ................................................................................................ 9 C. AVAILABILITY OF CUSTOMIZED SERVICES FOR INDIVIDUAL CLIENTS ............................................................................... 9 D. WRAP FEE PROGRAMS ......................................................................................................................................... 9 E. ASSETS UNDER MANAGEMENT .............................................................................................................................. 10 ITEM 5 – FEES AND COMPENSATION ......................................................................................................... 10 A. INVESTMENT ADVISORY FEES AND COMPENSATION ................................................................................................... 10 1) Investment Advisory Fees ........................................................................................................................... 10 2) Fixed Income Related Costs ........................................................................................................................ 11 3) Householding & Investment Advisory Fees ................................................................................................. 11 Householding Advisory Fees Criteria ................................................................................................................. 11 How to Opt Out of Householding ...................................................................................................................... 12 Termination of Householding by FTS ................................................................................................................ 12 Ineligible Accounts for Householding Advisory Fees ......................................................................................... 12 B. PAYMENT OF FEES ............................................................................................................................................... 12 C. ADDITIONAL FEES AND EXPENSES ........................................................................................................................... 13 1) Fixed Income Markups & Markdowns ........................................................................................................ 13 2) Other Fees ................................................................................................................................................... 13 a) Mutual Fund and ETP Fees ................................................................................................................................ 13 b) Mutual Fund Share Classes ............................................................................................................................... 13 D. PREPAYMENT OF FEES .......................................................................................................................................... 13 E. ADDITIONAL COMPENSATION AND CONFLICTS OF INTEREST ........................................................................................ 13 1) Mutual Fund Rule 12b-1 Fees ..................................................................................................................... 13 2) Fixed Income Markups & Markdowns ........................................................................................................ 13 3) Conflict of Interest when Recommending Compass over other Investment Advisory Programs ................ 14 4) NFS Minimum Account Fees ....................................................................................................................... 14 5) Payment of Investment Advisory Fees to IARs ............................................................................................ 14 6) Compensation Conflicts of Interest ............................................................................................................. 14 7) Bonuses & Performance Based Compensation ........................................................................................... 15 8) Conflicts Related to Active Trading and No Charge Investments ............................................................... 15 9) Recruitment Compensation ........................................................................................................................ 15 Forgivable Draw Compensation ........................................................................................................................ 15 a) 07/08/2026 Compass Managed Account Firm Brochure Page 2 of 35  b) c) Upfront Forgivable Loan or Promissory Note.................................................................................................... 15 Sign-On Bonus ................................................................................................................................................... 16 10) Minimum Guaranteed Payout Percentage ............................................................................................... 16 11) Back-End Asset-Based Bonus .................................................................................................................... 16 12) Retention Compensation .......................................................................................................................... 17 13) Retirement Compensation ........................................................................................................................ 17 14) IAR Forfeiture of Compensation ................................................................................................................ 17 15) Conflicts Related to IAR Production Standards ......................................................................................... 18 16) Conflicts Related to Recommending Compass Account vs. Brokerage Account ....................................... 18 17) Conflicts Related to Mutual Fund Revenue Sharing .................................................................................. 18 18) Conflicts Related to Receipt of Educational, Marketing, & Other Financial Support ................................ 19 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................... 19 ITEM 7 – TYPES OF CLIENTS ......................................................................................................................... 19 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ...................... 20 A. METHODS OF ANALYSIS AND INVESTMENT STRATEGIES .............................................................................................. 20 B. MATERIAL, SIGNIFICANT, OR UNUSUAL RISKS RELATING TO INVESTMENT STRATEGIES .................................................... 20 1) Risk of Asset Value Loss .............................................................................................................................. 21 2) Interest Rate Risk ........................................................................................................................................ 21 3) Credit Risk ................................................................................................................................................... 21 4) Cybersecurity Risk ....................................................................................................................................... 22 5) Artificial Intelligence (“AI”) Risk .................................................................................................................. 22 6) Derivatives Risk ........................................................................................................................................... 22 C. RISKS ASSOCIATED WITH PARTICULAR TYPES OF SECURITIES ........................................................................................ 22 1) Investments in a Compass Account ............................................................................................................ 22 2) ETFs ........................................................................................................................................................... 23 3) ETNs ........................................................................................................................................................... 23 4) ESG, SRI, Faith Based, and Similar Investments and Investment Strategies ............................................... 23 5) Foreign Exposure ......................................................................................................................................... 24 6) Legislative and Regulatory Risk .................................................................................................................. 24 7) Money Market Fund ................................................................................................................................... 24 8) Municipal Bonds.......................................................................................................................................... 24 9) Stock Markets and Investments .................................................................................................................. 24 10) Tracking Error ........................................................................................................................................... 25 11) Additional Risks ......................................................................................................................................... 25 ITEM 9 – DISCIPLINARY INFORMATION ................................................................................................... 25 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .................................... 26 A. FIFTH THIRD SECURITIES – BROKER-DEALER & MUNICIPAL ADVISOR ........................................................................... 26 B. FIFTH THIRD BANK, NATIONAL ASSOCIATION (FTB) .................................................................................................. 26 C. FIFTH THIRD INSURANCE AGENCY, INC. (FTIA) ......................................................................................................... 27 D. FRANKIN STREET ADVISORS, INC. (FRANKLIN STREET ADVISORS) ................................................................................. 27 E. FIFTH THIRD WEALTH ADVISORS, LLC (FTWA) ........................................................................................................ 27 F. COMERICA SECURITIES, INC. (COMERICA SECURITIES) ................................................................................................ 27 a) b) c) 07/08/2026 Compass Managed Account Firm Brochure ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING ............................................................................................................................ 27 A. CODE OF ETHICS .................................................................................................................................................. 27 B. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS .............................................................................................. 28 C. PERSONAL TRADING ............................................................................................................................................. 28 D. CONFLICTS RELATED TO RECEIPT OF GIFTS AND BUSINESS ENTERTAINMENT .................................................................. 28 ITEM 12 – BROKERAGE PRACTICES ............................................................................................................. 29 A. BROKER-DEALER SELECTION FOR CLIENT TRANSACTIONS ........................................................................................... 29 1) Research and Other Soft Dollar Benefits ..................................................................................................... 29 NFS Credits & Discounts .................................................................................................................................... 29 Conflicts Related to Interest on Cash Holdings ................................................................................................. 30 Conflicts Related to Clearing Firm (NFS) ........................................................................................................... 30 Page 3 of 35  2) Trade Errors ................................................................................................................................................ 31 B. ORDER AGGREGATION.......................................................................................................................................... 31 ITEM 13 – REVIEW OF ACCOUNTS ............................................................................................................... 31 A. FREQUENCY AND NATURE OF REVIEW OF CLIENT ACCOUNTS OR FINANCIAL PLANS ........................................................ 31 B. FACTORS PROMPTING REVIEW OF CLIENT ACCOUNTS OTHER THAN A PERIODIC REVIEW ................................................. 31 C. CONTENT AND FREQUENCY OF ACCOUNT REPORTS TO CLIENTS ................................................................................... 32 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ........................................................... 32 D. FTS EDUCATION SUMMIT ..................................................................................................................................... 32 E. FTB PRESIDENT’S CIRCLE ...................................................................................................................................... 32 F. AREA AND REGIONAL MEETINGS ............................................................................................................................ 33 G. COMPENSATION TO NON-SUPERVISED PERSONS FOR CLIENT REFERRALS ...................................................................... 33 ITEM 15 – CUSTODY ......................................................................................................................................... 33 ITEM 16 – INVESTMENT DISCRETION ....................................................................................................... 33 ITEM 17 – VOTING CLIENT SECURITIES .................................................................................................... 34 ITEM 18 – FINANCIAL INFORMATION ........................................................................................................ 34 A. BALANCE SHEET .................................................................................................................................................. 34 B. FINANCIAL CONDITIONS LIKELY TO IMPAIR ABILITY TO MEET CONTRACTUAL COMMITMENTS TO CLIENTS ........................... 34 C. BANKRUPTCY FILINGS ........................................................................................................................................... 34 INVESTMENT ADVISORY ACCOUNT SERVICE FEE SCHEDULE ......................................................... 35 Item 4 – Advisory Business A. About Fifth Third Securities Fifth Third Securities, Inc. (“FTS”, “we”, “our”, or “us”) is a registered broker-dealer member of Financial Industry Regulatory Authority (“FINRA”) and SIPC (www.SIPC.org), and a registered investment adviser with the U.S. Securities and Exchange Commission (registration does not imply a certain level of skill or training). FTS was established in 1925, and FTS became a registered investment adviser in November 2004. FTS is a direct wholly-owned subsidiary of Fifth Third Bank, National Association (“FTB”). FTB is a full-service bank (see Item 10 - Other Financial Industry Activities and Affiliations for more information). Brokerage and investment advisory services and fees differ, and it is important for clients to understand the differences between these two types of services. IMPORTANT – Read before you open a Compass Account – The FTS’ Customer Relationship Summary (Form CRS) provides important information about both brokerage and investment advisory services, and clients should review Form CRS prior to making any decision to engage FTS for either brokerage or investment advisory services. The current version of FTS’ Form CRS can be requested from your Investment Advisor Representative (“IAR”) or found by going to the website 53.com/ftsdisclosure. B. Compass Investment Management Program FTS is the sponsor of the Compass Managed Account Program (“Compass”), a program that provides investment management services to clients (also referred to as “you” or “your”) utilizing securities including but not limited to equities (exchange-traded stocks, stocks traded over-the-counter, American Depositary Receipts (“ADRs”)), mutual funds (which could include fund of funds), exchange-traded funds (“ETFs”) and exchange-traded notes (“ETNs”) (also collectively referred to herein as exchange traded products or “ETPs”), fixed income securities (e.g., corporate bonds, municipal bonds, U.S. government bonds, brokerage certificates of deposit, etc.), unit investment trusts (“UITs”), publicly traded real estate investment trusts (“REITs”), or a combination of these investments. Compass can utilize other securities as determined by FTS to be eligible. With respect to mutual funds and ETPs, our IARs can only recommend and purchase products that appear on FTS’ approved product list. Additional services included in Compass are brokerage and custodial services for Compass accounts, performance reporting, and assistance with investment style selection and asset allocation strategies. Compass provides investment management services for various investment styles and objectives. Compass is not intended for investors who want to frequently switch investments from one style or strategy to another 07/08/2026 Compass Managed Account Firm Brochure Page 4 of 35  in reaction to short-term trends. You cannot independently buy or sell securities within your Compass account. If you want to execute your own trades using the assets that would fund your Compass account, you should not open a Compass account and evaluate at opening a brokerage account instead. In Compass, FTS, through our IARs, acts as the Portfolio Manager. An IAR of FTS will meet with a prospective client to discuss and complete an investor profile. During this discussion, the IAR gathers information regarding the client’s risk tolerance, investment objectives, and other financial information. With this data, the IAR assists the client in determining whether Compass is appropriate for the client and recommends an investment style and an asset allocation strategy or strategies for the Compass account to the client. Additionally, FTS’ IARs conduct an evaluation of the securities which they use in Compass accounts. A client choosing to open a Compass account will sign an Investment Management Agreement and an Advisory Supplemental Form or the Statement of Investment Selection with FTS, as well as an agreement to open an account with National Financial Services LLC (“NFS”). An advisory relationship exists between the client and FTS once the 1) Investment Management Agreement and 2) Statement of Investment Selection or Advisory Supplemental Form have been reviewed and accepted by FTS’ Principal Review Desk. If FTS’ Principal Review Desk does not accept the Investment Management Agreement, Advisory Supplemental Form, or the Statement of Investment Selection, there is no advisory relationship between FTS and the client. Compass is accessed through the Fidelity Managed Account Xchange (“FMAX”) platform, of which Fidelity Institutional Wealth Adviser LLC (“FIWA”) is the platform manager. Clients grant FTS discretionary authority to manage Compass account assets. Such discretionary authority allows FTS to make all investment decisions with respect to the client’s Compass account(s) when FTS deems it appropriate and without prior consultation with the client, to buy, sell, exchange, convert and otherwise trade in any equity, mutual fund, ETP, fixed income security, UIT, publicly traded REIT, or other security that FTS determines is eligible in Compass. In addition, this discretionary authority allows FTS to invest a Compass client’s accounts/assets in a lower risk tolerance up to one level than the client has selected. Please see below for a list of risk tolerances in the Compass Program, which are listed in order of the riskiest to the least risky. For example, if a client has selected the risk tolerance as Aggressive Growth, then when FTS deems it appropriate, FTS could move the client’s account/assets to reflect a Growth risk tolerance. However, in this example FTS would not be able to move the client’s account/assets to reflect a Moderate Growth or lower risk tolerance since any risk tolerance of Moderate Growth or lower is more than one level below the client’s stated risk tolerance. Furthermore, this limited discretionary authority does not allow FTS to invest in a higher risk tolerance than the client has selected. Risk Tolerances Aggressive Growth Growth Moderate Growth Moderate Conservative Growth Conservative Capital Preservation NFS is FTS’ clearing brokerage and custodial services provider, to custody client assets invested by the client in Compass. NFS is a registered broker/dealer and is not an affiliated entity of FTS. Most or all security transactions for Compass accounts are executed through NFS as the clearing broker/dealer. However, FTS sometimes trades with other broker/dealers to achieve best execution, obtain a wider variety of securities, or take advantage of favorable mark-ups or mark-downs available elsewhere. FTS can at any time change the 07/08/2026 Compass Managed Account Firm Brochure Page 5 of 35  clearing broker and custodian for the client’s account. The discretion granted by you to FTS includes the discretion to select broker-dealers for the execution of transactions to achieve best execution. FTS and our IARs have no authority or duty to manage any of the client’s assets that are: (1) not within Compass or another investment advisory program offered by FTS (i.e., Compass Managed Account Program and the Passageway Managed Account Program), or (2) designated as Unsupervised Assets (see Item 4.B.7. – Unsupervised Assets) within FTS investment advisory accounts. Participating in the Compass program entails risk. For more information about some of these risks please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. 1) Fiduciary Duties Under federal law, a registered investment adviser, such as FTS, is a fiduciary to its investment advisory clients (a/k/a Compass clients). FTS’ fiduciary duty includes, but is not limited to, a duty of care and a duty of loyalty. The duty of loyalty requires FTS, and our IARs, not to place our own interest ahead of our Compass clients’ interests. FTS is to make appropriate disclosures to our Compass clients, which is done through several documents, such as this Brochure. These disclosures help provide material information relating to the investment advisory relationship and FTS. The duty of care requires, among other things, the duty of FTS to provide advice that is in the best interest of our Compass clients, a duty to monitor the client’s managed investments in Compass accounts, and the ongoing suitability of those investments, over the course of the investment advisory relationship. As part of FTS’ duty of care, it our responsibility to understand the client’s objectives for the investments which we manage under Compass, the client’s risk tolerance (e.g., how much risk and losses you are willing to take for the potential of gains in your Compass account), and other financial profile information (e.g., annual income, estimated net worth, liquid assets, federal tax bracket, etc.). This information is needed to have a reasonable belief that the advice we provide is in the best interest of the Compass client. Critically Important Client Responsibility: You need to promptly notify the FTS’ IAR that you work with of changes to your risk tolerance, investment objectives, or financial circumstances that differ from the financial profile information that you previously provided to FTS, so that your Summit account can be reevaluated for potential changes. Additionally, when FTS provides investment advice to clients of Compass regarding their retirement plan account or individual retirement account, FTS is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way FTS makes money creates conflicts with your interests, so FTS operates under a rule that requires us to act in the client’s best interest and not put our interest ahead of our clients. 2) Limitation of Products and Types of Products (FTS vs Other Broker-Dealers or Registered Investment Advisors) FTS offers a wide range of investment products, advisory services, and other services to help meet your financial needs. However, we do not offer the same investment products, or product types that are available through other broker-dealers or registered investment advisors. This limitation is due to various reasons that include, but are not limited to, the product company has not passed our due diligence process, we do not have a contract with the product company, or the product, product type, or the product company is outside of our current business model, or the amount of risk associated with the company or product is too great. 3) Limitation of Products and Types of Products (between FTS programs and services) In Compass, FTS offers equities, mutual funds, ETPs, fixed income securities, UITs, publicly traded REITs, and other types of securities that FTS determines are eligible. However, through our broker-dealer and other investment advisory programs offered by FTS, a wider selection of approved products and product types are available. 4) Fidelity Institutional Wealth Adviser, LLC (“FIWA”) FIWA oversees the technology platform on which Compass functions for Compass Accounts. FTS has access to tools and related services as well as research and additional information about investment products 07/08/2026 Compass Managed Account Firm Brochure Page 6 of 35  offered through the FMAX platform, which assists FTS’ IARs in building personalized solutions for FTS’ clients. For more information about the FMAX platform and the research and risk ratings of investment products on FMAX, as well as other investment tools and related services, please see FIWA’s ADV Part 2A Brochure describing FMAX. 5) Best Execution As a registered investment advisor, FTS and our IARs have a fiduciary duty to seek to obtain the best trade execution in Compass accounts. Clients should understand that we may not always obtain the lowest possible transaction cost, and best execution does not mean the best price will be obtained. In addition, we may execute transactions at different prices or costs, and the execution quality received by one client may differ from the execution quality received by another client depending on the type of security, market conditions, order size, account restrictions, or other relevant factors. Several factors are utilized in analyzing overall best trade execution quality, including but not limited to, execution capability, timeliness of affecting trades, ability to execute orders of significant size, service, costs, system capabilities, system security, financial stability of firm executing the trade, and other relevant considerations. These factors combined are collectively referred to as “best execution.” FTS can choose to place a trade at a firm other than NFS if we believe we need to in order to meet their best execution obligation (often referred to as “trading away”). To aid in our best execution obligations, FTS periodically and systematically conducts a sample review of equity securities transactions executed through NFS to help confirm FTS continues to meet our best execution obligations with our clients. 6) Non-Managed Assets and Worthless Securities FTS generally does not permit securities to be held in a Compass account that are not part of the asset management of the Compass account unless it is an Unsupervised Asset (discussed below) or is a worthless security. However, if a security is deemed to be worthless (has no market value) and you do not have a brokerage account with FTS where this worthless security can be held, then the worthless security can be held in the Compass account with the client’s understanding that the worthless security or securities are not being managed by FTS, our IARs, or FIWA. 7) Unsupervised Assets In some cases, a client may want to transfer a security or investment into a Compass account but not want that security or investment immediately managed as part of the account's investment strategy. Clients can want this approach for a variety of reasons, including a desire to defer the tax consequences associated with liquidating the asset. A client or an IAR may request that a security or investment be designated as an Unsupervised Asset within a Compass account by completing an Unsupervised Assets Administration Form. Clients may obtain the form from their IAR or access it at https://www.53.com/ftsdisclosure, and are to submit the completed form to their IAR for processing. Upon receipt of a completed Unsupervised Assets Administration Form, the request will be evaluated by both FTS and FIWA. A security or investment will be treated as an Unsupervised Asset only if the request is approved by both FTS and FIWA. Requests may be denied for a variety of reasons, including, but not limited to, circumstances in which FTS or FIWA reasonably believes that the client does not intend to liquidate the security or investment and have the proceeds managed within the Compass account, or where the client intends to retain the proposed Unsupervised Asset for an extended period of time inconsistent with the purpose of having the proceeds of the Unsupervised Asset managed. If FTS or FIWA do not agree to the request to have a security or investment treated as an Unsupervised Asset, written notice will be provided by FTS to the client. Important Concepts: 1) If a client does not intend for a security or investment to ultimately be managed within a Compass account, the client should neither request nor agree to designate that security or investment as an Unsupervised Asset. Only securities or investments that you reasonably expect to be transferred into and managed as part of a Compass account should be considered for a request as an 07/08/2026 Compass Managed Account Firm Brochure Page 7 of 35  Unsupervised Asset. 2) The discretionary authority granted by a client to FTS and our IARs includes the authority on determining when to liquidate an Unsupervised Asset and include the proceeds of the Unsupervised Asset into the management of the Compass account without the prior consent of the client. If a client does not want FTS and our IARs to determine when an Unsupervised Asset should be liquidated and incorporated into the management of a Compass account, the client should have those security(ies) or investment(s) held in a brokerage account instead of having the security(ies) or investment(s) established as an Unsupervised Asset in a Compass account. Since Unsupervised Assets are not part of the active management of a Compass account, FTS does not charge an Investment Advisory Fee (see Item 5 – Fees and Compensation for further details) on an Unsupervised Asset until it is liquidated. As a result, there is financial incentive and a conflict of interest for FTS and our IARs to liquidate an Unsupervised Asset and have the proceeds incorporated into the management of the Compass account as FTS and our IAR(s) on the Compass account will make more in compensation. 8) Holding a Client’s Order or Instruction FTS, at its own discretion and without consultation with the Compass client, may choose not to immediately act upon a Compass client’s order to place a transaction or series of transactions (e.g., buy, sell, exchange, transfer, withdrawal) or act upon a client’s instruction if FTS believes that the client is the subject of financial abuse or is engaged or potentially engaged in a criminal activity (directly or indirectly). Examples of client instructions that FTS or FTS’ IARs may choose not to act upon immediately include, but are not limited to, executing securities transactions, money movement instructions including wire and check movements, termination of advisory services, change in beneficiary or beneficiaries, and trading authorization of a third- party. In the instances where FTS does not immediately act upon a Compass client’s order to place a transaction or act upon a client’s instruction, FTS will attempt to promptly conduct a review in order to determine the appropriate course of action, which can include, but is not limited to, contacting the client, State and/or federal authorities, or the Compass client’s Trusted Contact. FTS can choose not to act upon a client’s instructions or order for up to 15 calendar days, or for a longer period if permitted by applicable State laws/regulations, or as directed by State or federal authorities. 9) Terminating Compass Asset Management Services Either FTS or the client can terminate participation in Compass at any time by providing thirty (30) days prior written notice to the other party. The client will be charged a pro-rated investment advisory fee for the portion of any billing period during which the account is open (see Item 5 – Fees and Compensation for further details) unless the client terminates the Investment Management Agreement within (5) business days from the client signing the Investment Management Agreement. If a client terminates the Investment Management Agreement within five (5) business days from the client signing the Investment Management Agreement, then the client is not charged with an investment advisory fee. FTS reserves the right to distribute the assets of a client’s account in-kind (a delivery or transfer of securities held in the Compass account instead of in cash), liquidate any and all assets in the Compass account, send to the address of record any security in certificate form, and/or send to the address of record any available cash balance upon termination of the account by either party unless the Compass client provides alternative instructions. FTS will generally evaluate a Compass account for termination if there has been no IAR-initiated transactional activity (e.g., buys or reallocations) for a period greater than 18 months (withdrawals from the Compass account are excluded). If after the completion of the review FTS determines that it is appropriate to terminate the Compass account, FTS will terminate the Investment Management Agreement by providing thirty (30) days prior written notice to the client. Upon notification that an account owner has died, the Investment Management Agreement is immediately terminated, and the client’s account is no longer a Compass account. Any subsequent trades placed based upon instructions from the executor, heirs, or beneficiaries are subject to standard fees and commissions of a brokerage account. For the fees associated with brokerage accounts, see the Standard Commission and Fee Schedule at 53.com/ftsdisclosure for more information. 07/08/2026 Compass Managed Account Firm Brochure Page 8 of 35  10) Class Action and Other Legal Proceedings On occasion, securities currently or previously held in a client’s account are the subject of a class action lawsuit or other legal proceedings. FTS and our IARs have no obligation to monitor or determine if securities currently or previously held by the client are subject to pending or resolved legal actions. In addition, FTS and our IARs have no duty to assess a client’s eligibility for participation in any class action settlement or other legal proceeding, nor to file or submit claims on a client’s behalf. Furthermore, FTS and our IARs have no obligation or responsibility to initiate litigation or otherwise seek to recover damages on behalf of clients who believe they have been injured by the result of actions, misconduct, or negligence of issuers whose securities the client holds. C. Availability of Customized Services for Individual Clients Clients have the opportunity to place reasonable investment restrictions on the types of investments that will be managed on the client's behalf within Compass accounts. The client must provide these investment restriction requests to FTS in writing. If FTS, our IARs, or FIWA deems the restriction request unreasonable, FTS will notify the client of the rejection of the restriction request in writing. Clients can request two types of restrictions on their Compass account: 1) individual security restrictions, and 2) industry restrictions. Clients may not impose restrictions which apply to underlying securities held in any mutual fund, ETP or other pooled investment product. Individual security restrictions only apply to that specific security that is identified by a symbol or CUSIP, and the restriction will not apply to other securities that hold that individual security, such as mutual funds, ETPs or other pooled investment products. For example, if a client has an accepted restriction request for Microsoft stock (symbol ‘MSFT’), the client’s Compass account will not purchase shares of Microsoft stock. However, a mutual fund held in the client’s Compass account can be invested in Microsoft, and therefore, the client has an indirect investment still in Microsoft. Industry restrictions apply to general sectors of industry. Some examples of industry restrictions include, but are not limited to, Resorts & Casinos, Tobacco, Wineries & Distilleries, and Auto Manufacturers. Clients do not have the ability to determine what securities are included or excluded within an industry restriction, nor can clients determine the criteria that are used to include or exclude a security within an industry restriction. If a client requests an industry restriction in a Compass account, the client accepts the FTS’, FTS’ IARs, or FIWA’s determination of what securities are included and excluded from the industry restriction. D. Wrap Fee Programs FTS offers multiple investment advisory services through various programs. One of those programs, the Passageway Managed Account Wrap Fee Program (“Passageway”), is a wrap fee program (e.g., generally does not have securities transaction-related costs in addition to the investment advisory fee). For clarity, Compass is not a wrap fee program. The product types and selection of portfolio managers available in Passageway accounts are different than the product types and selection of portfolio managers available in non-wrap fee accounts (Compass and Summit). For example, Passageway has the availability of other firm third-party asset managers that will act as the Portfolio Manager Additionally, in the Passageway Advisor Directed program, FTS IARs are limited to managing mutual funds and ETPs; whereas Compass has the availability for FTS IARs to invest in equities, mutual funds, ETPs, fixed income products, UITs, publicly traded REITs, and other security types that FTS determines are eligible for Compass. Finally, in the Summit Managed Account Program (“Summit”), FTS IARs have the availability to invest in equities, mutual funds, ETPs, fixed income products, and publicly traded REITs. However, in each of these advisory programs, the investment advisory account management is driven by the client’s best interest as determined through evaluation by FTS’ IAR using profile information provided by the client, the client’s preferences including reasonable investment restrictions, and investment strategies aligned with the client’s risk tolerance. Clients should discuss with the IAR whether a wrap fee program would be appropriate based on factors, including but not limited to the types of investments the client wants to be invested in, the fee and expenses associated with such assets, and the anticipated trading activity in the 07/08/2026 Compass Managed Account Firm Brochure Page 9 of 35  account. FTS receives a portion of the wrap fee for Passageway. Clients should review all of the investment advisory services offered by FTS prior to making any decision to engage in Compass. The current versions of the Passageway Managed Account Wrap Fee Program Brochure and Firm Brochures for Compass and Summit (both non-wrap fee programs) can be requested from your IAR or found by going to the website 53.com/ftsdisclosure. E. Assets Under Management As of April 30, 2026, FTS had approximately $14,228,900,000 in assets under management that are managed on a discretionary basis. Item 5 – Fees and Compensation A. Investment Advisory Fees and Compensation Compass clients are assessed investment advisory fees on Compass accounts for the ongoing advice, portfolio management, and services provided by FTS and our IARs. Compass clients are also assessed separate account service fees described below and on Investment Advisory Account Fee Schedule that appears at the end of this Brochure. 1) Investment Advisory Fees Investment advisory fees are negotiable between FTS and the Compass client. As a result, Compass clients that have similar account balances and/or allocations can pay different investment advisory fees. Clients should refer to their Advisory Supplemental Form or the Statement of Investment Selection to see the negotiated advisory fee schedule for your specific Compass account(s). FTS includes cash and cash equivalents positions in the daily weighted average market value of the assets under management when FTS assesses investment advisory fees. As a result, clients should limit the amount of cash or cash equivalents held in their Compass account. For the initial calendar quarter in which a Compass account is opened, the initial advisory fee will be based upon the number of days the account is open in Compass, and the daily weighted average market value of the assets under management. Likewise, upon the termination of a Compass account, an advisory fee will be based upon the beginning date of the calendar quarter through the date of termination of the Compass account and the daily weighted average market value of the assets under management. Clients should be aware that the investment management services provided under Compass can be more or less expensive than if the services were purchased separately, provided through another investment advisory program offered by FTS, or purchased at another financial firm. A client could receive services similar to those offered in Compass from other financial services providers. When determining the cost of purchasing services separately or the cost of other investment advisory programs, clients should evaluate the costs of brokerage commissions charged, the volume of trading activity in the account, transaction fees, wire fees, trade-away fees, foreign security transfer fees, retirement account termination fees, custody charges, fees charged for investment management services, fees for performance reporting, and the internal costs of the assets purchased (e.g., mutual fund and ETP internal expenses). Investment advisory fees (referred to as the “Program Fee” in the Investment Management Agreement) for Compass generally follow the below fee schedule, but investment advisory fees can be lower. Clients should refer to their Advisory Supplemental Form or Statement of Investment Selection to see the negotiated advisory fee schedule for their specific Compass account(s). Standard Investment Advisory Fee Schedule Value of Account Advisory Fee First $250,000 Next $250,000 Next $250,000 Next $250,000 Next $1,000,000 1.50% 1.35% 1.25% 1.10% 1.00% 07/08/2026 Compass Managed Account Firm Brochure Page 10 of 35  Balance Above $2,000,000 0.80% The maximum investment advisory fee for investment advisory programs offered through FTS is 1.50%. 2) Fixed Income Related Costs When FTS buys or sells fixed income securities (e.g., municipal bonds, corporate bonds, government bonds or securities) in your Compass account, FTS will act as the agent in the transaction. When acting as agent, FTS sources fixed income securities from other dealers (also known as a counterparty) in the market. The price FTS receives from the dealer will include a markup or markdown which is included in the price you receive in your Compass account. The markup or markdown charged varies based on several factors including, but not limited to, the type of security being bought or sold, maturity date, and size of the transaction. FTS does not act as a principal (i.e., trade from our own inventory) for fixed income securities transactions in a Compass account. 3) Householding & Investment Advisory Fees Clients who have a tiered investment advisory fee schedule (see the Standard Investment Advisory Fee Schedule above) can potentially reduce their investment advisory fees when FTS investment advisory accounts are linked together to aggregate total assets under management (hereafter referred to as “Householding”). FTS investment advisory accounts in the Summit, Compass, and Passageway programs are eligible for Householding. By Householding FTS investment advisory accounts, the client can potentially reach a subsequent tier on the investment advisory fee schedule that has a lower advisory fee. For example, if a client has two Compass accounts at FTS using the standard tiered investment advisory fee schedule (see above) and each of these accounts has a balance of $150,000, the combined assets of these accounts would be $300,000. Instead of each investment advisory account receiving an investment advisory fee charge of 1.5%, the Householding feature will result in the first $250,000 receiving a 1.5% charge, and the next $50,000 receiving a charge of 1.35%. Householding FTS investment advisory accounts will not always result in a lower investment advisory fee if the combined assets of the Householded accounts do not reach a subsequent tier of the client’s investment advisory fee schedule. For example, if the client has two investment advisory accounts Householded each with a balance of $100,000 and the first tier of the investment advisory fee schedule goes from $0 - $250,000, then the client would not receive a reduction in investment advisory fees because the total Householded amount is $200,000, which is below the minimum amount for the next tier ($250,000.01). If the client has a flat percentage investment advisory fee (e.g., 1.40%) rather than a tiered investment advisory fee schedule, the client will not receive any reduction of investment advisory fees regardless of the value of combined assets when FTS investment advisory accounts are Householded. a) Householding Advisory Fees Criteria For investment advisory accounts to qualify for Householding, the FTS investment advisory accounts must meet certain conditions. The current conditions for Householding are: • Each of the Householded investment advisory accounts through FTS being linked together must have the same IAR or IARs associated. For example, if a client with an FTS investment advisory account that has an IAR (John Doe) and their spouse has a different IAR (Jane Smith) who handles their FTS investment advisory account, the FTS investment advisory accounts will not be Householded because the clients have different IARs. • Each Householded FTS investment advisory account must be open (i.e., the investment advisory relationship has not been terminated) at the end of the calendar quarter. For example, if a client has two FTS investment advisory accounts that meet all the conditions to receive Householding but terminates one of the FTS investment advisory accounts during the calendar quarter including up to the last day of the calendar quarter, then the FTS investment advisory accounts would not be Householded. • Each Householded FTS investment advisory account must have the same mailing address listed with FTS. If a client or clients have two or more separate mailing addresses, even if the client or clients 07/08/2026 Compass Managed Account Firm Brochure Page 11 of 35  are related or part of the same family (e.g., spouse, children, trust, etc.), the FTS investment advisory accounts are not eligible for Householding. A client should never provide FTS with a mailing address that is not their own address. If a client provides FTS with another individual’s address, that individual at the other address would receive the client’s statements and other communications from FTS, FIWA, and NFS rather than the client; and • If the client has additional non-advisory accounts (e.g., brokerage accounts, annuities, 529 Plans, etc.), these accounts and assets are not eligible for Householding. Provided that the above-listed criteria are met and continue to be met, Householding will be applied to the applicable investment advisory accounts through FTS. Investment advisory accounts through FTS that are linked for Householding are not required to be opened on the same day to be eligible for Householding. Clients are not required to take any steps to apply for Householding. Important Consideration for Householding – When investment advisory accounts through FTS are Householded together, clients receive only one Quarterly Performance Report that reflects all of the Householded investment advisory accounts through FTS. Clients desiring to receive separate Quarterly Performance Reports for their FTS’ investment advisory accounts will need to opt-out of Householding, which can result in paying more in investment advisory fees. b) How to Opt Out of Householding Clients can opt-out of Householding by providing a written request to: Fifth Third Securities, Inc. Attn: FTS Compliance Department 38 Fountain Square Plaza MD: 1090XB Cincinnati, OH 45263 However, if a client chooses to opt-out of Householding, the client or clients will not receive the potential benefit of lower investment advisory fees. c) Termination of Householding by FTS FTS can at any time choose to cease offering Householding or change the conditions of when or how investment advisory accounts through FTS are Householded. If FTS ceases offering Householding or changes the conditions for Householding, FTS will mail clients a written notification approximately 30 calendar days in advance of the change(s) taking effect. d) Ineligible Accounts for Householding Advisory Fees Householding is not available for any of the following account types: • Investment advisory accounts offered through affiliated entities, such as FTB (e.g., PCS and IM&T programs), Fifth Third Wealth Advisors, LLC (“FTWA”), and Franklin Street Advisors, Inc. • FTS brokerage accounts, including those custodied at NFS. • Variable annuities, variable universal life contracts, 529 Plans, or other mutual fund accounts held directly at the investment company. • Insurance products, contracts, annuities, or other accounts held through Fifth Third Insurance Agency, Inc. B. Payment of Fees Investment advisory fees (referred to as the “Program Fee” in the Investment Management Agreement) are calculated at the beginning of each calendar quarter based upon the daily weighted average market value of the assets under management for the previous quarter. Investment advisory fees are automatically deducted from the client’s Compass account and are charged quarterly in arrears in the month following the end of the calendar quarter, generally based on the Standard Investment Advisory Fee Schedule (See Item 5.A. – Investment Advisory Fees and Compensation). 07/08/2026 Compass Managed Account Firm Brochure Page 12 of 35  C. Additional Fees and Expenses 1) Fixed Income Markups & Markdowns As outlined in Item 5.A. – Investment Advisory Fees and Compensation, Compass accounts are subject to transaction-related charges (markups and markdowns) when FTS buys or sells fixed income securities in your Compass account. 2) Other Fees FTS and the custodian for Compass accounts, NFS, assess additional costs and fees. These costs are not included in the investment advisory fees described above. These costs include but are not limited to the following: wire fee, overnight mailing fee, foreign security movement fee, and stop payment on check fee. Refer to the Investment Advisory Account Service Fee Schedule at the end of this Brochure. a) Mutual Fund and ETP Fees FTS does not charge a sales commission or load for investments in mutual funds or ETPs. However, a client that already owns certain securities that have contingent deferred sales charge (e.g., class B and C share mutual funds) will be subject to that fund company’s charges. Liquidation of these investments reduces the value the client will have to invest in Compass. Clients should carefully review the securities that will be used to fund a Compass account prior to choosing to establish a Compass account. In addition, each mutual fund and ETP have their own expenses, which are described in each mutual fund and ETP’s prospectus. These fees and expenses generally include a management fee, trading costs associated with the underlying securities of the fund, and other expenses, which can also include Rule 12b-1 fees or similar fees for mutual funds. The fees and expenses of a mutual fund and ETP reduce the performance of the account and are embedded in the net return of the mutual fund or ETP. Therefore, the client should review both the total direct and indirect fees and expenses of mutual funds and ETPs. See 5.E. – Additional Compensation and Conflicts of Interest for additional information on how FTS handles Rule 12b-1 fees in your Compass account. b) Mutual Fund Share Classes Some mutual funds have different share classes available, and these share classes have different expenses, including the internal expenses. FTS and our IARs will utilize the cheapest share class of mutual funds that is available to FTS and our IARs at the time of the purchase. However, some mutual funds have different share classes that are not available to FTS and our IARs, and these share classes of mutual funds can be cheaper than those purchased in the client’s Compass account. Compass accounts can be invested in alternative mutual funds which can have higher operating expenses compared to traditional mutual funds, and some alternative mutual funds are considerably more expensive. D. Prepayment of Fees FTS charges investment advisory fees to Compass clients quarterly in arrears; such fees are not paid in advance. E. Additional Compensation and Conflicts of Interest 1) Mutual Fund Rule 12b-1 Fees Some investment companies (issuers of mutual funds) pay Rule 12b-1 fees to FTS for mutual funds held in a Compass account. When this occurs, FTS will accept these 12b-1 fees and then have these 12b-1 fees reimbursed directly to the client’s Compass account the following month the 12b-1 is credited to FTS. For clarity, if part or all of the 12b-1 fee is retained by NFS, the Investment company (mutual fund company), or any other party other than FTS, these 12b-1 fees are not credited back to the client’s Compass account since FTS did not receive these 12b-1 fees. 2) Fixed Income Markups & Markdowns When fixed income products are purchased or sold in a Compass account, there will be a markup or markdown cost made by the dealers involved in those transactions, which can include NFS or an affiliated entity of NFS. These charges are not separately itemized but are embedded in the price of the security. 07/08/2026 Compass Managed Account Firm Brochure Page 13 of 35  FTS does not reduce the investment advisory fees that Compass accounts are charged to offset these markups and markdowns. The amounts of the markup/markdown vary based on factors including the type of security, maturity, credit quality, and trading volume, and are not separately disclosed on trade confirmations by FTS or NFS. 3) Conflict of Interest when Recommending Compass over other Investment Advisory Programs FTS pays fees to FIWA and/or Portfolio Managers (who are not IARs of FTS) in the Passageway Program. These fees range from 0.02% to 0.50% of the daily weighted average market value of the assets under management in Passageway accounts (excluding Advisor Directed Program accounts), of which 0.02% represents the fee that FIWA charges to FTS. When FTS pays these fees to FIWA and/or Portfolio Managers, it reduces the amount of compensation an IAR receives. As a result, an IAR has a conflict of interest in recommending Compass to a client versus other investment advisory programs under Passageway. Critically Important Conflict of Interest: FTS pays fees to FIWA and/or Portfolio Managers in other investment advisory programs in Passageway, which directly reduces the amount an IAR would receive in compensation. As a result, IARs have a financial incentive to recommend to a client a Summit account that will result in greater compensation to the IAR. 4) NFS Minimum Account Fees FIWA charges FTS a minimum fee for each investment advisory account. This minimum fee varies by program (e.g., Compass, Passageway One, Passageway Focus). As a result, FTS has a conflict of interest to recommend investment advisory accounts only when it expects the investment advisory account, including Compass accounts, will be funded at a level sufficient to cover this minimum fee. To help mitigate this conflict of interest, FTS absorbs the cost of the minimum fee rather than passing it on to our IARs. By not allocating this cost to IARs, FTS reduces the financial incentive for IARs to recommend advisory accounts based on the need to cover the minimum fee. 5) Payment of Investment Advisory Fees to IARs A client’s IAR is generally paid a portion of the investment advisory fees (generally a percentage) charged for a Compass account. The specific amount the IAR will receive will depend on several factors, including but not limited to, the role the IAR has with FTS (e.g., Investment Executive), how long the IAR has been associated with FTS, and the total amount of revenue attributable to the IAR in a calendar year. Specifically, IARs who meet certain revenue thresholds or tiers (e.g., dollar amounts such as $300,000) are eligible for a higher payout percentage of the investment advisory fees, commissions, sales loads, trail commissions, and/or fees from the sales and services associated with the IAR. For example, an IAR whose revenue totaled $200,000 earns less as a percentage than an IAR whose revenue has totaled $400,000. These tiers create a conflict of interest as they provide a financial incentive for the IAR to increase the revenue associated with them. To help address this conflict of interest, FTS has created an IAR compensation schedule with multiple tiers in which an IAR can earn a higher payout. By creating multiple tiers with smaller percentage increases, this decreases the financial incentive for an FTS IAR to act inappropriately to obtain a higher payout percentage. IARs in an “Investment Executive” role for five or more years or in a partnership with another Investment Executive who has been in the role for five or more years, FTS pays a portion of the investment advisory fees from Compass accounts to the Investment Executive as the investment advisory fees are earned. For all other IARs who can offer investment advisory services through FTS, FTS will advance the first year’s estimated investment advisory fees of a new Compass account to an IAR based upon the market value of the assets in the first month the assets are invested within the Compass account. Then, in the approximate thirteenth month since the opening of the Compass account, FTS will pay the IAR in advance for that month’s anticipated investment advisory fees based upon the market value of the Compass account. 6) Compensation Conflicts of Interest As a result of the receipt of compensation, when an IAR makes a recommendation to a client and that client opens a Compass account, the IAR has a conflict of interest because it is anticipated that the IAR will receive 07/08/2026 Compass Managed Account Firm Brochure Page 14 of 35  a portion of the investment advisory fees associated with that Compass account. The investment advisory fees earned by an IAR at FTS can be greater than what the IAR would receive at another registered investment advisor firm. The Compass investment advisory fees can be more than what an IAR would receive if a client conducted their transactions in a brokerage account and paid separately for the investment advice, or if the IAR recommended another investment advisory program offered through another FTS. As a result, your IAR has a financial incentive to offer a Compass account over a brokerage account or other investment advisory accounts through another FTS investment advisory program. 7) Bonuses & Performance Based Compensation Some IARs are eligible for bonuses or other performance-based compensation. This performance-based compensation is based on a number of factors and generally includes the overall revenue associated with the IAR, which will often include FTS, Fifth Third Insurance Agency, Inc. (“FTIA”), and/or FTB activities and revenue. Certain individuals who are in a role with FTB and oversee an FTB branch office have the potential to receive performance-based compensation based in whole or in part on the branch’s performance metrics. The branch receives credit for FTS-related revenue, including investment advisory fees resulting from your Compass account. 8) Conflicts Related to Active Trading and No Charge Investments FTS does not charge Compass clients a ticket charge or commission for securities transactions placed in a Compass account. However, FTS is charged by NFS for securities transactions of certain investments in Compass accounts. Therefore, FTS has an incentive to lower or limit the number of securities transactions in investments that NFS charges FTS. To help mitigate this conflict of interest, FTS’ IARs do not directly share in the costs of securities transactions when they are placed in a Compass account, nor does FTS notify IARs of which investments NFS charges FTS. 9) Recruitment Compensation FTS provides recruitment compensation to IARs who join FTS. There are generally three types of recruitment compensation methods that FTS can use when an IAR joins our firm. a) Forgivable Draw Compensation The forgivable draw recruitment compensation will generally be broken into two segments. In the first segment, the IAR will generally receive a bi-weekly forgivable draw for the first 6 calendar months and a higher payout percentage for the first 6 calendar months. In the second segment, the IAR will generally receive either a forgivable or non-forgivable draw and a higher payout percentage for the subsequent 12 calendar months. The determining factor whether the draw is forgivable or non-forgivable in the second segment is dependent upon either the amount of revenue associated with the IAR for that time period or the amount of the total market value of the assets brought to FTS during that time period. Generally, recruitment compensation is limited to a time period of no greater than 24 calendar months to allow the IAR to transition to FTS. However, depending on the individual circumstances of the IAR, FTS could deviate from these stated timeframes by going longer or shorter for either segment, or having an overall longer or shorter time period for the recruitment compensation. FTS has established written policies and procedures, controls, and processes that are reasonably designed to provide a supervisory structure that oversees the Compass Program and FTS’ IARs. b) Upfront Forgivable Loan or Promissory Note An upfront forgivable loan (or promissory note) is an upfront payment paid by us to the IAR when the IAR joins our firm. The IAR doesn’t have to repay the loaned amount if the Financial Professional stays with us for the duration of the loan or note and the IAR meets specified revenue targets within defined time periods (e.g., monthly, quarterly). The specific length of time period of the upfront forgivable loan can vary from IAR to IAR. However, generally speaking, a larger upfront forgivable loan will result in a longer time period the upfront 07/08/2026 Compass Managed Account Firm Brochure Page 15 of 35  forgivable loan will last. An example of how the upfront forgivable loan generally works, if an IAR received a three-year upfront forgivable loan and the IAR meets the revenue threshold in March, then 1/36 or approximately 2.78% of the upfront forgivable loan has been forgiven by us and the IAR no longer needs to pay back this amount. An upfront forgivable loan creates a conflict of interest for the IAR because the IAR has a financial incentive to meet monthly revenue thresholds. However, with respect to Compass accounts, these IARs are subject to a fiduciary duty to act in the best interests of Compass clients when making recommendations. FTS helps address this conflict by having a separate group of securities registered principals that review the sales activities of Compass, and these registered principals do not directly receive compensation from the recommendations made by IARs. c) Sign-On Bonus A sign-on bonus is an upfront payment provided to an IAR upon joining FTS. This bonus is structured to incentivize a long-term relationship and is contingent upon the IAR remaining with FTS for a specified period and meeting certain production or performance expectations during that time. The specific terms, including the amount of the sign-on bonus and the applicable time horizon, can vary based on individual circumstances and business considerations. A sign-on bonus creates a conflict of interest by providing a financial incentive tied to an IAR’s continued employment and performance. However, with respect to Compass accounts, these IARs are subject to a fiduciary duty to act in the best interests of Compass clients when making recommendations. FTS helps address this conflict by having a separate group of securities registered principals that review the sales activities of Compass, and these registered principals do not directly receive compensation from the recommendations made by IARs. 10) Minimum Guaranteed Payout Percentage FTS generally pays our IARs a percentage of the commissions, sales loads, trail commissions, and/or fees received from the sales and services associated with the IAR (otherwise known as the “payout percentage”). An IAR in the role of an Investment Executive or a Private Bank Investment Executive, when that IAR is initially registered with FTS, is provided with a minimum guaranteed payout percentage. This guarantees that the Investment Executive or Private Bank Investment Executive’s payout percentage will be at a certain percentage for a specified time period. The minimum guaranteed payout percentage is used even if the actual compensation associated with the Investment Executive or Private Bank Investment Executive’s activities is lower than normally required. It is anticipated that the minimum guaranteed payout percentage will be higher than the standard payout percentage when an Investment Executive or Private Bank Investment Executive initially starts with FTS. When we provide an Investment Executive or Private Bank Investment Executive with a minimum guaranteed payout percentage, we do so to help reduce the conflict of interest that can occur when an Investment Executive or Private Bank Investment Executive initially starts with FTS and is making recommendations to clients. The length of time that the minimum guaranteed payout percentage is in place can vary from IAR to IAR, but when we offer the minimum guaranteed payout percentage, it will generally last 24 months from the date the IAR starts with FTS or enters a new role with FTS. However, depending on the individual circumstances of the IAR, we could deviate from these stated timeframes by going longer or shorter for either segment, or having an overall longer or shorter time period for the recruitment compensation. 11) Back-End Asset-Based Bonus A back-end asset-based bonus is a payment that is earned by an IAR after joining FTS, contingent upon achieving specified asset levels within a defined period of time. This bonus is typically calculated based on the amount of client assets transitioned to or maintained with FTS and is payable only if the applicable asset thresholds and retention requirements are met. The structure, measurement period, and payout timing of a back-end asset-based bonus are anticipated to vary depending on individual circumstances and business considerations. The Back-End Asset-Based Bonus creates a conflict of interest due to the financial incentive 07/08/2026 Compass Managed Account Firm Brochure Page 16 of 35  provided to the IAR to encourage the transfer or retention of assets. However, in Compass these IARs have a fiduciary duty to Compass clients for their Compass accounts when making recommendations. We help mitigate this conflict through supervisory and compliance controls, including independent review of applicable transactions by supervisory personnel who do not receive compensation based on the assets gathered or the recommendations made by IARs. Furthermore, we help mitigate this conflict of interest by having the Back-End Asset-Based Bonus not tied to any specific product type or service (e.g., brokerage assets versus investment advisory/Compass). 12) Retention Compensation Upon occasion, we provide retention compensation to IARs to remain with FTS. A retention bonus is a payment that is provided to an IAR in connection with their continued registration and performing securities- related activities with FTS over a specified period of time. This bonus is typically contingent upon the IAR remaining with FTS through the applicable retention period, and in some cases, meeting certain performance, production, or asset retention expectations during that time. The structure, amount, and duration of a retention bonus are anticipated to vary based on individual circumstances and business considerations. A retention bonus creates a conflict of interest because it provides a financial incentive for the IAR to remain with us and maintain client relationships with FTS. However, in Compass these IARs have a fiduciary duty to Compass clients for their Compass accounts when making recommendations. We help mitigate this conflict through established supervisory and compliance processes, including independent review of Compass accounts by supervisory personnel who do not receive compensation based on retention- related incentives or recommendations. 13) Retirement Compensation IARs in the role of an Investment Executive have the potential to participate in the receipt of compensation after their retirement from FTS and the securities industry. An Investment Executive’s eligibility in FTS retirement compensation program is dependent upon a number of factors, including but not limited to, the Investment Executive’s tenure with FTS, an Investment Executive’s age, completion of pre-retirement criteria, and/or compliance with various regulatory requirements to receive compensation after their termination from FTS and the securities industry. An Investment Executive’s retirement compensation (payout percentage) is based on the total revenue earned in the rolling 12-months prior to retiring. The payout percentage based upon last rolling 12-months creates a conflict of interest for the retiring Investment Executive since it creates a financial incentive for the retiring Investment Executive to increase their revenue so they can receive more compensation in their retirement. We help mitigate this conflict by having a separate group of securities registered principals review the activities of IARs. These registered principals do not directly receive compensation from the recommendations made by IARs and will at times use tools and systems designed to aid their supervisory reviews based upon various risk-based information. Additionally, we have provisions in the IARs’ compensation plans that provide for the recovery, withholding, repayment, or “clawback” of compensation due to violation of policy, procedures, or state and federal laws or regulations. 14) IAR Forfeiture of Compensation Certain activities or failure to perform certain activities will or can result in the forfeiture of an IAR’s receipt of their portion of the investment advisory fee. This includes the following: • FTS requires its IARs to conduct an annual review meeting with Compass clients. If an annual review is not conducted in a calendar year starting the year after the Compass account is opened, the IAR will have their portion of investment advisory fees for that Compass account forfeited until a review has been conducted with the applicable Compass client. Once the annual review has been conducted, the IAR will begin to receive the portion of the investment advisory fees for that Compass account again. • As part of the due diligence of the securities made available in Compass for IARs to manage, 07/08/2026 Compass Managed Account Firm Brochure Page 17 of 35  securities will be removed from the available list when the security does not meet certain criteria. Once a security is removed from the available list, the IAR will have a specified time period to have the security or securities removed from the Compass account as a managed asset. If an IAR does not sell, exchange, or work with the client to transfer the removed security or securities from an Compass account within the prescribed time period, then the IAR’s portion of the investment advisory fees are forfeited until the security is no longer held in the Compass account as a managed asset. Once the removed security is no longer in the Compass account, the IAR will receive the portion of the investment advisory fees for that Compass account again. Notwithstanding this process, an IAR can seek an exception from FTS to this process for non- qualified accounts (e.g., Individual, Transfer on Death, Joint accounts) where the IAR would not be required to remove the applicable security for up to one year. If an IAR’s exception request is approved by FTS, the client is sent a written notification informing them that the security or securities no longer meets the due diligence requirements but are being retained in the Compass account. In this scenario, the IAR continues to receive the investment advisory fees associated with the Compass account. • When a Compass account’s value is below $25,000, the IAR does not receive any compensation associated with your Compass account. Additionally, when a Compass account’s value is between $25,000 and $49,999.99, your IAR does not receive compensation from the Compass account unless the client has total household assets of $50,000 or more with FTS. In addition to the aforementioned reasons, FTS can, as a part of disciplinary action, cause the forfeiture or withholding of an IAR’s portion of investment advisory fees associated with a specific Compass account or accounts when an IAR acts materially different from FTS’ expectations or policies and procedures. 15) Conflicts Related to IAR Production Standards As part of an IAR’s continued registration and/or employment with FTS, FTS has established minimum production standards based upon the tenure of the IAR with FTS. Failure by an IAR to meet FTS’ minimum production standards results in an evaluation of the overall performance and activity of the IAR, which can lead to the deregistration and/or termination of employment. To help mitigate this conflict of interest, when an IAR does not meet the production standards, FTS does not automatically deregister or terminate the employment of the IAR, but first FTS conducts and evaluation to help determine the rationale for the IAR’s current production. The evaluation can include but is not limited to the workplace behaviors (e.g., showing up to the office, hours being worked), frequency of contact with clients, client follow-ups, personal events (e.g., death of a family member), and other activities related to the IAR’s work activities. 16) Conflicts Related to Recommending Compass Account vs. Brokerage Account Due to the on-going relationship and the advisory fees associated with a Compass account, FTS and FTS’ IARs have a financial conflict of interest when recommending a Compass Account over a Brokerage Account as FTS and FTS IARs have the possibility to earn more compensation than they potentially would in a Brokerage Account. FTS helps address this conflict by having a separate group of securities registered principals that review the solicited Compass Accounts by IARs, and these registered principals do not directly receive compensation from the recommendations made by FTS’ IARs. Furthermore, FTS helps address this conflict by requiring FTS’ IARs to complete paperwork with clients when recommending the opening of a new Compass Account. This paperwork outlines the types of services the client is seeking (e.g., on-going reviews of accounts and assets). Clients who are not seeking to have FTS or FTS’ IARs to provide on-going management of their account, should not open a Compass Account. 17) Conflicts Related to Mutual Fund Revenue Sharing FTS has fee arrangements with some mutual fund companies (which also includes companies that offer ETPs) that issue mutual funds that are available for purchase in the Compass Program. These payments are 07/08/2026 Compass Managed Account Firm Brochure Page 18 of 35  often referred to as “revenue sharing.” However, each of these revenue sharing arrangements with mutual fund companies (which also includes companies that offer ETPs) are solely related to FTS’ Institutional Brokerage business and do not apply to the mutual funds held in Compass accounts. Under these revenue sharing arrangements, the mutual fund company can pay FTS a fee based that is based off: 1. The amount of client sales; 2. Assets invested in the mutual company’s mutual funds; and/or 3. A fixed fee. The actual amounts that FTS receives can vary from one mutual fund company to another and can have a minimum dollar amount prior to FTS being eligible to receive a revenue sharing payment. In all cases, such revenue sharing payments will be paid to FTS from the mutual fund company’s own resources and not directly from client funds or assets. Such arrangements will have no impact on the fees being charged to clients by FTS and our IARs. FTS provides marketing support to the mutual fund company and allows the mutual fund company to access FTS’ IARs so that the mutual fund company can promote their mutual funds. This revenue share arrangement creates a conflict of interest by incentivizing FTS to have clients invest in mutual funds that provide revenue share instead of mutual funds that do not make revenue sharing payments to FTS. FTS does not directly share revenue sharing payments with our IARs. Since FTS’ IARs receive no direct portion of the revenue share that is received by FTS, FTS does not believe its IARs have a conflict of interest when selecting one mutual fund over another mutual fund as a result of these revenue sharing arrangements. Lastly, in order to mitigate this conflict of interest, currently FTS does not receive revenue share payments on any of the assets in mutual funds that are held in Compass accounts. Please visit the bottom of https://www.53.com/investments/mutual-funds.html for the list of the mutual fund companies that FTS has a revenue sharing arrangement with. 18) Conflicts Related to Receipt of Educational, Marketing, & Other Financial Support FTS and our IARs have a conflict of interest as a result of when Portfolio Managers, service providers, and products companies, such as mutual fund companies, unit investment trust sponsors, annuity companies, life insurance companies, ETP companies, or their affiliates, reimburse or cover the costs for FTS and/or our IARs for the following activities: marketing, business and client development, educational enhancement, and/or due diligence reviews incurred by FTS and/or an IAR related to the promotion or sale of the Portfolio Manager services or product company’s products (e.g., mutual fund, ETP). This compensation is also used to subsidize the cost of education programs, such as conferences we offer to our IARs, which include travel and travel-related expenses, meals, overnight lodging, speakers, and entertainment. Portfolio Managers, products companies, and service providers that participate in these events gain the opportunity to interact with our IARs and their supervisors, and it is anticipated that these interactions will result in additional sales of those products or services associated with those Portfolio Managers and product companies. Accordingly, a conflict of interest exists where we offer opportunities to Portfolio Managers, products companies, and service providers that are willing to cover expenses and/or pay us to cover expenses as compared to Portfolio Managers, products companies, and service providers that do not. IARs do not directly receive a portion of this compensation. However, IARs’ attendance and participation in these events can be expected to lead IARs to recommend and direct investments to the Portfolio Managers, products companies, and service providers that provide this compensation as compared to Portfolio Managers, products companies, and service providers that do not. Item 6 – Performance-Based Fees and Side-By-Side Management FTS does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. FTS and our IARs do not engage in side-by-side management. Item 7 – Types of Clients Compass is available to individuals, high net worth individuals, trusts, estates, foundations, charitable 07/08/2026 Compass Managed Account Firm Brochure Page 19 of 35  institutions, corporations, private pension plans, and other business entities or organizations with sufficient liquid assets to participate in Compass. Compass is not intended for government entities (federal, state, or municipal) or for public pension plans. Compass clients are required to promptly notify FTS in writing of any material changes to their information previously provided to FTS. Some examples include: Investment objective Investment time horizon • • Risk tolerance • Net worth • Annual income • • Address Failure by the client to provide FTS with current, accurate information could adversely affect FTS and our IARs’ ability to effectively manage the client’s assets within Compass. A Compass account requires a certain minimum dollar value of either cash or marketable securities that are acceptable to FTS before FTS approves an account. The Compass account minimum is $100,000. In addition, FTS and our IARs, or FIWA, at their discretion, can terminate a Compass account if the Compass account falls below the $100,000 account-opening minimum. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis and Investment Strategies FTS’ IARs utilize various sources of information, which can include but is not limited to, financial newspapers and magazines, inspection of corporate activities, research materials prepared by others, corporate rating services, annual reports, prospectuses, materials provided by FIWA, filings with the U.S. Securities and Exchange Commission, and other publicly available tools and information sources. An IAR of FTS will meet with a prospective client to interview and complete an investor profile. During this interview the IAR gathers information regarding the client’s risk tolerance, investment objectives, and financial information. With this data, the IAR assists the client in determining whether Compass is appropriate for them and recommends an investment style and an asset allocation model for the Compass account to the client. Each Compass account is invested in securities aligned with the client’s selected risk tolerance. However, FTS can invest a client’s account in a portfolio corresponding to a risk tolerance that is one level more conservative than the client’s selected risk tolerance. The client’s Statement of Investment Selection or Advisory Supplemental Form reflects the selected asset allocation model. As noted above, FTS and our IARs are responsible for the selection and monitoring of investments in the Compass account after the client has signed the Statement of Investment Selection or Advisory Supplemental Form and funded the Compass account. Information about the risks associated with those investments can be found in the corresponding investment’s prospectus, if applicable. In addition to this Brochure, a copy of the IAR’s Investment Advisor Supplemental Brochure (ADV Part 2B) is provided to the client at or prior to the establishment of the Compass account. Clients can request another copy of this Brochure or their IAR’s ADV Part 2B at any time by contacting their IAR or contacting FTS at the phone number listed on the cover page of this Brochure. Diversification and asset allocation can help reduce the risk of a portfolio, but they do not remove all risk or chance of loss of the original amount invested or the gains earned in a Compass account. Periodically, the Compass account is rebalanced to help provide consistency with the client’s ongoing investment objectives and the asset allocation. B. Material, Significant, or Unusual Risks Relating to Investment Strategies Different types of investments and investment strategies involve varying degrees of risk, and it should not be assumed that the future performance of any specific investment or investment strategy will be profitable. This includes the investments and investment strategies recommended or undertaken by FTS or our IARs. Investments are not obligations of, and are not guaranteed by, FTS, FTB or any of our other affiliates, and are 07/08/2026 Compass Managed Account Firm Brochure Page 20 of 35  not Federal Deposit Insurance Corporation (“FDIC”) or government insured. Investments are subject to risks, including possible loss of the principal amount invested. Losses can occur with any investment or strategy, including conservative investments or strategies. The more risk the client is willing to bear, the greater the potential for loss of the principal amount invested by the client or loss of unrealized gains on assets held in the Compass account. Additional information about the risks concerning a particular mutual fund or ETP can be found in the respective mutual fund or ETP’s prospectus. Clients of Compass should be prepared to bear the risk of loss associated with having a Compass account. Portfolio goals and objectives are not guaranteed and may not be achieved. Past performance does not guarantee future results. Compass accounts and the securities in the client’s Compass account can be subject to the following risks: 1) Risk of Asset Value Loss The investment strategy or strategies provided by FTS and our IARs, including the conservative models, involve the risk of loss including the loss of the original investment amount or loss of unrealized gains on assets. Clients should have a willingness to incur such losses in connection with investments in the Compass, especially if the client invests for a shorter period of time. By investing in Compass, clients can lose money by investing in stocks, bonds, mutual funds, ETPs, or other securities or by the investment strategy or strategies used by the IAR. Many factors affect each investment’s or Compass account’s performance. Nearly all investments and Compass accounts are subject to volatility in non-U.S. markets, through either direct investment exposure or indirect effects in U.S. markets from events occurring abroad, including adverse political, social, economic, or market occurrences. Additionally, investments or Compass accounts that pursue debt exposure are subject to risks, including, but not limited to, prepayment risk, default risk, and interest rate risk. In addition, funds, ETPs, and investment strategies that pursue strategies that concentrate in specific sectors or industries or are otherwise subject to particular segments of the market (e.g., healthcare, technology, real estate, financial, or international) can be significantly impacted by events affecting those sectors, industries, or markets. Mutual funds or ETPs that invest in other funds bear all the risks inherent in the underlying investments in which those funds invest. Strategies that pursue leveraged risk, including investment in derivatives — such as options, swaps (interest rate, total return, and credit default) and futures contracts — and forward-settling securities, magnify market exposure and losses. Mutual funds, ETPs, and Compass accounts are also subject to operational risks, which can include risk of loss or losses arising from failures in internal processes or systems, or people, such as routine processing errors or major systems failures, or from external events, such as exchange outages. 2) Interest Rate Risk The bond market is volatile, and bonds and other fixed income securities carry interest rate risk. Interest rate risk is generally expected to occur when the interest rate changes, but interest rate risk can also occur when market expectations of interest rate changes (or lack thereof) do not occur. Interest rates and bond prices generally have an inverse relationship; meaning that when interest rates increase the values of bonds decrease (and the opposite will generally occur when interest rates decrease). Generally, the longer the duration of a bond, the greater the impact on the valuation of the bond. For example, an interest rate increase will generally have a greater impact (an expected decrease in value) on a 20-year bond versus 5- year bond by the same issuer with same or similar terms. Fixed income securities also carry inflation risk and credit and default risks for both issuers and counterparties. Most bond funds do not have a maturity date, so holding the bond funds until maturity to avoid losses caused by price volatility is not feasible. Additionally, certain types of bonds can be less liquid than more actively traded investments, meaning bonds can be difficult to sell quickly or without accepting a lower price, which can result in a significant loss to you when sold. 3) Credit Risk Issuers of debt and other counterparties may be unable to make interest or principal payments when due or otherwise honor their debt obligations. Credit rating changes of the issuer can adversely affect the value of the debt instrument or security. Additionally, changes in the financial condition of an issuer or 07/08/2026 Compass Managed Account Firm Brochure Page 21 of 35  counterparty(ies) and/or changes in specific economic or political conditions that affect a particular type of security or issuer, can increase the risk of default by an issuer or counterparty, which can affect a security or instrument’s credit quality or value. Lower-quality debt securities involve greater risk of default or price changes due to changes in the credit quality of the issuer. 4) Cybersecurity Risk Companies, markets, investment companies, including ETPs and mutual fund companies, and services providers, like FTS, FIWA, and NFS, use significant amounts of technologies in their day-to-day functions. As a result, these entities and those individuals who use these services or have investments in companies are subject to numerous cybersecurity risks. Cybersecurity risks include, but are not limited to, compromised company, employee or client data, disruption of services, corruption or loss of data, inability to perform services (e.g., trading, valuation, issuance of reports, communications), and financial losses. 5) Artificial Intelligence (“AI”) Risk Technology advances in AI and machine learning technologies (e.g., ChatGPT, Gemini, Grok, etc.) create risks for users of these technologies, including FTS, our IARs, FIWA, and NFS. AI is a fast-evolving technology that has several risks associated with it, including but not limited to the following: • Confidential information Exposure: Accidental or intentional use of confidential or sensitive information into AI or machine learning technologies can result in the dataset being accessible by other AI technologies and/or users which could lead to unauthorized disclosure or misuse of client or firm data. • Bias and Factual Inaccuracies Risks: AI can be prone to algorithmic biases and present false or misleading information as factually accurate, known as “hallucinations”. AI hallucinations can be created by flawed data training, AI’s misinterpreting data or patterns, source of data is inaccurate, or the AI model will struggle to accurately understand real-world knowledge or factual information. • Model Risk: Models (e.g., portfolio management models, predicative models, risk assessment models, etc.) created, managed, or assisted by AI, can behave unpredictably if trained on biased, incomplete, or outdated data. This can lead to model issues such as poor investment decisions or misaligned risk assessments. • Regulatory Uncertainty: The legal and regulatory landscape governing AI is still developing and may go through rapid changes. Future changes in laws or regulations will impact on how AI can be used by financial institutions, potentially requiring changes to business practices or technology infrastructure, which could negatively impact FTS, our IARs, FIWA, and NFS current and future use of AI. 6) Derivatives Risk A derivative can be defined as a financial instrument or contract which derives its value from one or more underlying financial instruments such as an asset, index, or interest rate. A mutual fund or ETP’s use of derivatives can reduce the returns of your Compass account and/or increase the volatility Compass clients are exposed to. Derivatives are also subject to counterparty risk, which is the risk that the other party in the transaction will not fulfill its contractual obligation. Derivatives may give rise to a form of leverage, and when leverage is used in a mutual fund, ETP, or other security or investment strategy there is greater risk and often higher costs. C. Risks Associated with Particular Types of Securities 1) Investments in a Compass Account A Compass account will be invested in various securities, which will depend on the individual strategy(ies) determined by the IAR and the client. These securities will employ various investment strategies, and each investment strategy has a number of risks associated with it. Therefore, Compass accounts and the securities held within the Compass account are subject to these risks and clients can lose a substantial amount of their original investment in Compass. For more information regarding the risks associated with a mutual fund or 07/08/2026 Compass Managed Account Firm Brochure Page 22 of 35  ETP, please refer to the corresponding prospectus. 2) ETFs An ETF is a fund that trades on an exchange throughout the trading day, similar to stocks, and often seeks to track an index (e.g., S&P 500® Index), commodity or commodities (e.g., oil, natural gas, gold, precious metals, etc.), or a basket of assets based upon a theme, territory, or sector (e.g., healthcare, energy, international stock, consumer staples, dividend appreciation, emerging markets China, etc.). As a result, ETFs often do not have the objective to outperform what they are tracking. However, some ETFs are actively managed and do not seek to track a certain index or basket of assets. ETFs can also have unique risks depending on their structure and underlying investments. ETFs can trade at a premium (above) or discount (below) to their net asset value (“NAV”), and ETFs can also be affected by the market fluctuations of their underlying investments. If FTS or a client decides to terminate the Compass account during a down market or when ETFs are experiencing a large volume of redemptions, the value of the ETFs can be significantly below the NAV of the underlying assets held in the ETFs. ETFs can experience further below market valuations if the ETF has invested in illiquid or investments that have experienced less liquidity causing the ETF to take below desired valuations to cover redemptions from shareholders. Additionally, some ETFs have not experienced a down market, and there can be unknown risks associated with ETFs. 3) ETNs An ETN is an unsecured debt obligation of the issuer (usually an investment bank or another financial institution) that often seeks to track a market or strategy and provide returns linked to the performance of a specified index, minus applicable fees. ETNs trade on an exchange throughout the trading day similar to stocks and ETFs but they do not buy or hold assets to replicate or approximate the performance of the underlying index. In addition, ETNs generally do not seek to outperform what they are tracking. Because ETNs are debt instruments, they carry credit risk, meaning a client’s return depends on the financial stability and creditworthiness of the issuer. ETNs can also trade at a premium (above) or discount (below) their indicative value, particularly when market supply and demand fluctuate or if the issuer suspends new issuance. If FTS or a client decides to terminate the Compass account during periods of market stress, reduced liquidity, or concerns about the issuer’s financial health, the value of ETNs may be significantly impacted. Additionally, ETNs can include maturity dates as well as call provisions or early redemption features depending on the specific terms of the ETN, and some may have limited trading activity, which can increase volatility and reduce liquidity. As with ETFs, some ETNs track complex or less-tested strategies, and there may be unknown risks associated with ETNs. 4) ESG, SRI, Faith Based, and Similar Investments and Investment Strategies IARs that engage in Environmental, Social, and Governance (“ESG”), Socially Responsible Investing (“SRI”), Faith Based Investing, or similar investment strategy or strategies will generally choose to avoid investments and/or companies that might otherwise be considered appropriate investment options due to factors that can run contrary to the ESG, SRI, or Faith Based investment strategy. As a result, clients selecting an IAR or having an IAR invest in ESG, SRI, Faith Based, or similar investment strategy can result in lower returns than if the IAR had used a non-ESG, SRI, Faith Based, or similar investment strategy or investments. Furthermore, an IAR’s selection process to include and/or exclude investments can be based upon a number of factors, such as imposing a minimum revenue associated with the activity seeking to be avoided (such as Adult Entertainment). As a result, even if a client selects an ESG, SRI, Faith Based, or similar investment strategy with the IAR, the client could still be invested in investments or companies that the client is seeking to avoid. Additionally, clients selecting an investment strategy or focus on ESG, SRI, Faith Based, or other similar investment strategy with the IAR should refer to the mutual fund or ETN’s prospectus for more details on the ESG, SRI, or Faith Based investment strategy. FTS does not guarantee that a client’s specific ESG, SRI, or Faith Based goals or client’s interpretation of what the ESG, SRI, Faith Based or similar investment strategy will be represented by an IAR or the underlying investments selected. ESG, SRI, Faith Based, or similar investment strategies can be interpreted differently. For example, an IAR that has an investment strategy to invest in “clean energy” might consider companies involved in solar and nuclear energy as clean energy options. Whereas a client may not consider solar and nuclear energy sectors as “clean energy.” 07/08/2026 Compass Managed Account Firm Brochure Page 23 of 35  5) Foreign Exposure Foreign securities, like domestic U.S. securities, are subject to market volatility risk, performance of underlying assets, regulatory risks, economic developments, and other factors that can significantly impact the valuation of a fund or security. In addition, foreign securities are subject to foreign interest rate(s), currency exchange rate, regulatory, geopolitical risks, and other risks, all of which can be greater in emerging markets. These risks are particularly significant for funds that focus on a single country, region, or emerging markets. Foreign markets will at times be more volatile than U.S. markets and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates can also be extremely volatile and can lead to significant losses. As an example, a fund’s underlying assets could have a positive performance; however, the fund’s value could decrease due to current currency exchange rate changes. 6) Legislative and Regulatory Risk Securities and investment strategies used in the Compass account can be adversely affected by new laws or changes to existing laws or regulations. Changes to laws, regulations, or government policies can impact the securities markets as a whole, specific industries, individual issuers of securities, and individual securities. These changes can affect the value, liquidity, or performance of your investments and could occur without prior notice. 7) Money Market Fund Clients could lose money by investing in a money market fund. Although a money market fund generally seeks to preserve the value of a client’s investment at $1.00 per share, FTS, our IARs, and the fund cannot guarantee it will preserve the value of $1.00. A client’s investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. FTS and our IARs, NFS and its affiliates, the money market fund’s sponsor, have no legal obligation to provide financial support to money market funds and client is not to expect that the money market fund’s sponsor will provide financial support to the fund at any time. 8) Municipal Bonds The municipal market is affected by adverse tax, legislative, or political changes, and by the financial condition of the issuers of municipal securities. Municipal funds normally seek to earn income and pay dividends that are expected to be exempt from federal income tax. If a fund investor is a resident in the state of issuance of the bonds held by the fund, interest dividends may also be exempt from state and local income taxes. Income that is exempt from regular federal income tax can be subject to state, local, or federal alternative minimum tax. Certain funds normally seek to invest only in municipal securities generating income exempt from both federal income taxes and the federal alternative minimum tax; however, outcomes cannot be guaranteed, and the funds sometimes generate income subject to these taxes. For federal tax purposes, a fund’s distribution of gains attributable to a fund’s sale of municipal or other bonds are generally taxable as either ordinary income or long-term capital gains. Redemptions, including exchanges, can result in a capital gain or loss for federal and/or state income tax purposes. Tax code changes could affect the municipal bond market. Tax laws are subject to change, and tax law changes or proposed changes can cause the prices of tax-exempt securities to decrease and/or affect the tax-exempt status of securities and securities that hold tax-exempt securities. 9) Stock Markets and Investments Stock markets are volatile and can decline significantly in a short amount of time in response to adverse issuer, political, regulatory, market, or economic developments. Different parts of the market can react differently to these developments. Value and growth stocks can perform differently from other types of stocks. Growth stocks can be more volatile. Value stocks can continue to be undervalued by the market for long periods of time. In addition, stock investments are subject to risk related to market capitalization as well as company-specific risk. Depending on the number of factors, such as, market events, the client’s risk tolerance, and the IAR’s investment strategy or strategies, an IAR may not make any changes to the investment strategies, or the investments used in a Compass account even when the stock markets incur significant losses. 07/08/2026 Compass Managed Account Firm Brochure Page 24 of 35  FTS and our IARs can invest in alternative mutual funds or ETPs, which can use investment strategies that differ from the buy-and-hold strategy typical in the fund industry. Compared to a traditional mutual fund, an alternative fund typically holds more non-traditional investments and can employ more complex trading strategies. Some examples of assets that can be held in alternative mutual funds include, but are not limited to, managed futures, arbitrage, commodities, leveraged loan, global real estate, master limited partnerships, and option contracts. Clients considering a strategy that utilizes alternative investments in a Compass account should be aware of their unique characteristics and risks. In addition to the risks listed above, some of these risks can include, but are not limited to: • Investment Structure: An alternative mutual fund made up of other mutual funds (often referred to as “fund of funds”) can offer greater diversification than a single-strategy or even multi-strategy alternative mutual fund or traditional mutual fund. At the same time, this greater diversification can lead to a flattening of return and potentially less transparency. There can also be an inability to re-allocate or adapt in a way that is beneficial to the overall performance of a particular fund of funds. • Leverage Risk: Using derivatives, such as commodity futures and options to increase the alternative mutual fund’s combined long and short exposure creates leverage, which can magnify the alternative mutual fund’s potential for gain or loss and, therefore, amplify the effects of market volatility on the alternative mutual fund’s share price. • Liquidity Risk: Liquidity risk exists when particular investments of an alternative mutual fund or ETP would be difficult to purchase or sell, possibly preventing the alternative mutual fund or ETP from selling such illiquid securities at an advantageous time or price, or possibly requiring the alternative mutual fund or ETP to dispose of other investments at unfavorable times or prices in order to satisfy the alternative mutual fund or ETP obligations. • Strategy Risk: In addition to the usual market and investment specific risks mutual funds have, alternative mutual funds can carry additional risks from the strategies they use. For example, market-neutral funds tend to have significant portfolio turnover risk that will generally result in higher costs. Similarly, a distressed bond fund is likely to have significant credit risk. 10) Tracking Error Tracking error risk generally applies to securities (such as an ETP) and investment strategies used by our IARs that attempt to track a market index (such as S&P 500® Index) and the deviation of actual performance the client realizes from the performance of the market index it attempts to track. Tracking error can result from numerous factors including but not limited to trading costs, management fees, cash holdings, market conditions - particularly sudden and extreme market changes, client-imposed restrictions, imperfect weighting between the securities and the market index, and changes to the composition of the market index. It is anticipated that tracking error risk will cause the performance of a client’s Compass account or the security or securities within a Compass account to be less or more than the market index. 11) Additional Risks For more risks specific to the underlying assets and the investment strategy used by an IAR, please refer to the mutual fund or ETP’s prospectus. Mutual fund and ETP’s prospectuses can be requested from FTS at any time through one of FTS’ IARs. Item 9 – Disciplinary Information FTS has no material civil or criminal actions or administrative proceedings to report. Below are regulatory events associated with FTS for the past 10 years, but these regulatory events are not limited to FTS’ registered investment advisor. Many of these regulatory events involve FTS’ broker-dealer and not the investment advisory business of FTS. Additional regulatory events involving FTS’ broker-dealer that date further back than 10 years and additional details regarding the below listed FINRA disciplinary actions are found at https://brokercheck.finra.org/firm/summary/628. FINRA – 05/08/2018 - Without admitting or denying the findings, FTS consented to the findings that FTS 07/08/2026 Compass Managed Account Firm Brochure Page 25 of 35  failed to fully comply with an undertaking from a previous Acceptance Waiver and Consent entered into with FINRA in 2009. In addition, FTS made material misstatements and omissions in approximately 77% of a sample set of 250 variable annuity exchanges randomly selected and reviewed by FINRA from among 1,431 variable annuity exchanges. Misstatements and omissions about the cost or benefits of the variable annuity exchange made the exchange appear more beneficial to the customer. FTS also failed to implement a supervisory structure reasonably designed to ensure that its registered representatives obtained and assessed accurate information about the customer’s existing and proposed variable annuities prior to affecting the exchanges. These activities did not involve FTS’ registered investment advisor, nor did it involve FTS’ Compass Program. SEC – 07/18/2023 - FTS settled allegations of wrongdoing by the SEC, in which the SEC alleged that 79 municipal bond underwriting offerings sold to broker-dealers and/or registered investment advisors failed to comply with municipal bond offering disclosure requirements under Rule 15c2-12 of the Securities Exchange Act of 1934 and found that FTS’ policies and procedures weren’t reasonably designed to determine if the broker dealers and/or registered investment advisors satisfied the exemption requirements under Rule 15c2- 12. FTS agreed to cease-and-desist from future violations of those provisions, be censured, and pay $442,465.59 in disgorgement plus prejudgment interest of $67,506.09 to the SEC and a $200,000 civil money penalty. Additional details regarding this Order are found at https://www.sec.gov/files/litigation/admin/2023/34-97937.pdf. These activities did not involve FTS’ registered investment advisor, nor did it involve FTS’ Compass. SEC – 09/29/2023 - FTS settled allegations of wrongdoing by the SEC, where from January 2019 to 2022, FTS employees sent and received Off-Channel Communications that related to the business of the broker-dealer and registered investment advisor. Due to the fact that these communications were not sent or received on FTS systems, FTS failed to surveil, maintain, or preserve these communications. As a result, FTS was required to cease-and-desist from further violation of SEC Rules related to retention of required books and records, pay a civil money penalty in the amount of $8,000,000, and take remedial measures including the hiring of an independent consultant. Additional details regarding this Order are found at https://www.sec.gov/files/litigation/admin/2023/34-98627.pdf. Item 10 – Other Financial Industry Activities and Affiliations A. Fifth Third Securities – Broker-Dealer & Municipal Advisor FTS is registered both as a broker-dealer with FINRA and as a registered investment advisor and municipal advisor with the SEC (registration does not imply a certain level of skill or training). Principal executive officers of the broker-dealer are also officers of the registered investment advisor. IARs of FTS also act as brokerage representatives of FTS, and they solicit other services and products separate from the investment advisory services provided through FTS (e.g., Compass, Passageway, Summit). When an IAR acts in the capacity of a brokerage representative, they receive compensation for these separate activities done under FTS’ broker-dealer. Clients are under no obligation to engage FTS and our IARs for these separate brokerage products and services. B. Fifth Third Bank, National Association (FTB) FTS is a wholly owned subsidiary of FTB. FTB is a federally chartered institution and is not a registered investment advisor under the U. S. Securities & Exchange Commission. It is anticipated that FTB will benefit from the compensation for services provided through Compass. In addition, FTS IARs can recommend or refer clients to FTB, where FTB provides investment advisory services. These services are separate from the advisory accounts and services offered by FTS. If a client opens an investment advisory account with FTB based on a recommendation or referral from FTS or an FTS IAR, FTS and our IAR(s) receive ongoing compensation from FTB. The processes, procedures, and documentation required to open and maintain an account with FTB also differ from those of FTS and may be less burdensome than FTS’ requirements. These compensation arrangements, along with the differences in processes and requirements, create conflicts of interest for both FTS and our IARs. To help mitigate these conflicts of interest, FTB performs supervisory reviews of recommendations and referrals made by FTS and our IARs to validate that such recommendations are based on the client’s individual needs and best interest, 07/08/2026 Compass Managed Account Firm Brochure Page 26 of 35  rather than on the compensation received by FTS and our IARs. C. Fifth Third Insurance Agency, Inc. (FTIA) FTIA is a licensed insurance agency, which is a wholly owned subsidiary of FTB. FTS’ IARs act as insurance agents for FTIA. FTS and its IARs offer insurance products and services to advisory clients outside of Compass accounts. Clients are under no obligation to engage FTIA or its insurance agents for these separate services and products for which a customary commission is received. These insurance products are separate from Compass and are not considered managed assets within Compass. D. Frankin Street Advisors, Inc. (Franklin Street Advisors) Franklin Street Advisors is a registered investment advisor that is a wholly owned subsidiary of FTB and is an affiliated entity of FTS. Franklin Street Advisors is not a Program Manager currently available in the Compass Program; therefore, FTS does not consider the affiliated entity, Franklin Street Advisors, a conflict of interest to Compass clients or prospective clients. FTS operates independently from Franklin Street Advisors, although the two entities share certain resources, such as technology applications and other support services provided through Fifth Third Bank. E. Fifth Third Wealth Advisors, LLC (FTWA) FTWA is a wholly owned, indirect subsidiary of FTB and an adviser registered with the U.S. Securities and Exchange Commission. FTWA is not a Program Manager currently available in the Compass Program; therefore, FTS does not consider the affiliated entity, FTWA, a conflict of interest to Compass clients or prospective clients. FTS operates independently from FTWA, although the two entities share certain resources, such as technology applications and other support services provided through Fifth Third Bank. F. Comerica Securities, Inc. (Comerica Securities) Comerica Securities is a wholly owned subsidiary of FTB and is a broker-dealer and member FINRA/SIPC. Comerica Securities is not a Program Manager available in the Compass Program and currently does not provide investment advisory services to retail customers; therefore, FTS does not consider the affiliated entity, Comerica Securities, a conflict of interest to Compass clients or prospective clients. The two entities share certain resources, such as technology applications and other support services provided through Fifth Third Bank. Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading A. Code of Ethics FTS has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. FTS' Code of Ethics is based upon the principle that FTS and its employees owe a fiduciary duty to clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with the firm and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. The Code of Ethics is designed to help maintain the high ethical standards long maintained by FTS continue to be applied. The purpose of the Code of Ethics is to preclude activities which lead to or give the appearance of conflicts of interest, insider trading and other forms of prohibited or unethical business conduct. FTS’ fiduciary duty means that FTS has an affirmative duty of utmost good faith to act solely in the best interest of its clients. FTS and its employees are subject to the following specific fiduciary obligations when dealing with investment advisory clients: • The duty to have a reasonable, independent basis for the investment advice provided; • The duty to help confirm that investment advice is suitable to meeting the client’s individual investment objectives, needs and circumstances; and • A duty to be loyal to clients. To implement the Code of Ethics, all FTS access persons are required to acknowledge their receipt of the FTS’ Code of Ethics. FTS’ IARs are subject to specific personal securities transactions and holdings reporting 07/08/2026 Compass Managed Account Firm Brochure Page 27 of 35  requirements. FTS’ Code of Ethics further includes the FTS policy prohibiting the use of material non-public information. FTS requires that all access persons must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. Any individual not in observance of the above may be subject to termination or other disciplinary actions. Advisory clients or prospective advisory clients can receive the full version of FTS’ Code of Ethics by making a written request to: Fifth Third Securities, Inc. Attn: Compliance Department 38 Fountain Square Plaza MD: 1090XB Cincinnati, OH 45263 B. Participation or Interest in Client Transactions As discussed in Item 5A – Investment Advisory Fees and Compensation, fixed income trades can result in a markup or markdown charged in addition to the investment advisory fee you pay for your FTS account, and it varies based on several factors including, but not limited to, the type of security being bought or sold, maturity date, and size of the transaction. FTS helps address this conflict by having a separate group of securities registered principals that review activities in Compass, and these registered principals do not directly receive compensation from the recommendations made by IARs. C. Personal Trading IARs are prohibited from buying or selling securities (or related securities such as warrants, options, or futures) either prior to or subsequent to submitting a trade for a Compass client with the intent to benefit from a price fluctuation generated from the Compass client’s trade. Nevertheless, FTS’ IARs can invest in the same securities (or related securities such as warrants, options, or futures) that they recommend to Compass clients. Our IARs can also recommend securities to Compass clients at or about the same time as our IARs buy or sell the same securities in their personal accounts. This creates a potential conflict of interest, including the risk that the IAR’s personal trading could influence, or appear to influence, investment recommendations, or that the IAR’s personal trading could receive more favorable timing or pricing than trades for Compass clients. To help address these conflicts, IARs are required to adhere to FTS’s Code of Ethics that emphasizes the IAR’s fiduciary duty to avoid serving their own personal interests ahead of our clients. IARs are also subject to specific personal securities transactions and holdings reporting requirements. IARs are prohibited from purchasing initial public offerings in their own personal accounts under FTS’ Code of Ethics, and IARs must receive pre-clearance before investing in private securities offerings (e.g., Regulation D offerings). D. Conflicts Related to Receipt of Gifts and Business Entertainment FTS has additional policies and procedures to help address other potential material conflicts of interest that arise from our IARs giving and receiving gifts and gratuities and business entertainment. IARs can receive business entertainment from product or service providers. Examples of business entertainment include, but are not limited to, an occasional meal or a ticket to an event (e.g., concert, game, local event). This creates a conflict of interest for the IAR where the IAR recommends the product associated with the company who has provided the business entertainment. To help mitigate this conflict, FTS generally limits the amount of business entertainment that can be received by its IAR per product or service company when the business entertainment is not associated with training, an FTS meeting, or a meeting with an FTS client. This limit does not apply to business entertainment of de minimis value as long as the value of the business entertainment received is below $40. Additionally, IARs can receive gifts from product companies, asset managers, or vendors. This creates a conflict of interest for the IAR where the IAR recommends the product or service associated with the company who has provided the gift. To help mitigate this conflict, FTS and regulatory rules prohibit the 07/08/2026 Compass Managed Account Firm Brochure Page 28 of 35  receipt of gifts over a certain limit per company and per calendar year. IARs are required to report to FTS when they receive a gift that was provided by a product or service company with the exception of promotional items of small dollar value (e.g., water bottle with the company logo on the bottle, pens, notebooks, t-shirt). Item 12 – Brokerage Practices A. Broker-Dealer Selection for Client Transactions In Compass, clients establish their accounts through NFS, the clearing broker-dealer and custodian for Compass accounts. NFS performs the necessary execution and custodial services on behalf of FTS. Clients do not have the ability to request other clearing broker-dealers for their accounts. Although FTS has found the services of NFS to be consistent with its obligation to seek best execution and that the fees (including but not limited to commissions and/or transaction fees) charged are reasonable in relation to the value of the brokerage and research services provided, a client may nonetheless pay a fee for services that is higher than another qualified broker-dealer might charge to effect the same transaction. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a clearing broker-dealer’s services, including the value of research provided, execution capability, commission rates and the benefit to all clients. 1) Research and Other Soft Dollar Benefits FTS does not enter into agreements that involve soft dollar benefits. However, as part of our agreements with NFS, FTS does receive benefit in the form of credits and discounts for using NFS as our clearing broker-dealer and custodian. The receipt of these benefits is not dependent on the amount or volume of client transactions placed through NFS or commissions earned by NFS for placement of trades for FTS (i.e., soft dollar benefits). Conflicts of interest due to our agreements with NFS are outlined below. a) NFS Credits & Discounts NFS provides FTS with credits in the form of receipt of payment to FTS and the offset or reduction of fees and expenses owed by FTS to NFS when FTS meets certain criteria established by NFS. These credits include singular or infrequent credits (e.g., credit as part of contract renewal or update) and recurring credits (e.g., monthly, annual intervals). One of these credits is calculated based on net flows to NFS, defined as incoming cash and securities transfers less outgoing transfers. Accordingly, FTS has conflicts of interest in both promoting transfers of cash and securities to NFS and retaining those assets with NFS. This credit excludes cash and securities associated with the Deconversion Credit referenced below. FTS’ receipt of these NFS credits represents a conflict of interest. To help mitigate the conflict of interest these credits create, FTS and NFS have limited the criteria that have to be met by FTS to receive these credits. For example, the receipt of these credits are not dependent on the amount or volume of transactions placed through NFS, the amount of charges/fees assessed by NFS to FTS, commissions earned by NFS for placement of trades, the number of clients or accounts FTS has with NFS (with the exception of the Deconversion Credit), and does not prevent FTS to place a security transaction or transactions through another firm if FTS believes it is in the client’s best interest. In addition, in connection with Fifth Third Bancorp’s acquisition of Comerica Incorporated and its subsidiaries, including Comerica Bank, N.A., NFS will provide FTS with: (1) a one-time credit to offset costs associated with the conversion of accounts and assets from Ameriprise Financial Services, LLC (“Ameriprise”) to NFS (the “Deconversion Credit”), (2) an increase to an existing annual credit provided by NFS to FTS, and (3) discounted fees from NFS’s affiliated entity, Fidelity Institutional Wealth Adviser LLC, for investment advisory accounts which includes Compass accounts. The Deconversion Credit is contingent on the volume of assets and accounts transferred. If the transferred assets and accounts fall below a specified threshold, NFS will not provide the Deconversion Credit. Additionally, if a specified percentage or more of the assets and accounts transferred to NFS in connection with this conversion are subsequently moved away from NFS within a defined period after the conversion, 07/08/2026 Compass Managed Account Firm Brochure Page 29 of 35  FTS is to negotiate with NFS to determine whether FTS will reimburse a portion of the Deconversion Credit. As a result, FTS has conflicts of interest related both to encouraging the transfer of accounts and assets from Ameriprise to NFS and to retaining those accounts and assets after the transfer. To help mitigate these conflicts, the Deconversion Credit is not tied to the transfer of specific asset types and does not depend on future transactions occurring at NFS. b) Conflicts Related to Interest on Cash Holdings NFS shares credit interest compensation with FTS on cash balance holdings held in Compass accounts. To help mitigate this conflict of interest, FTS requires clients to select a core account investment vehicle (a/k/a sweep option) for available cash balances instead of allowing the Compass account to remain in cash. Even when a client selects a core account investment vehicle, there are situations when a Compass account will still end up holding a cash balance. As a result, FTS will receive credit interest from this cash balance holding. Additionally, we do not directly share with IARs the credit interest income received from cash holdings in a Compass account, and lastly, the interest earned on cash holdings in a Compass account that FTS receives from NFS is reimbursed directly to the client’s Compass account. These reimbursements for cash holdings occur in the same quarter or the following quarter that FTS receives the interest from NFS. Furthermore, FTS Clients can select an available core account investment vehicle or change the core account investment vehicle at any time for their Compass Account by contacting their IAR. Additional information regarding the available investment options for your core account investment vehicle can be found at 53.com/ftsdisclosure under “Core Account Investment Vehicle Disclosure Summary”. c) Conflicts Related to Clearing Firm (NFS) (1) No Cost Transactions FTS pays NFS clearance and execution fees for trades placed in Compass accounts. These clearance and execution fees are in part based upon the type of security involved in the transaction (e.g., listed equity, over-the-counter equities, municipal bonds, mutual funds, etc.). However, NFS makes transactions in certain mutual funds and ETPs available to FTS at no cost if the mutual fund or ETPs is part of NFS’ NTF Mutual Funds Program, NTF Managed Account Program, and iNTF Managed Account Program. The availability of no cost transactions creates a conflict of interest for FTS by providing the availability to have transactions in certain mutual funds and ETPs at no cost while transactions in other mutual funds and ETPs not part of NFS’ NTF Mutual Funds Program, NTF Managed Account Program, and iNTF Managed Account Program are assessed a charge or fee. To help mitigate this conflict of interest, FTS does not distribute to IARs the list of mutual funds and ETPs on NFS’ NTF Mutual Funds Program, NTF Managed Account Program, and iNTF Managed Account Program. Furthermore, IARs perform initial and ongoing due diligence on the securities that are used by them in Compass accounts. (2) NFS Credits & Discounts NFS provides FTS with credits in the form of receipt of payment to FTS and the offset or reduction of fees and expenses owed by FTS to NFS when FTS meets certain criteria established by NFS. These credits include singular or infrequent credits (e.g., credit as part of contract renewal or update) and recurring credits at (e.g., monthly, or annual intervals). One of these credits is calculated based on net flows to NFS, defined as incoming cash and securities transfers less outgoing transfers. Accordingly, FTS has conflicts of interest in both promoting transfers of cash and securities to NFS and retaining those assets with NFS. This credit excludes cash and securities associated with the Deconversion Credit referenced below. FTS’ receipt of these NFS credits represents a conflict of interest. To help mitigate the conflict of interest these credits create, FTS and NFS have limited the criteria that have to be met by FTS to receive these credits. For example, the receipt of these credits are not dependent on the amount of assets FTS has with NFS, the amount or volume of transactions placed through NFS, the amount of charges/fees assessed by NFS to FTS, any commissions earned by NFS for placement of trades, the number of clients or accounts FTS has with NFS (with the exception of the Deconversion Credit), and does not prevent FTS to place a security transaction or transactions through another firm if FTS believes it is in the client’s best interest. In addition, in connection with Fifth Third Bancorp’s acquisition of Comerica Incorporated and its 07/08/2026 Compass Managed Account Firm Brochure Page 30 of 35  subsidiaries, including Comerica Bank, N.A., NFS will provide FTS with: (1) a one-time credit to offset costs associated with the conversion of accounts and assets from Ameriprise Financial Services, LLC (“Ameriprise”) to NFS (the “Deconversion Credit”), (2) an increase to an existing annual credit provided by NFS to FTS, and (3) discounted fees from NFS’s affiliated entity, Fidelity Institutional Wealth Adviser LLC, for investment advisory accounts. The Deconversion Credit is contingent on the volume of assets and accounts transferred. If the transferred assets and accounts fall below a specified threshold, NFS will not provide the Deconversion Credit. Additionally, if a specified percentage or more of the assets and accounts transferred to NFS in connection with this conversion are subsequently moved away from NFS within a defined period after the conversion, FTS is to negotiate with NFS to determine whether FTS will reimburse a portion of the Deconversion Credit. As a result, FTS has conflicts of interest related both to encouraging the transfer of accounts and assets from Ameriprise to NFS and to retaining those accounts and assets after the transfer. To help mitigate these conflicts, the Deconversion Credit is not tied to the transfer of specific asset types and does not depend on future transactions occurring at NFS. 2) Trade Errors If FTS, our IARs, or FIWA makes an error when submitting a trade order on a client’s behalf, it is the policy of FTS that the trade error be corrected as soon as possible and in such a manner the client is not disadvantaged and bears no loss as a result of the error. Upon the identification of a trade error, FTS will work with NFS and/or FIWA to take the appropriate steps necessary to rectify the error. If correcting a trade error results in a loss or a gain within the client’s account, FTS or FIWA will retain any gain or absorb any loss. B. Order Aggregation IARs can pool securities trades for the same security for multiple client accounts to create large blocks of trades. This is done to help achieve best price execution for the total pool of accounts and/or to help avoid conflicts of interest of favoring one client over another. Once the trades have been executed, the securities or proceeds are allocated back to the pool of client accounts at the average price for the block trade as a whole. IARs must adhere to FTS’ allocation policies. For more information on block trading please see FIWA’s ADV Part 2A Brochure. A current copy can be requested from your IAR or can be obtained directly from the SEC’s website (https://adviserinfo.sec.gov/firm/brochure/301896) and selecting “Fidelity Managed Account Xchange” under Brochure Name. Item 13 – Review of Accounts A. Frequency and Nature of Review of Client Accounts or Financial Plans FTS’ IARs periodically review client Compass accounts. Reviews by IARs can include the client’s current asset allocation and the managed securities in the Compass account. In addition, IARs will generally attempt to meet with Compass clients each calendar year and review their financial and investment goals, risk tolerance, and other information relevant to maintaining an appropriate investment strategy for the client, as well as review the investment management of the Compass account. These reviews by IARs sometimes result in rebalancing a Compass account back to or a close approximate of the asset allocation selected by the client. These reviews with Compass clients can be conducted in-person, telephonically, or by a videoconferencing system (e.g., Microsoft Teams). Generally, if FTS is unable to conduct a review with a Compass client for two consecutive calendar years, FTS will commence with termination of the advisory relationship with the Compass client in the third year unless a review with the client is able to occur. However, FTS understands that in certain client situations meeting with an FTS IAR may not be practical and in those circumstances (e.g., military service member deployed overseas), FTS can choose not to terminate the advisory relationship with the Compass client. B. Factors Prompting Review of Client Accounts Other Than a Periodic Review FTS and our IARs can perform reviews beyond the periodic reviews mentioned above. These additional reviews can be prompted by a client’s request, FTS’ internal monitoring and reviews, statutory or regulatory requests or 07/08/2026 Compass Managed Account Firm Brochure Page 31 of 35  rule changes, market developments, potential issues identified with respect to the Compass account (e.g., suspected fraud or money laundering), among other factors. C. Content and Frequency of Account Reports to Clients On a quarterly basis, FIWA sends Compass clients a statement containing a description of the activity that occurred in the client’s account(s) during the previous quarter including, but not limited to, the following: • Securities holdings • Account value • Transactions occurred in the account, including contributions and withdrawals • Investment advisory fees charged for the period This quarterly statement includes a statement to the effect that a Compass client is to contact FTS if there have been any changes in financial situation or investment objectives, if the Compass client wishes to impose reasonable investment restrictions on the management of the Compass account, or if the Compass client wishes to reasonably modify existing investment restrictions. FTS does not independently verify the accuracy of the performance information provided by FIWA on client quarterly performance reports. In addition, clients receive either monthly statements from NFS if securities transactions (e.g., purchases, sales, or transfers) occur in the Compass account or quarterly statements from NFS if no transactions occur in the Compass account. FTS strongly recommends clients compare the holdings and transactions listed on NFS statements against the quarterly performance reports provided by FIWA. The client should promptly alert their IAR or FTS if the client identifies any discrepancies between these statements. FIWA performance statements reflect a trade-date basis, and NFS statements reflect a settlement-date basis. This means transactions that occur at the end of a quarter that have not settled will appear on the FIWA statement but will not appear on the NFS statement. When FTS or a client terminates the Investment Management Agreement and the corresponding Compass account, the client will not receive a quarterly performance report for the quarter in which the Compass account was terminated. Item 14 – Client Referrals and Other Compensation FTS and our parent company, FTB, recognize and provide rewards to our Financial Professionals which include Financial Professionals who are IARs. D. FTS Education Summit Each year, FTS holds an educational meeting to provide enhanced training for our top Financial Professionals, including our IARs. FTS provides travel, food, entertainment, lodging accommodations, and other expenses for our Financial Professionals who are invited to the FTS Education Compass. FTS generally invites the Financial Professionals who have produced the most revenue based upon the specific role of the Financial Professional. Criteria for qualifying for an invitation to the FTS Education Compass can change from year-to-year, but it is anticipated that the criteria will generally involve the overall performance of the IAR. E. FTB President’s Circle Each year, FTB holds the President’s Circle meeting for top-performing FTB employees based upon role, including our IARs. Invitation to the FTB President’s Circle is generally based on the overall revenue to FTB for a period of time. The revenue counted towards being invited to the FTB’ President’s Circle includes revenue associated with FTS’ transactions and accounts. FTS generally has no final determination for the criteria of the FTB’s President’s Circle, but FTS does have input as to the general structure to help ensure that the criteria complies with FTS’ standards and regulatory rules. IARs who are not invited cannot attend the FTS Education Compass or FTS President’s Circle. These factors create a conflict of interest for IARs if they would like to be invited to these events. To help mitigate this conflict, FTS employs a separate group of principals who generally review the recommendations of IARs that result in securities 07/08/2026 Compass Managed Account Firm Brochure Page 32 of 35  transactions or opening investment advisory accounts. Additionally, criteria for an invitation to these events is not based solely on the revenue of a single product, product or service type, and the time period in which the overall revenue is based will be for a longer period of time (generally between 9-12 months). F. Area and Regional Meetings IARs can also receive recognition in area and/or regional meetings. Examples of recognition can include verbal recognition, trophies, plaques, or other physical awards. G. Compensation to Non-Supervised Persons for Client Referrals FTS currently does compensate individuals who are securities registered with FTS for qualified client referrals to FTS. To qualify for the referral fee the following conditions must be met: 1) the client is not an existing client of FTS at the time of the referral, 2) the client agrees to and has an appointment with a Registered Representative of FTS, and 3) the client has a minimum of $50,000 in investable assets. If these three conditions are met, individuals who are securities registered with FTS would receive a $25 referral fee. A referral fee is not contingent upon the client opening an account (Investment Advisory or Brokerage), purchasing any security or investment, or FTS receiving any type of compensation from the client or their investable assets. FTS pays on-going compensation to IARs who are made available to some Compass clients to assist with their Compass account when their primary IAR is unavailable. Assistance provided by these IARs will generally be around the administration of the accounts, such as Compass account balance inquiries, specific information requests about the client’s Compass account holdings (e.g., current value of a security, date(s) when a specific security was purchased or sold, prospectus request, etc.), and information about the IARs, as applicable. Assistance with Compass clients would not include making investment decisions for the Compass account, recommendations to change to other investment advisory programs of FTS, or asset allocation changes to an existing Compass account without the involvement of the primary IAR. These IARs that receive the nominal fee are registered as IARs with FTS and applicable clients will receive a copy of the IAR’s Investment Advisory Supplemental Brochure (Form ADV 2B) in addition to their primary IAR’s Investment Advisory Supplemental Brochure. Item 15 – Custody NFS is the qualified custodian for FTS. Compass clients receive either monthly statements from NFS if securities transactions (e.g., purchases, sales, or transfers) occur in the Compass account or quarterly statements from NFS if no transactions occur in the Compass account. Clients are encouraged to compare the holdings and transactions listed on NFS statements against the quarterly performance reports provided by FIWA (See 13.C. – Content and Frequency of Account Reports to Clients). The client should promptly alert their IAR or FTS if the client identifies any discrepancies between these statements. FIWA performance statements reflect a trade-date basis, and NFS statements reflect a settlement-date basis. This means transactions that occur at the end of a quarter that have not settled will appear on the FIWA statement but will not appear on the NFS statement. Item 16 – Investment Discretion By signing the IMA, Compass clients grant FTS discretionary authority to manage Compass account assets. Such discretionary authority allows FTS to make all investment decisions with respect to the client’s Compass account(s) when FTS deems appropriate and without prior consultation with the client, to buy, sell, exchange, convert and otherwise trade in any equity, mutual fund, ETP, fixed income security, UIT, publicly traded REIT or other security approved by FTS or FIWA for use in Compass accounts. In addition, this discretionary authority allows FTS to invest a client’s accounts/assets in a lower risk tolerance up to one level than the client has selected (see Item 4B – Compass Investment Management Program). Compass clients have the opportunity to place reasonable investment restrictions on the types of investments that will be managed on the client's behalf within Compass accounts (see Item 4.C. – Availability of Customized Services for Individual Clients). 07/08/2026 Compass Managed Account Firm Brochure Page 33 of 35  Item 17 – Voting Client Securities FTS and our IARs are prohibited from accepting voting authorizations or instructions from Compass clients and exercising or voting on any security-related issues for assets held in Compass accounts. However, IARs can provide Compass clients with general information about proxy voting such as the meaning of the vote, deadlines, and potential implications. Responsibility for proxy voting is governed by the terms outlined in the IMA. Compass clients receive their proxies or other solicitations directly from NFS. Please contact your IAR directly or contact us at 888-889- 1025 with questions about a particular solicitation. Item 18 – Financial Information A. Balance Sheet FTS is not required to provide a balance sheet with this Brochure because we do not solicit prepayment of more than $1,200 in fees per client, six months or more in advance. B. Financial Conditions Likely to Impair Ability to Meet Contractual Commitments to Clients FTS is not aware of any financial impairment that will preclude us from meeting our contractual commitments to our advisory clients. C. Bankruptcy Filings FTS has not been the subject of a bankruptcy petition in the last ten years. (Remainder of the Page Intentionally Left Blank) 07/08/2026 Compass Managed Account Firm Brochure Page 34 of 35  Investment Advisory Account Service Fee Schedule*,1 Effective Date July 8, 2026 Fee Description Fee Frequency Aged Legal Items Fee $25.00 Per item Varies Per applicable occurrence American/Global Depositary Receipt Fee2 Bounced or Return Check Fee3 $50.00 Per item Country/State Taxes4 Varies Per applicable transaction Debit Interest Charge NFBLR5 plus 3% Accrues daily, charged monthly Foreign Security Movement Fee $75.00 Per security Foreign Tax Fee6 Varies Per applicable occurrence Options Regulatory Fee7 Varies Per options transaction Overnight Mailing Fee $10.00 Per delivery Physical Reorganization Fee $25.00 Per item Precious Metals Fee Varies8 Per security SEC Section 31 Fee9 Varies Per applicable transaction Stop Payment on Check Fee3 $30.00 Per item Trade Settlement Extension Fee3 $30.00 Per extension Transfer Agent – Register/Ship Fee10 $25.00 Per certificate Outgoing Wire Transfer Fee $15.00 Per wire Important Disclosures * This Investment Advisory Account Service Fee Schedule discloses only account-level service fees and does not include investment advisory fees. For information on the investment advisory fees, refer to your Statement of Investment Selection or Advisory Supplemental Brochure. To learn more about fees and charges for Fifth Third Securities investment advisory programs (e.g., Compass, Passageway, Summit), review the corresponding Form ADV 2A brochure at 53.com/ftsdisclosure. 1 All Fees are subject to change and can vary by program and arrangement (e.g., Investment Advisory, Standard, Preferred, Private Bank, Online). Certain fees (e.g., regulatory, state and foreign government fees, etc.) are outside of the control of National Financial Services, LLC and Fifth Third Securities and can be changed or added at any time without prior notice. 2 American Depositary Receipts (ADRs) and Global Depositary Receipts (GDRs) may have administrative, or management type, fees associated with them which are passed through to shareholders. Refer to the ADR or GDR’s prospectus for information on pass through fees. 3 Fee is comprised of the combined fees assessed and paid to National Financial Services, LLC and Fifth Third Securities. 4 Fee represents charge assessed by some foreign governments on purchases and sells of securities of companies incorporated in thei r countries. The fee corresponds to the amount of tax, as set forth under applicable foreign tax laws. It is generally a percentage or scheduled amount based on the total purchase or sale amount of the securiti es subject to tax. The fee is passed on from the foreign government to the client. When applicable, the fee will appear on the trade confirmation. 5 The National Financial Base Lending Rate (NFBLR) is set at the discretion of National Financial Services, LLC after considering commercially recognized interest rates, industry conditions regarding the extension of margin credit and general credit conditions. 6 Fee represents charge assessed by some foreign governments on income generated from securities of companies incorporated in their countries. The fee corresponds to the amount of tax, as set forth under applicable foreign tax laws. It is generally a percentage or scheduled amount based on the income generated from the securiti es subject to tax. The fee is passed on from the foreign government to the client. When applicable, the fee will appear on the monthly or quarterly account statement. 7 Fee represents charge assessed by the Options Clearing Corporation (OCC) on all options transactions that are passed on to you and will be displayed on the trade confirmation as Activity Assessment Fee. 8 Fee varies based on several factors regarding the precious metal including, but not limited to, package weight, value, delivery location, and insurance required to ship. 9 Fee represents charge assessed by the SEC (Section 31 Fee) that is passed on to you and will be displayed on the trade confirmation as Activity Assessment Fee. The fee is calculated on the investment amount (principal) of applicable transactions. More information on the Section 31 Fee can be found on the SEC’s website. 10 This fee generally appears in your account as DRS Registration. Fifth Third Bank, N.A. provides access to investments and investment services through various subsidiaries, including Fifth T hird Securities. Fifth Third Securities is the trade name used by Fifth Third Securities, Inc., member FINRA/SIPC, a registered broker-dealer and a registered investment advisor registered with the U.S. Securities and Exchange Commission (SEC). Registration does not imply a certain level of skill or training. Securities, Investments, Investment Advisory Services, and Insurance: Are Not FDIC Insured Offer No Bank Guarantee Are Not Insured By Any Federal Government Agency May Lose Value Are Not A Deposit 07/08/2026 Compass Managed Account Firm Brochure Page 35 of 35 

07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 1 of 61  Item 2 – Material Changes This section describes the material changes to the Fifth Third Securities, Inc. “Brochure” since the March 31, 2026 version. • Item 4.B.4) – Dollar Cost Averaging – This section has been updated to disclose that the specified time limitation applicable to dollar-cost averaging does not apply to securities or investments designated as Unsupervised Assets. See page 9 for additional information. • Item 4.B.8)d. – Fund Strategist Portfolio – To help clients better understand the differences between the advisory programs offered under Passageway when reviewing this Brochure, FTS has created this Fund Strategist Portfolio category. Fund Strategist Portfolio category reflects a range of Portfolio Managers that FIWA provides FTS access to, which these Portfolio Managers support the management of client models. The current and new programs that fall under this new category include the AllianceBernstein Program, Aspire Program, BlackRock Program, Brinker Capital Program, Cantor Fitzgerald Program, Capital Group Program, FEG Program, Frontier Program, Goldman Sachs Mutual Fund Program, Goldman Sachs ETF Program., John Hancock Program, Richard Bernstein Program, Russell Program, Symmetry Program, Vanguard Program, Voya Program, and Wilshire Program. See pages 13-20 for additional information. • Item 4.B.8)d.(3) – BlackRock Program – Update section to reflect multiple investment strategies that can be provided under the BlackRock Program. The name of the program has been changed from “BlackRock Global Allocation Selects Program” to the “BlackRock Program.” Additionally, this section has been revised to reflect that the investment adviser associated with the BlackRock Program from BlackRock Advisors, LLC to BlackRock Investment Management, LLC. See page 14 for additional information. • Item 4.B.8)d.(11) – John Hancock Portfolios Program (John Hancock Program) – Section was added to disclose a new Passageway program where FIWA has retained Manulife Investment Management (US) LLC (a subsidiary of John Hancock Subsidiaries LLC) to recommend investments and models in the John Hancock Program. See page 18 for additional information. • Item 4.B.8)d.(12) – Richard Bernstein Program – Section was added to disclose a new Passageway program where FIWA has retained Richard Bernstein Advisors, LLC to recommend investments and models in the Richard Bernstein Program. See pages 17-18 for additional information. • Item 4.B.8)d.(14) – Symmetry Managed Portfolio Program (“Symmetry Program”) – The name of the program has been changed from “Symmetry Managed Mutual Fund Portfolio Program” to the “Symmetry Managed Portfolio Program.” In addition, this section was Updated to reflect that client grants FIWA discretionary authority to manage the assets in client’s Symmetry Program account, and FIWA has retained Symmetry Partners, LLC to assist with the recommendation of investments and models. See pages 18-19 for additional information. • Item 4.B.8)d.(16) - Voya Investment Management Program (Voya Program) – Section was added to disclose a new Passageway program where FIWA has retained Voya Investment Management Co., LLC to recommend investments and models in the Voya Program. See pages 19-20 for additional information. • Item 4.C.1)a – NFS Minimum Account Fees – Added section disclosing that FIWA charges FTS a minimum fee for investment advisory accounts. See page 23 for additional information. • Item 4.D.4) – Ineligible Accounts for Householding Advisory Fees – Added section to disclose types of accounts that are not included in the calculation of Householding for potential lower investment advisory fees. See page 25 for additional information. 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 2 of 61  • Item 4.E.1)a. – Bonuses & Performance Based Compensation – Added section disclosing some IARs are eligible for bonuses or other performance-based compensation. See page 26 for additional information. • Item 4.E.1)d. – Retirement Compensation – Added section disclosing that IARs in the role of an Investment Executive have the potential to participate in the receipt of compensation after their retirement from FTS and the securities industry. See pages 28-29 for additional information. • Item 4.M. – Unsupervised Assets – Section added describing the process on how a client can request to transfer a security or investment into a Passageway account but not have that security or investment immediately managed as part of the account's investment strategy and the important considerations before making a request. See pages 32-33 for additional information. • Item 6.C.2)j – Exchange Traded Notes (“ETN”s) – Added section discloses risks associated with investing in ETNs. See page 39 for additional information. • Item 9.B.2)a. – Related Entities, Fifth Third Bank, N.A. (FTB) – Update information regarding the conflicts of interest related to recommendations or referrals made by FTS and our IARs to FTB for investment advisory services. These FTB investment advisory services are separate from the advisory accounts and services offered by FTS, including Passageway. See pages 43-44 for additional information. • Item 9.C.4) – Conflict Related to Recommending Passageway Account vs. Compass Account – Added section related to conflict of interest related to IARs making recommendation of Passageway or Summit Management Accounts when the IAR is not eligible to recommend the Compass Managed Account Program. See page 45 for additional information. • Item 9.C.8)b – NFS Credits & Discounts – Updated section to reflect the current credits and discounts FTS receives or can receive from the clearing and custody firm, National Financial Services LLC and the conflicts of interest the receipt of these credits and discounts create. See page 47 for additional information. • Item 9.C.15) – Conflicts Related to the John Hancock Program – Added section disclosing the conflicts of interest related to the new John Hancock Program. See page 49 for additional information. • Item 9.C.17) – Conflicts Related to the Symmetry Program – Update section disclosing the conflicts of interest related to Symmetry recommendations that will include mutual funds and/or ETFs made available, issued, advised, or sub-advised by Symmetry or affiliated entity(ies) of Symmetry. See page 49 for additional information. • Item 9.C.19) – Conflicts Related to the Voya Program – Added section disclosing the conflicts of interest related to the new Voya Program. See page 50 for additional information. • Item 9.G. – Client Referrals and Other Compensation – Added subsections related to FTS’ Education Summit, Fifth Third Bank’s President’s Circle, and Area and Regional Meetings. See pages 52-53 for additional information. Item 3 – Table of Contents ITEM 1 – COVER PAGE .................................................................................................................................... 1 ITEM 2 – MATERIAL CHANGES ..................................................................................................................... 2 ITEM 3 – TABLE OF CONTENTS ................................................................................................................... 3 ITEM 4 – SERVICES, FEES, AND COMPENSATION ................................................................................... 6 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 3 of 61  a) b) c) d) e) a) a) b) A. ABOUT FIFTH THIRD SECURITIES ............................................................................................................................ 6 B. PASSAGEWAY INVESTMENT MANAGEMENT PROGRAMS ............................................................................................. 7 1) Fiduciary Duties ........................................................................................................................................... 7 2) Reasonable Investment Restrictions ........................................................................................................... 8 3) Limitation of Products and Types of Products ............................................................................................ 8 4) Dollar Cost Averaging ................................................................................................................................. 9 5) Terminating Passageway Services .............................................................................................................. 9 6) Fidelity Institutional Wealth Adviser, LLC (“FIWA”) .................................................................................... 9 7) Tax Overlay Service ..................................................................................................................................... 10 8) Passageway Programs ................................................................................................................................ 10 Passageway One Program ................................................................................................................................. 10 Advisor Directed Program ................................................................................................................................. 12 Separately Managed Account Program (“SMA Program”) ................................................................................ 12 Fund Strategist Portfolio ................................................................................................................................... 13 (1) AllianceBernstein Dynamic Multi-Asset Program (“AllianceBernstein Program”) .............................................. 13 (2) Aspire Strategist Portfolios Program (“Aspire Program”) ................................................................................... 14 (3) BlackRock Program (“BlackRock Program”) ........................................................................................................ 14 (4) Brinker Capital Management Program (“Brinker Capital Program”) .................................................................. 14 (5) Capital Global Model Portfolios Program (“Capital Group Program”) ................................................................ 15 (6) Cantor Fitzgerald Managed Sponsored Program (“Cantor Fitzgerald Program”)............................................... 15 (7) Frontier Asset Model Provider Investment Strategies Program (“Frontier Program”) ........................................ 15 (8) Fund Evaluation Group Managed Program (“FEG Program”) ............................................................................. 16 (9) Goldman Sachs Multi-Manager Mutual Fund Portfolio Program (“Goldman Sachs Mutual Fund Program”) – formerly known as the Standard and Poor’s Managed Mutual Fund Portfolio Program ......................................... 16 (10) Goldman Sachs Multi-Manager Exchange Trade Funds Portfolio Program (“Goldman Sachs ETF Program”) – formerly known as the Standard and Poor’s Exchange Trade Funds Portfolio Program ....................................... 17 (11) John Hancock Portfolios Program (“John Hancock Program”) .......................................................................... 17 (12) Richard Bernstein Program ............................................................................................................................... 18 (13) Russell Investment Management Program (“Russell Program”) ...................................................................... 18 (14) Symmetry Managed Portfolio Program (“Symmetry Program”) ...................................................................... 18 (15) Vanguard Investment Management Program (“Vanguard Program”) ............................................................. 19 (16) Voya Investment Management Program (“Voya Program”) ............................................................................ 19 (17) Wilshire Program .............................................................................................................................................. 20 Passageway Focus Program .............................................................................................................................. 20 C. INVESTMENT ADVISORY FEE INFORMATION .............................................................................................................. 20 1) FIWA, NFS, and Portfolio Manager Fees ..................................................................................................... 21 NFS Minimum Account Fees ............................................................................................................................. 23 2) Passageway Program Standard Fee Schedule: ........................................................................................... 23 3) Tax Overlay Service Fee Schedule: .............................................................................................................. 24 D. CLIENT HOUSEHOLDING INVESTMENT ADVISORY FEES ............................................................................................... 24 1) Householding Advisory Fees Criteria ........................................................................................................... 24 2) How to Opt Out of Householding ................................................................................................................ 25 3) Termination of Householding by FTS .......................................................................................................... 25 4) Ineligible Accounts for Householding Advisory Fees ................................................................................... 25 E. IAR COMPENSATION ............................................................................................................................................ 26 1) Compensation Conflicts of Interest ............................................................................................................. 26 Bonuses & Performance Based Compensation ................................................................................................. 26 Recruitment Compensation .............................................................................................................................. 26 (1) Forgivable Draw Compensation .......................................................................................................................... 27 (2) Upfront Forgivable Loan or Promissory Note ...................................................................................................... 27 (3) Sign-On Bonus ..................................................................................................................................................... 27 (4) Minimum Guaranteed Payout Percentage .......................................................................................................... 27 (5) Back-End Asset Based Bonus ............................................................................................................................... 28 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 4 of 61  c) d) Retention Compensation .................................................................................................................................. 28 Retirement Compensation ................................................................................................................................ 28 2) IAR Forfeiture of Compensation .................................................................................................................. 29 F. MUTUAL FUND AND ETP FEES ............................................................................................................................... 30 G. ADDITIONAL COSTS CHARGED BY CUSTODIAN .......................................................................................................... 30 H. MISCELLANEOUS FEES .......................................................................................................................................... 30 I. TRADE ERRORS ..................................................................................................................................................... 31 J. BEST EXECUTION .................................................................................................................................................. 31 K. TRADE ALLOCATIONS AND BLOCK TRADING .............................................................................................................. 31 L. NON-MANAGED ASSETS AND WORTHLESS SECURITIES ............................................................................................... 32 M. UNSUPERVISED ASSETS ....................................................................................................................................... 32 N. HOLDING A CLIENT’S ORDER OR INSTRUCTION ......................................................................................................... 33 ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ......................................................... 33 A. MINIMUM ACCOUNT REQUIREMENT ...................................................................................................................... 33 B. CHANGES TO A CLIENT’S FINANCIAL SITUATION ........................................................................................................ 34 C. TYPES OF CLIENTS ................................................................................................................................................ 34 ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION ..................................................... 34 A. SELECTION AND REVIEW OF PORTFOLIO MANAGERS ................................................................................................. 34 B. RELATED ENTITIES AS PORTFOLIO MANAGER ............................................................................................................ 35 C. FTS’ IARS AS PORTFOLIO MANAGERS IN ADVISOR DIRECTED AND PASSAGEWAY ONE PROGRAMS.................................... 35 1) Advisory Business ........................................................................................................................................ 35 2) Methods of Analysis, Investment Strategies, and Risk of Loss ................................................................... 35 Risk of Asset Value Loss ..................................................................................................................................... 36 a) Interest Rate Risk .............................................................................................................................................. 36 b) Credit Risk .......................................................................................................................................................... 37 c) Cybersecurity Risk ............................................................................................................................................. 37 d) Artificial Intelligence (“AI”) Risk ........................................................................................................................ 37 e) Derivatives Risk ................................................................................................................................................. 37 f) Direct Indexing Risk ........................................................................................................................................... 38 g) Investments in a Passageway Account .............................................................................................................. 38 h) ETFs ................................................................................................................................................................... 38 i) Exchange Traded Notes (“ETNs”) ...................................................................................................................... 39 j) ESG, SRI, Faith Based, and Similar Investments and Investment Strategies ..................................................... 39 k) Foreign Exposure ............................................................................................................................................... 39 l) m) Legislative and Regulatory Risk ......................................................................................................................... 40 n) Money Market Fund .......................................................................................................................................... 40 o) Municipal Bonds ................................................................................................................................................ 40 Stock Markets and Investments ........................................................................................................................ 40 p) Tracking Error .................................................................................................................................................... 41 q) Additional Risks ................................................................................................................................................. 41 r) 3) Performance Based Fees ............................................................................................................................. 41 4) Voting Client Securities ............................................................................................................................... 41 D. CLASS ACTIONS AND OTHER LEGAL PROCEEDINGS .................................................................................................... 41 ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ..................................... 42 ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS ............................................................... 42 ITEM 9 – ADDITIONAL INFORMATION ...................................................................................................... 42 A. DISCIPLINARY INFORMATION ................................................................................................................................. 42 1) FINRA – 05/08/2018 ................................................................................................................................... 42 2) SEC – 07/18/2023 ....................................................................................................................................... 43 3) SEC – 09/29/2023 ....................................................................................................................................... 43 B. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ........................................................................................ 43 1) Fifth Third Securities - Broker-Dealer & Municipal Advisor......................................................................... 43 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 5 of 61  a) b) c) d) e) a) b) 2) Related Entities ........................................................................................................................................... 43 Fifth Third Bank, National Association (FTB) ..................................................................................................... 43 Fifth Third Insurance Agency, Inc. (FTIA) ........................................................................................................... 44 Franklin Street Advisors, Inc. (Franklin Street Advisors) ................................................................................... 44 Fifth Third Wealth Advisors, LLC (FTWA) ........................................................................................................... 44 Comerica Securities, Inc. (Comerica Securities) ................................................................................................ 44 C. ADDITIONAL CONFLICTS OF INTEREST ...................................................................................................................... 44 1) Conflicts Related to Active Trading and No Charge Investments: .............................................................. 44 2) Conflicts Related to IAR Compensation....................................................................................................... 45 3) Conflicts Related to IAR Production Standards ........................................................................................... 45 4) Conflict Related to Recommending Passageway Account vs. Compass Account ....................................... 45 5) Conflicts Related to Recommending Passageway Account vs. Brokerage Account ................................... 45 6) Conflicts Related to Mutual Fund Revenue Sharing .................................................................................... 45 7) Conflicts Related to Interest on Cash Holdings ........................................................................................... 46 8) Conflicts Related to Clearing Firm (NFS) ..................................................................................................... 46 No Cost Transactions ......................................................................................................................................... 46 NFS Credits & Discounts .................................................................................................................................... 47 9) Conflicts Related to Receipt of Educational, Marketing, & Other Financial Support .................................. 47 10) Conflicts Related to Receipt of Gifts and Business Entertainment:........................................................... 48 11) Conflicts Related to the AllianceBernstein Program ................................................................................. 48 12) Conflicts Related to the BlackRock Program ............................................................................................. 48 13) Conflicts Related to the Brinker Capital Program ..................................................................................... 49 14) Conflicts Related to the Capital Group Program ....................................................................................... 49 15) Conflicts Related to the John Hancock Program ....................................................................................... 49 16) Conflicts Related to the Russell Program .................................................................................................. 49 17) Conflicts Related to the Symmetry Program ............................................................................................. 49 18) Conflicts Related to the Vanguard Program ............................................................................................. 50 19) Conflicts Related to the Voya Program ..................................................................................................... 50 20) Conflicts Related to the Tax Overlay Service ............................................................................................. 50 D. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING .................................. 50 1) Code of Ethics ........................................................................................................................................... 50 E. REVIEW OF ACCOUNTS ......................................................................................................................................... 51 F. QUARTERLY PERFORMANCE REPORTS...................................................................................................................... 51 G. CLIENT REFERRALS AND OTHER COMPENSATION ...................................................................................................... 52 1) FTS Education Summit ................................................................................................................................ 52 2) FTB President’s Circle .................................................................................................................................. 52 3) Area and Regional Meetings ....................................................................................................................... 53 H. FINANCIAL INFORMATION ..................................................................................................................................... 53 1) Balance Sheet .............................................................................................................................................. 53 2) Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients 53 3) Bankruptcy Petitions in Previous Ten Years .............................................................................................. 53 EXHIBIT A .......................................................................................................................................................... 54 INVESTMENT ADVISORY ACCOUNT FEE SCHEDULE ........................................................................... 61 Item 4 – Services, Fees, and Compensation A. About Fifth Third Securities Fifth Third Securities, Inc. (“FTS”, “we”, “our”, or “us”) is a registered broker-dealer member of Financial Industry Regulatory Authority (“FINRA”) and SIPC (www.SIPC.org), and a registered investment adviser with the U.S. Securities and Exchange Commission (registration does not imply a certain level of skill or training). 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 6 of 61  FTS is a direct wholly-owned subsidiary of Fifth Third Bank, National Association (“FTB”). FTB is a full-service bank (see Item 9.B. Other Financial Industry Activities and Affiliations for more information). Brokerage and investment advisory services and fees differ, and it is important for clients to understand the differences between these two types of services. IMPORTANT – Read before you open a Passageway Account – The FTS’ Customer Relationship Summary (Form CRS) provides important information about both brokerage and investment advisory services, and clients should review Form CRS prior to making any decision to engage FTS for either brokerage or investment advisory services. The current version of FTS’ Form CRS can be requested from your Investment Advisor Representative (“IAR”) or found by going to the website 53.com/ftsdisclosure. B. Passageway Investment Management Programs FTS is the sponsor of the Passageway Managed Account Program (“Passageway”), a program that provides various investment management services to clients. Passageway is accessed through the Fidelity Managed Account Xchange (“FMAX”) platform, of which Fidelity Institutional Wealth Adviser LLC (“FIWA”) is the platform sponsor. Additional services included in Passageway: brokerage and custodial services for Passageway accounts, performance reporting, and assistance with investment style selection and asset allocation strategies. Passageway is not intended for investors who want to frequently switch investments from one style or strategy to another in reaction to short-term trends. FTS makes various portfolio managers available in Passageway (each a “Portfolio Manager” and collectively, “Portfolio Managers”). An IAR of FTS will meet with a prospective client to discuss and complete an investor profile. During this discussion, the IAR gathers information regarding the client’s risk tolerance, investment objectives, and other financial information. With this data, the IAR assists the client in determining whether Passageway is appropriate for them and recommends one or more Passageway programs to the client. A client choosing to open a Passageway account will sign an Investment Management Agreement and a Statement of Investment Selection (Passageway accounts opened prior to February 2007 would have signed an Investment Policy Statement in lieu of the Statement of Investment Selection) with FTS, as well as an agreement to open an account with National Financial Services LLC (“NFS”). An advisory relationship exists between the client and FTS once the Investment Management Agreement and Statement of Investment Selection have been reviewed and accepted by FTS’ Principal Review Desk. If FTS’ Principal Review Desk does not accept the Investment Management Agreement or the Statement of Investment Selection, there is no advisory relationship between FTS and the client. NFS is FTS’ clearing brokerage and custodial services provider, to custody client assets invested by the client in Passageway. NFS is a registered broker/dealer and is not an affiliated entity of FTS. Most or all security transactions for Passageway accounts are executed through NFS as the clearing broker/dealer. However, Portfolio Managers sometimes trades with other broker/dealers to achieve best execution, obtain a wider variety of securities, or take advantage of favorable mark-ups or mark-downs available elsewhere. FTS can at any time change the clearing broker and custodian for the client’s account. The discretion given by you includes the discretion to select broker-dealers for the execution of transactions to achieve best execution. FTS and Portfolio Managers have no authority or duty to manage any of the client’s assets that are: (1) not within Passageway or another investment advisory program offered by FTS (i.e., Compass Managed Account Program and the Summit Managed Account Program), or (2) are designated as Unsupervised Assets within FTS investment advisory accounts (see Item 4.M. Unsupervised Assets for more information). Participating in any of the Passageway programs entails risk. For more information about some of these risks please see Item 6.C. 2) Methods of Analysis, Investment Strategies and Risk of Loss and the Portfolio Managers’ Form ADV Part 2A, if applicable. 1) Fiduciary Duties Under federal law, a registered investment adviser, such as FTS, is a fiduciary to its investment advisory 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 7 of 61  clients (a/k/a Passageway clients). FTS’ fiduciary duty includes, but is not limited to, a duty of care and a duty of loyalty. The duty of loyalty requires FTS, and our IARs, not to place our own interest ahead of our Passageway clients’ interests. FTS is to make appropriate disclosures to our Passageway clients, which is done through several documents, such as this Brochure. These disclosures help provide material information relating to the investment advisory relationship and FTS. The duty of care requires, among other things, the duty of FTS to provide advice that is in the best interest of our Passageway clients, a duty to monitor the client’s managed investments in Passageway accounts, and the ongoing suitability of those investments, over the course of the investment advisory relationship. As part of FTS’ duty of care, it our responsibility to understand the client’s objectives for the investments which we manage under Passageway, the client’s risk tolerance (e.g., how much risk and losses you are willing to take for the potential of gains in your Passageway account), and other financial profile information (e.g., annual income, estimated net worth, liquid assets, federal tax bracket, etc.). This information is needed to have a reasonable belief that the advice we provide is in the best interest of the Passageway client. Critically Important Client Responsibility: You need to promptly notify the FTS’ IAR that you work with in writing of changes to your risk tolerance, investment objectives, or financial circumstances that differ from the financial profile information that you previously provided to FTS, so that your Passageway account can be reevaluated for potential changes. Additionally, when FTS provides investment advice to clients of Passageway regarding their retirement plan account or individual retirement account, FTS is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way FTS makes money creates conflicts with your interests, so FTS operates under a rule that requires us to act in the client’s best interest and not put our interest ahead of our clients. 2) Reasonable Investment Restrictions Clients have the opportunity to place reasonable investment restrictions on the types of investments that will be managed on the client's behalf within Passageway accounts. The client must provide these investment restriction requests to FTS in writing. If FTS, Fidelity Institutional Wealth Adviser, LLC (“FIWA”), or a Portfolio Manager deems the restriction request unreasonable, FTS will notify the client of the rejection of the restriction request in writing. Clients can request two types of restrictions on their Passageway account: 1) individual security restrictions, and 2) industry restrictions. Clients may not impose restrictions which apply to underlying securities held in any mutual fund, ETF, ETN, or other pooled investment products. Individual security restrictions only apply to that specific security that is identified by a symbol or CUSIP, and the restriction will not apply to other securities that hold that individual security, such as mutual funds and exchange traded funds (“ETF”s). For example, if a client has an accepted restriction request for Microsoft stock (symbol ‘MSFT’), the client’s Passageway account will not purchase shares of Microsoft stock. However, a mutual fund held in the client’s Passageway account can be invested in Microsoft, and therefore, the client has an indirect investment still in Microsoft. Industry restrictions apply to general sectors of industry. Some examples of industry restrictions include, but are not limited to, Resorts & Casinos, Tobacco, Wineries & Distilleries, and Auto Manufacturers. Clients do not have the ability to determine what securities are included or excluded within an industry restriction, nor can clients determine the criteria that are used to include or exclude a security within an industry restriction. If a client requests an industry restriction in a Passageway account, the client accepts the FTS’, FIWA’s, or the Portfolio Manager’s determination of what securities are included and excluded from the industry restriction. 3) Limitation of Products and Types of Products FTS offers a wide range of investment products, advisory services, and other services to help meet your financial needs. However, we do not offer the same investment products, Portfolio Managers, or product types that are available through other broker-dealers or registered investment advisors. This limitation is due 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 8 of 61  to various reasons that include, but are not limited to, the product company or Portfolio Manager has not passed our due diligence process, we do not have a contract with the product company or Portfolio Manager, the Portfolio Manager is not available through FIWA, or the product, product type, or Portfolio Manager, or the product company is outside of our current business model or the amount of risk associated with the company or product is too great. 4) Dollar Cost Averaging FTS’ IARs can use dollar-cost averaging when making purchases of securities in Passageway accounts except for accounts in the Advisor Directed Program. Dollar-cost averaging is the investment strategy of regularly or periodically making purchases of a security or securities over a time period instead of making the purchases at a single point in time. Dollar-cost averaging attempts to help address the volatility risk that sometimes occurs in the markets or with a single security. An example of dollar-cost averaging is when investing $15,000 into one security and instead of purchasing it all at once, the IAR or Portfolio Manager makes a purchase of $5,000 of the same security once a month for three months. FTS limits the timeframe in which dollar-cost averaging can be used to a maximum of approximately 90 calendar days. If the 90th day falls on a weekend or a market holiday, the period may extend to the next business day when the securities markets are open. This 90 day period does not apply to securities and investments that have been approved as Unsupervised Assets (see Item 4.M. Unsupervised Assets for more information). Dollar-cost averaging does not prevent losses, and the use of dollar-cost averaging can result in paying more for a security or securities than if the security or securities were purchased all at one time. 5) Terminating Passageway Services Either FTS or the client can terminate participation in Passageway at any time by providing thirty (30) days prior written notice to the other party. The client will be charged a pro-rated investment advisory fee for the portion of any billing period during which the account is open (see Item 4.C. Investment Advisory Fee Information for further details) unless the client terminates the Investment Management Agreement within (5) business days from the client signing the Investment Management Agreement. If a client terminates the Investment Management Agreement within five (5) business days from the client signing the Investment Management Agreement, then the client is not charged with an investment advisory fee. FTS reserves the right to distribute the assets of a client’s account in-kind (a delivery or transfer of securities held in the Passageway account instead of in cash), liquidate any and all assets in the Passageway account, send to the address of record any security in certificate form, and/or send to the address of record any available cash balance upon termination of the account by either party unless the Passageway client provides alternative instructions. FTS will generally evaluate a Passageway account for termination if there has been no IAR- initiated transactional activity (e.g., buys or reallocations) for a period greater than 18 months (withdrawals from the Passageway account are excluded). If after the completion of the review FTS determines that it is appropriate to terminate the Passageway account, FTS will terminate the Investment Management Agreement by providing thirty (30) days prior written notice to the client. Upon notification that an account owner has died, the Investment Management Agreement is immediately terminated, and the client’s account is no longer a Passageway account. Any subsequent trades placed based upon instructions from the executor, heirs, or beneficiaries are subject to standard fees and commissions of a brokerage account. See the Standard Commission and Fee Schedule at 53.com/ftsdisclosure for more information. 6) Fidelity Institutional Wealth Adviser, LLC (“FIWA”) FIWA oversees the technology platform on which Passageway functions for Passageway Accounts. FTS has access to tools and related services as well as research and additional information about investment products offered through the FMAX platform, which assists FTS’ IARs in building personalized solutions for FTS’ clients. For more information about the FMAX platform and the research and risk ratings of investment products on FMAX, as well as other investment tools and related services, please see the current FIWA’s ADV Part 2A Brochure describing FMAX. Additionally, FIWA provides due diligence services to FTS for the majority or all of the Portfolio Managers in the SMA Program, and the majority or all of the mutual funds and ETFs, and ETNs 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 9 of 61  available through the Advisor Directed Program and the Passageway One Program. 7) Tax Overlay Service Clients can elect to utilize the Tax Overlay Service for non-qualified accounts (e.g., non-retirement accounts) in the following Passageway Programs: • AllianceBernstein Program • Aspire Program • BlackRock Program • Brinker Capital Program • Cantor Fitzgerald Program • Capital Group Program • FEG Program • Frontier Program • Goldman Sachs Mutual Fund Program • Goldman Sachs ETF Program • John Hancock Program • Passageway One Program • Richard Bernstein Program • Russell Program • Symmetry Program • Vanguard Program • Voya Program • Wilshire Program The Tax Overlay Service seeks to enhance the client’s after-tax returns by analyzing holdings and trading activities in an account. As the Portfolio Manager makes changes, Envestnet evaluates the tax cost of executing those changes, and can make different trades than the Portfolio Manager’s model. The evaluation process attempts to balance the tax cost of adhering to the Portfolio Manager’s model, versus the risk incurred by deviating from the Portfolio Manager’s model, with the objective of delivering better after-tax performance to participating clients. Clients should refer to FIWA’s ADV Part 2A and their Statement of Investment Selection for additional information regarding the Tax Overlay Service. FTS makes no guarantee that the use of the Tax Overlay Service will achieve the tax results the client wants. The Tax Overlay Service is completely optional to a Passageway client, and a client does not have to opt into receiving the Tax Overlay Service in order to have a Passageway Program account. Clients should seek the advice of their tax professional prior to electing to utilize the Tax Overlay Services for their Passageway One Program account. The Tax Overlay Service is an added service (if selected), and as a result, carries an additional fee that is assessed to FTS. As a result, the Tax Overlay Service fee decreases the total amount in fees that FTS and our IARs receive when a client chooses to use the Tax Overlay Service. Therefore, FTS and our IARs have a conflict of interest associated with the Tax Overlay Service, because there is a financial incentive not to provide the Tax Overlay Service. Please refer to Item 4.C.3) Tax Overlay Services Fee Schedule for more information on the fees associated with the Tax Overlay Service. 8) Passageway Programs Passageway consists of the below referenced separate programs. Clients, in consultation with an IAR and signing the corresponding Investment Management Agreement, elect to participate in one or more of the following programs. a) Passageway One Program The Passageway One Program provides the opportunity for clients to have multiple Portfolio Managers and 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 10 of 61  different types of Portfolio Managers that manage assets under a single account. FTS requires that at least one Portfolio Manager who is not an IAR of FTS be selected in a Passageway One Program account. In the Passageway One Program, the client appoints FTS as the Portfolio Manager, and as the Portfolio Manager FTS has the discretionary authority to: i. Design, implement, and change the asset allocation used in conjunction with the Passageway One Program Account including making all investment decisions with respect to the client’s account(s) when FTS deems appropriate and without prior consultation with the client, to invest, reinvest, buy, sell, exchange, convert and otherwise trade in any security or investment. ii. Add and/or remove any Portfolio Manager(s) that are available under any of the Passageway Programs (with the exclusion of the Passageway Focus Program) to manage the assets or portion of the assets in the Passageway One Account. iii. FTS’ IARs can act as the Portfolio Manager and provide investment management services on the assets or a portion of the assets in the Passageway One Account utilizing mutual funds, ETFs, and/or exchange traded notes (ETFs and exchange traded notes collectively referred to herein as exchange traded products or “ETPs”). iv. Increase, decrease, or otherwise change the dollar amount or the assets managed by a Portfolio Manager in the Account, including when an IAR(s) is serving as a Portfolio Manager. The above discussed discretionary authority allows FTS through our IARs to act as the Portfolio Manager, and any other Portfolio Manager selected by FTS to take any and all of the above actions without prior consultation with the client. In addition, this discretionary authority allows FTS to invest a client’s accounts/assets in a lower risk tolerance up to one level than the client has selected. Please see below for a list of risk tolerances in the Passageway One Program, which are listed in order of the riskiest to the least risky. For example, if a client has selected the risk tolerance as Aggressive Growth, then when FTS deems it appropriate, FTS could move the client’s account/assets to reflect a Growth risk tolerance. However, in this example FTS would not be able to move the client’s account/assets to reflect a Moderate Growth or lower risk tolerance since they are more than one level below the client’s stated risk tolerance. Furthermore, this discretionary authority does not allow FTS to invest in a higher risk tolerance than what the client has selected. Risk Tolerances Aggressive Growth Growth Moderate Growth Moderate Conservative Growth Conservative Capital Preservation The Passageway One Program provides investment management services for various investment styles and objectives. Initial and ongoing due diligence on the assets within the Passageway One Program is conducted by the Portfolio Manager, FIWA, or FTS. Due diligence performed by Portfolio Managers, FIWA, and FTS differ from each other. The minimum account size for establishing an account in the Passageway One Program is $100,000; however, Portfolio Managers impose their own minimum amount to manage a client’s assets. Therefore, the minimum accounts size to use some Portfolio Managers in a Passageway One Account will be greater than $100,000. Clients can ask the FTS IAR for the minimum amount a specific Portfolio Manager requires to manage assets. FTS, at its discretion, can choose to terminate a client’s participation in a Passageway One 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 11 of 61  Program account if the account falls below $100,000. The FTS IAR will provide the Portfolio Manager’s Form ADV Part 2A for each Portfolio Manager that the FTS IAR selects. Clients should refer to the applicable Portfolio Manager’s Form ADV Part 2A for additional information and details about the Portfolio Manager. Additionally, the Passageway One operates under FIWA’s “Unified Managed Account Program” also known as the “UMA Program,” and the FTS IAR will provide FIWA’s ADV Part 2A that includes information about FIWA and the UMA Program. b) Advisor Directed Program In the Advisor Directed Program, FTS’ IARs provide investment management services to clients utilizing mutual funds and/or ETPs. Investment management services provided under the Advisor Directed Program are limited to open-end mutual funds and ETPs. The Advisor Directed Program provides investment management services for various investment styles and objectives. Initial and ongoing due diligence for the mutual funds and ETPs available within the Advisor Directed Program is conducted by FIWA or FTS. Due diligence performed by FIWA and FTS differ from each other. Clients grant FTS discretionary authority to manage Advisor Directed Program account assets. Such discretionary authority allows FTS to make all investment decisions with respect to the client’s Advisor Directed account(s) when FTS deems appropriate and without prior consultation with the client, to buy, sell, exchange, convert and otherwise trade in any mutual fund or ETP approved by FTS or FIWA. In addition, this discretionary authority allows FTS to invest a Passageway client’s accounts/assets in a lower risk tolerance up to one level than the client has selected. Please see below for a list of risk tolerances in the Advisor Directed Program, which are listed in order of the riskiest to the least risky. For example, if a client has selected the risk tolerance as Aggressive Growth, then when FTS deems it appropriate, FTS could move the client’s account/assets to reflect a Growth risk tolerance. However, in this example FTS would not be able to move the client’s account/assets to reflect a Moderate Growth or lower risk tolerance since any risk tolerance of Moderate or lower is more than one level below the client’s stated risk tolerance. Furthermore, this limited discretionary authority does not allow FTS to invest in a higher risk tolerance than the client has selected. Risk Tolerances Aggressive Growth Growth Moderate Growth Moderate Conservative Growth Conservative Capital Preservation The minimum account size for establishing an account in the Advisor Directed Program is $50,000. FTS, at its discretion, can choose to terminate a client’s participation in an Advisor Directed Program account if the account falls below $50,000. c) Separately Managed Account Program (“SMA Program”) In the SMA Program, the client grants FTS and FIWA discretionary authority to manage the assets in client’s SMA Program account(s) and to delegate such authority to selected Portfolio Manager(s). Such discretionary authority allows FTS’ delegate, the Portfolio Manager(s), to make investment decisions with respect to the account(s) when the Portfolio Manager(s) deems appropriate and without prior consultation with the client to invest, reinvest, sell, exchange, and otherwise trade in any stocks, bonds, and other securities, subject to any reasonable investment restrictions made by the client. Clients can select one Portfolio Manager or multiple Portfolio Managers, provided the client has sufficient assets for multiple Portfolio Managers. FTS’ IARs will assist clients in selecting Portfolio Managers on an account-by-account basis. Portfolio Managers that are available within the SMA Program provide investment management services for various investment 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 12 of 61  styles and objectives. For a complete list of Portfolio Managers available within the SMA Program, please contact an IAR of FTS. In the SMA Program, the client chooses the Portfolio Manager(s). FTS will not fire a Portfolio Manager on behalf of a client without the client’s approval with the exception when a Portfolio Manager has been removed from the SMA Program. FTS and FIWA retain the right to terminate a Portfolio Manager's participation in Passageway. When a Portfolio Manager is removed from the SMA Program, clients utilizing this Portfolio Manager are notified by their IAR of this event. The IAR will work with clients to identify another Portfolio Manager or Passageway program that corresponds with their investment objectives and risk tolerance. Some SMA Portfolio Manager’s use Index-Based Investing, also known as “Direct Indexing,” which is where the Portfolio Manager within the SMA Program uses an investment strategy buying individual stocks that make up a specific market index (such as S&P 500® Index). Due to the complexity and ever changing weighting of companies that make up a market index, clients will not be invested in a mirror image of the market index when a Portfolio Manager uses Direct Indexing, and Direct Indexing will have an imperfect correlation between the individual stocks purchased and the weighting of the market index. Refer to Item 6.C.2) - Methods of Analysis, Investment Strategies, and Risk of Loss in this Brochure for more information about Direct Indexing Risks and Tracking Error. FTS IAR will distribute the Portfolio Manager’s Form ADV Part 2A for each Portfolio Manager that the FTS IAR recommends. Clients should refer to the applicable Portfolio Manager’s Form ADV Part 2A for additional information and details about the Portfolio Manager. The minimum account size per Portfolio Manager account in the SMA Program is $100,000 or more, based on the specific Portfolio Manager chosen by the client. FTS, at its discretion, can choose to terminate a client’s participation in an SMA Program account if the account falls below the account opening minimum. d) Fund Strategist Portfolio Through FIWA’s Fund Strategist Portfolio (also referred to as the Fund Strategist Portfolio Program), FIWA provides FTS with access to a range of Portfolio Managers that support FIWA in the management of models with clients. FTS and our IARs are responsible for working with clients to help determine whether to recommend a Portfolio Manager, as well as the corresponding asset allocation, model, and/or investment strategy(ies) based upon the client’s financial information. Below is the current list of Portfolio Managers FTS makes available through the Fund Strategist Portfolio: (1) AllianceBernstein Dynamic Multi-Asset Program (“AllianceBernstein Program”) In the AllianceBernstein Program, the client grants FIWA the discretionary authority to manage assets. FIWA has retained AllianceBernstein, L.P. (“AllianceBernstein”) to assist with the recommendation of investments and models. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different mutual funds and/or exchange-traded funds. The AllianceBernstein Program provides investment management services for various investment styles and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients should refer to AllianceBernstein’s Form ADV Part 2A and FIWA’s Form ADV Part 2A for additional information and details about AllianceBernstein, and FIWA. Additionally, the AllianceBernstein Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the AllianceBernstein Program is $50,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in an AllianceBernstein account if the account falls below $50,000. Clients should note that AllianceBernstein is also an asset manager available under the Passageway SMA Program. Clients can determine if they are in the SMA Program or the AllianceBernstein Program by 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 13 of 61  speaking with their IAR or by reviewing the Statement of Investment Selection that was signed at the opening of the Passageway account. For the AllianceBernstein Program, the Statement of Investment Selection will have a reference to “Multi-Asset” under the Investment Type field (e.g., AB Dynamic Multi-Asset Income 40/60 Strategy). Whereas, the Passageway SMA Program will generally have the reference of “Separate Account” in the name of the Investment Type (e.g., AB US Large Cap Growth Managed Account Separate Account). (2) Aspire Strategist Portfolios Program (“Aspire Program”) In the Aspire Program, the client grants FIWA the discretionary authority to manage assets. FIWA has retained Aspire Strategist Portfolios, LLC (“Aspire”) to assist with the recommendation of models made up of assets, such as ETFs and the allocation of those assets. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different mutual funds. The Aspire Program provides investment management services for various investment styles and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients should refer to Aspire’s Form ADV Part 2A, and FIWA’s Form ADV Part 2A for additional information and details about FIWA and Aspire. Additionally, the Aspire Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the Aspire Program is $50,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in an Aspire account if the account falls below $50,000. (3) BlackRock Program (“BlackRock Program”) In the BlackRock Program, the client grants FIWA the discretionary authority to manage assets. FIWA has retained BlackRock Investment Management, LLC. (“BlackRock”) to assist with the recommendation of investments and models. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different mutual funds and/or exchange-traded funds. The BlackRock Program provides investment management services for various investment styles, strategies, and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients should refer to BlackRock’s Form ADV Part 2A and FIWA’s Form ADV Part 2A for additional information and details about BlackRock, and FIWA. Additionally, the BlackRock Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the BlackRock Program is $50,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in a BlackRock account if the account falls below $50,000. (4) Brinker Capital Management Program (“Brinker Capital Program”) In the Brinker Capital Program, the client grants FIWA the discretionary authority to manage assets. FIWA has retained Orion Portfolio Solutions, LLC dba Brinker Capital Investments (“Brinker Capital”) to assist with the recommendation of investments and models. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different mutual funds and/or exchange-traded funds. The Brinker Program provides investment management services for various investment styles and objectives, and clients should refer to the Statement of Investment selection for details 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 14 of 61  regarding the specific options chosen. Clients should refer to Brinker Capital’s Form ADV Part 2A, and FIWA Form ADV Part 2A for additional information and details about Brinker Capital, and FIWA. Additionally, the Brinker Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the Brinker Capital Program is $50,000. FTS or FIWA at its discretion, can choose to terminate a client’s participation in a Brinker Capital account if the account falls below $50,000. (5) Capital Global Model Portfolios Program (“Capital Group Program”) In the Capital Group Program, the client grants FIWA the discretionary authority to manage assets. FIWA has retained Capital Research and Management Company (“Capital Group”) to assist with the recommendation of investments and models. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different mutual funds and/or exchange-traded funds. The Capital Group Program provides investment management services for various investment styles and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients should refer to Capital Group’s Form ADV Part 2A and FIWA’s Form ADV Part 2A for additional information and details about Capital Group, and FIWA. Additionally, the Capital Group Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the Capital Group Program is $50,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in a Capital Group account if the account falls below $50,000. (6) Cantor Fitzgerald Managed Sponsored Program (“Cantor Fitzgerald Program”) In the Cantor Fitzgerald Program, the client grants FIWA the discretionary authority to manage assets. FIWA has retained Cantor Fitzgerald Investment Advisors, L.P. (“Cantor Fitzgerald”) to assist with the recommendation of models made up of assets, such as ETFs, and the allocation of those assets. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different assets. The Cantor Fitzgerald Program provides investment management services for various investment styles and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients should refer to Cantor Fitzgerald’s Form ADV Part 2A, and FIWA’s Form ADV Part 2A for additional information and details about FIWA and Cantor Fitzgerald. Additionally, the Cantor Fitzgerald Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the Cantor Fitzgerald Program is $50,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in a Cantor Fitzgerald account if the account falls below $50,000. (7) Frontier Asset Model Provider Investment Strategies Program (“Frontier Program”) In the Frontier Program, the client grants FIWA the discretionary authority to manage assets. FIWA has retained Frontier Asset Management, LLC (“Frontier”) to assist with the recommendation of models made up of assets, such as ETFs and the allocation of those assets. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different mutual funds. 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 15 of 61  The Frontier Program provides investment management services for various investment styles and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients should refer to Frontier’s Form ADV Part 2A, and FIWA’s Form ADV Part 2A for additional information and details about FIWA and Frontier. Additionally, the Frontier Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the Frontier Program is $50,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in a Frontier account if the account falls below $50,000. (8) Fund Evaluation Group Managed Program (“FEG Program”) In the FEG Program, the client grants FIWA the discretionary authority to manage assets. FIWA has retained Fund Evaluation Group, LLC (“FEG”) to assist with the recommendation of models made up of mutual funds and/or ETFs and the asset allocation of those assets. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different mutual funds and/or exchange-traded funds. The FEG Program provides investment management services for various investment styles and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients should refer to FEG’s Form ADV Part 2A, and FIWA’s Form ADV Part 2A for additional information and details about FIWA and FEG. Additionally, the FEG Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the FEG Program is $50,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in an FEG account if the account falls below $50,000. (9) Goldman Sachs Multi-Manager Mutual Fund Portfolio Program (“Goldman Sachs Mutual Fund Program”) – formerly known as the Standard and Poor’s Managed Mutual Fund Portfolio Program In the Goldman Sachs Mutual Fund Program, the client grants FIWA the discretionary authority to manage assets. Such discretionary authority allows FIWA to make investment decisions with respect to the account(s) when FIWA deems appropriate and without prior consultation with the client, to invest, reinvest, sell, exchange, convert and otherwise trade in any mutual fund subject to any reasonable investment restrictions made by the client. FIWA has retained Goldman Sachs Asset Management, L.P. (“Goldman Sachs”) to assist with the recommendation of models made up of mutual funds and the asset allocation of those mutual funds. The Goldman Sachs Mutual Funds Program provides investment management services for various investment styles and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients should refer to Goldman Sachs’ Form ADV Part 2A, and FIWA’s ADV Part 2A for additional information and details about FIWA and Goldman Sachs. Additionally, the Goldman Sachs Mutual Fund Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the Goldman Sachs Mutual Fund Program is $50,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in a Goldman Sachs Mutual Fund account if the account falls below $50,000. Clients should note that Goldman Sachs is also an asset manager available under the Passageway SMA Program and provides recommendations to FIWA in the Goldman Sachs ETF Program (listed below). Clients can determine if they are in the SMA Program, the Goldman Sachs ETF Program, or the Goldman Sachs 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 16 of 61  Mutual Fund Program by speaking with their IAR or by reviewing the Statement of Investment Selection that was signed at the opening of the Passageway account. For the Goldman Sachs Mutual Fund Program, the Statement of Investment Selection will have a reference to “Mutual Fund” under the Investment Type field (e.g., Goldman Sachs Multi-Manager 50/50 Mutual Fund Model Portfolio Fund Strategist Portfolio). The Goldman Sachs ETF Program, the Statement of Investment Selection will have a reference to “ETF” under the Investment Type field (e.g., Goldman Sachs Multi-Manager 50/50 ETF Model Portfolio Fund Strategist Portfolio). Whereas, the Passageway SMA Program will generally have the reference of “Separate Account” in the name of the Investment Type (e.g., Goldman Sachs S&P 4 Managed Account Separate Account). (10) Goldman Sachs Multi-Manager Exchange Trade Funds Portfolio Program (“Goldman Sachs ETF Program”) – formerly known as the Standard and Poor’s Exchange Trade Funds Portfolio Program In the Goldman Sachs ETF Program, the client grants FIWA the discretionary authority to manage assets. Such discretionary authority allows FIWA to make investment decisions with respect to the account(s) when FIWA deems appropriate and without prior consultation with the client, to invest, reinvest, sell, exchange, and otherwise trade in any ETF subject to any reasonable investment restrictions made by the client. FIWA has retained Goldman Sachs Asset Management, L.P. to assist with the recommendation of models consisting of exchange-traded funds and the asset allocation of those exchange-traded funds. The Goldman Sachs ETF Program provides investment management services for various investment styles and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients should refer to Goldman Sachs’ Form ADV Part 2A, and FIWA’s ADV Part 2A for additional information and details about FIWA and Goldman Sachs. Additionally, the Goldman Sachs ETF Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the Goldman Sachs ETF Program is $50,000. FTS or FIWA, at their discretion, can choose to terminate a client’s participation in a Goldman Sachs ETF account if the account falls below $50,000. Clients should note that Goldman Sachs is also an asset manager available under the Passageway SMA Program and provides recommendations to FIWA in the Goldman Sachs Mutual Fund Program (listed above). Clients can determine if they are in the SMA Program, the Goldman Sachs ETF Program, or the Goldman Sachs Mutual Fund Program by speaking with their IAR or by reviewing the Statement of Investment Selection that was signed at the opening of the Passageway account. For the Goldman Sachs Mutual Fund Program, the Statement of Investment Selection will have a reference to “Mutual Fund” under the Investment Type field (e.g., Goldman Sachs Multi-Manager 50/50 Mutual Fund Model Portfolio Fund Strategist Portfolio). The Goldman Sachs ETF Program, the Statement of Investment Selection will have a reference to “ETF” under the Investment Type field (e.g., Goldman Sachs Multi-Manager 50/50 ETF Model Portfolio Fund Strategist Portfolio). Whereas, the Passageway SMA Program will generally have the reference of “Separate Account” in the name of the Investment Type (e.g., Goldman Sachs S&P 4 Managed Account Separate Account). (11) John Hancock Portfolios Program (“John Hancock Program”) In the John Hancock Program, the client grants FIWA the discretionary authority to manage assets. FIWA has retained Manulife Investment Management (US), LLC (“Manulife”) to assist with the recommendation of models made up of mutual funds and/or ETFs and the asset allocation of those assets. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different mutual funds and/or ETFs. It is expected that the investment recommendations will include mutual funds and/or ETFs made available, issued, distributed, advised, and/or sub-advised by Manulife or affiliated entity(ies) of Manulife. See Item 9.C. – Additional Conflicts of Interest of this Brochure and Manulife’s Form ADV Part 2A for additional information regarding these 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 17 of 61  conflicts of interest. The John Hancock Program provides investment management services for various investment styles and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients should refer to Manulife’s Form ADV Part 2A, and FIWA’s Form ADV Part 2A for additional information and details about FIWA and Manulife. Additionally, the John Hancock Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the John Hancock Program is $50,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in a John Hancock account if the account falls below $50,000. (12) Richard Bernstein Program In the Richard Bernstein Program, the client grants FIWA the discretionary authority to manage assets. FIWA has retained Richard Bernstein Advisors, LLC (“Richard Bernstein”) to assist with the recommendation of models made up of mutual funds and/or ETFs and the asset allocation of those assets. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different mutual funds and/or ETFs. The Richard Bernstein Program provides investment management services for various investment styles and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients should refer to Richard Bernstein’s Form ADV Part 2A, and FIWA’s Form ADV Part 2A for additional information and details about FIWA and Richard Bernstein. Additionally, Richard Bernstein Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the Richard Bernstein Program is $50,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in a Richard Bernstein account if the account falls below $50,000. (13) Russell Investment Management Program (“Russell Program”) In the Russell Program, the client grants FIWA the discretionary authority to manage assets. FIWA has retained Russell Investment Management, LLC (“Russell”) to assist with the recommendation of investments and models. It is expected that the investment recommendations will solely be made up of mutual funds made available, issued, distributed, advised, and/or sub-advised by Russell and/or an affiliated entity(ies) of Russell. See Item 9.C. – Additional Conflicts of Interest in this Brochure for additional information regarding this conflict of interest. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different mutual funds. The Russell Program provides investment management services for various investment styles, strategies, and objectives, and clients should refer to the Statement of Investment selection for additional details as to what has been selected. Clients should refer to Russell’s Form ADV Part 2A, FIWA’s Form ADV Part 2A for additional information and details about FIWA and Russell. Additionally, the Russell Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the Russell Program is $50,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in a Russell account if the account falls below $50,000. (14) Symmetry Managed Portfolio Program (“Symmetry Program”) 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 18 of 61  In the Symmetry Program, the client grants FIWA the discretionary authority to manage the assets in client’s Symmetry Program account. FIWA has retained Symmetry Partners, LLC (“Symmetry”) to assist with the recommendation of investments and models. Such discretionary authority allows FIWA to make investment decisions with respect to the account(s) when Symmetry deems appropriate and without prior consultation with the client, to invest, reinvest, sell, exchange, and otherwise trade in any mutual fund or ETF subject to any reasonable investment restrictions made by the client. It is expected that the investment recommendations will include mutual funds and/or ETFs made available, issued, distributed, advised, and/or sub-advised by Symmetry or affiliated entity(ies) of Symmetry. See Item 9.C. – Additional Conflicts of Interest of this Brochure and Symmetry’s Form ADV Part 2A for additional information regarding these conflicts of interest. The Symmetry Program provides investment management services for various investment styles, strategies, and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients should refer to the applicable Symmetry’s Form ADV Part 2A for additional information and details about Symmetry. Additionally, the Symmetry Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the Symmetry Program is $50,000. FTS or Symmetry, at its discretion, can choose to terminate a client’s participation in a Symmetry Program account if the account falls below $50,000. (15) Vanguard Investment Management Program (“Vanguard Program”) In the Vanguard Program, the client grants FIWA the discretionary authority to manage assets. FIWA has retained The Vanguard Group Inc. (“Vanguard”) to assist with the recommendation of investments and models. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different mutual funds and/or exchange traded funds. It is expected that the investment recommendations will solely or primarily be made up of mutual funds and/or ETFs made available issued, distributed, advised, and/or sub-advised by Vanguard or affiliated entity(ies) of Vanguard. See Item 9.C. – Additional Conflicts of Interest of this Brochure and Vanguard’s Form ADV Part 2A for additional information regarding these conflicts of interest. The Vanguard Program provides investment management services for various investment styles and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients should refer to Vanguard’s Form ADV Part 2A, FIWA’s Form ADV Part 2A for additional information and details about FIWA and Vanguard. Additionally, the Vanguard Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the Vanguard Program is $50,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in a Vanguard account if the account falls below $50,000. (16) Voya Investment Management Program (“Voya Program”) In the Voya Program, the client grants FIWA the discretionary authority to manage assets. FIWA has retained Voya Investment Management Co., LLC (“Voya”) to assist with the recommendation of models made up of mutual funds and/or ETFs and the asset allocation of those assets. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different mutual funds and/or ETFs. It is expected that the investment recommendations will include mutual funds and/or ETFs made available, issued, distributed, advised, and/or sub-advised by Voya or affiliated entity(ies) of Voya. See Item 9.C. – Additional Conflicts of Interest of this Brochure and Voya’s Form ADV Part 2A for additional 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 19 of 61  information regarding these conflicts of interest. The Voya Program provides investment management services for various investment styles and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients should refer to Voya’s Form ADV Part 2A, and FIWA’s Form ADV Part 2A for additional information and details about FIWA and Voya. Additionally, the Voya Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the Voya Program is $50,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in a Voya account if the account falls below $50,000. (17) Wilshire Program In the Wilshire Program, the client grants FIWA the discretionary authority to manage assets. FIWA has retained Wilshire Associates, Inc. (“Wilshire”) to assist with the recommendation of models made up of mutual funds and the asset allocation of those assets. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different mutual funds. The Wilshire Program provides investment management services for various investment styles and objectives, and clients should refer to the Statement of Investment selection for details regarding the specific options chosen. Clients investing in the Wilshire Diversified Alternatives Portfolio should be aware that Wilshire uses mutual funds that use investment strategies that differ from the buy-and-hold strategy typical in the mutual fund industry, and these mutual funds typically hold more non-traditional investments and employ more complex trading strategies. Please refer to Item 6.C.2) Methods of Analysis, Investment Strategies and Risk of Loss for more information regarding the potential risks of portfolios using alternative mutual funds. Clients investing in the Wilshire Diversified Alternatives Portfolio should also review the prospectuses of the mutual funds making up this portfolio strategy. Clients should refer to Wilshire’s Form ADV Part 2A, and FIWA’s ADV Part 2A for additional information and details about FIWA and Wilshire. Additionally, the Wilshire Program falls under FIWA’s “Fund Strategist Portfolio Program” also referred to as the “FSP Program,” and clients can find additional information about FIWA’s FSP Program in FIWA’s ADV Part 2A. The minimum account size for establishing an account in the Wilshire Program is $50,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in a Wilshire account if the account falls below $50,000. e) Passageway Focus Program In the Passageway Focus Program, the client grants FIWA the discretionary authority to manage assets. This discretionary authority allows FIWA to invest, reinvest, sell, exchange, and otherwise manage the client’s assets in the Passageway account at FIWA’s discretion, including but not limited to, when FIWA deems appropriate and without prior consultation with the client, to select, allocate, reallocate, and sell the assets in the client’s account to different mutual funds and/or exchange-traded funds. The Passageway Focus Program provides investment management services for various investment styles and objectives. Clients should refer to FIWA’s Form ADV Part 2A for additional information and details about FIWA. The minimum account size for establishing an account in the Passageway Focus Program is $10,000. FTS or FIWA, at its discretion, can choose to terminate a client’s participation in a Passageway Focus Program account if the account falls below $10,000. C. Investment Advisory Fee Information Investment advisory fees (referred to as the “Program Fee” in the Investment Management Agreement) are calculated at the beginning of each calendar quarter based upon the daily weighted average market value of the assets under management for the previous quarter. Investment advisory fees are automatically 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 20 of 61  deducted from the client’s Passageway account, and are charged quarterly in arrears, generally based on the Passageway Program Standard Fee Schedule (see further below). Investment advisory fees are negotiable between FTS and the Passageway client. As a result, Passageway clients that have similar account balances and/or allocations can pay different investment advisory fees. Clients should refer to their Investment Policy Statement or their Statement of Investment Selection to see the negotiated advisory fee schedule for their specific Passageway account(s). FTS includes cash and cash equivalents positions in the daily weighted average market value of the assets under management when FTS assesses investment advisory fees. As a result, clients should limit the amount of cash or cash equivalents held in their Passageway account. For the initial calendar quarter in which a Passageway account is opened, the initial advisory fee will be based upon the number of days the account is open in Passageway, and the daily weighted average market value of the assets under management. Likewise, upon the termination of a Passageway account, an advisory fee will be based upon the beginning date of the calendar quarter through the date of termination of the Passageway account and the daily weighted average market value of the assets under management. Clients should be aware that the investment management services provided under Passageway can be more or less expensive than if the services were purchased separately, provided through another advisory program offered by FTS, or purchased at another financial firm. A client could purchase services similar to those offered in Passageway from other financial services providers. When determining the cost of purchasing services separately or the cost of other investment advisory programs, clients should evaluate the costs of brokerage commissions charged, the volume of trading activity in the account, transaction fees, wire fees, trade-away fees, foreign security transfer fees, retirement account termination fees, custody charges, fees charged for investment management services, fees for performance reporting, and the internal costs of the assets purchased (e.g., mutual fund and ETP internal expenses). The maximum investment advisory fee for all Passageway Programs is 1.50%. 1) FIWA, NFS, and Portfolio Manager Fees FTS pays fees to FIWA for the platform and services FIWA renders under Passageway. FIWA fees are assessed at the account level but are not directly paid by clients. FTS pays NFS clearance and execution fees for trades placed in Passageway accounts. These clearance and execution fees are generally based upon the type of security involved in the transaction (e.g., listed equity, over-the-counter equities, municipal bonds, mutual funds, etc.). However, NFS makes transactions in certain mutual funds and ETPs available to FTS at no cost if the mutual fund or ETP is part of NFS’ NTF Mutual Funds Program, NTF Managed Account Program, and iNTF Managed Account Program. See “Conflicts Related to Clearing Firm (NFS)” under Item 9C. – Additional Conflicts of Interest in this Brochure for important information regarding the conflicts of interest related to these NFS fees and NFS’ NTF Mutual Funds Program, NTF Managed Account Program, and iNTF Managed Account Program. FTS pays management fees to the Portfolio Managers, excluding FTS’ IARs, for the advisory services they render under Passageway. These Portfolio Managers’ management fees vary and are based upon the market value of the assets of a client’s Passageway account. In addition, some of the Portfolio Managers that fall under the Fund Strategist Portfolios category receive compensation in the form of fees through the management of fund(s) as outlined in the respective mutual fund and ETP’s prospectuses. Critically Important Conflict of Interest: The management fees paid by FTS (directly or indirectly) to the Portfolio Manager, and fees paid to FIWA directly reduces the amount an IAR will receive in compensation. As a result, IARs have a financial incentive to recommend to a client an investment advisory Program that has lower fees as it will result in greater compensation to the IAR. To aid in providing clients transparency regarding an IAR’s financial incentive to recommend one Passageway Program over another, below is the schedule of fees FTS is charged for each Passageway program: 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 21 of 61  Passageway One Program2 SMA Program Passageway Focus2 Advisor Directed Program 0.00% 0.10% Up to 0.50% (Fee will vary by the Portfolio Manager(s) selected) Up to 0.50% (Fee will vary by the Portfolio Manager selected) Fund Strategist Portfolio AllianceBernstein Program4 Aspire Program2 BlackRock Program1 Brinker Capital Program5 FEG Program2 Frontier Program2 0.02% 0.17% 0.02% 0.02% Cantor Fitzgerald Program2 0.27% Capital Group Program6 0.02% 0.32% Goldman Sachs ETF Program2 0.17% 0.22- 0.27% Fund Strategist Portfolio John Hancock Program2 Russell Program7 Vanguard Program8 Voya Program2 Wilshire Program2 Goldman Sachs Mutual Fund Program2 0.17% 0.02% Richard Bernstein Program2 0.17% 0.00-0.02% 0.00-0.02% 0.02% 0.22% Fund Strategist Portfolio Symmetry Program2 Structured Portfolios (Closed to new accounts) PrecisionCore ETF Portfolios US Sector Momentum 0.27% Panoramic Portfolios 0.02%3 0.27% 0.27% 1 FTS does not pay a management fee to BlackRock. The BlackRock Program utilizes mutual funds and/or ETFs where BlackRock and/or an affiliated entity or entities of BlackRock receive compensation through the management of those funds. Please refer to the corresponding prospectuses of the BlackRock funds and Item 9C. – Additional Conflicts of Interest in this Brochure for additional detail. However, FIWA charges FTS 0.02% for BlackRock Program accounts. 2 0.02% of the listed fee reflects the amount FIWA charges FTS. This FIWA fee is included in the investment advisory fee paid by the client, as reflected on the Statement of Investment Selection, and does not reflect an additional charge to the client. 3 FTS does not pay a management fee to Symmetry Partners, LLC for the Panoramic Portfolios. The Panoramic Portfolios within the Symmetry Program utilizes Symmetry Panoramic funds where Symmetry receives compensation through the management of those funds. Please refer to the corresponding prospectuses of the Symmetry Panoramic funds, Symmetry Partners, LLC’s ADV Part 2A, and Item 9C. – Additional Conflicts of Interest in this Brochure for additional detail. However, FIWA charges FTS 0.02% for Symmetry Program accounts that use the Panoramic Portfolios. 4 FTS does not pay a management fee to AllianceBernstein. The AllianceBernstein Program utilizes AllianceBernstein mutual funds where AllianceBernstein and/or an affiliated entity or entities of AllianceBernstein receive compensation through the management of those funds. Please refer to the 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 22 of 61  corresponding prospectuses of the AllianceBernstein funds and Item 9C. – Additional Conflicts of Interest in this Brochure for additional detail. However, FIWA charges FTS 0.02% for AllianceBernstein Program accounts. 5 FTS does not pay a management fee to Brinker Capital. The Brinker Capital Program utilizes Brinker Destination funds where Brinker Capital and/or an affiliated entity or entities of Brinker Capital receive compensation through the management of those funds. Please refer to the corresponding prospectuses for the Destination funds and Item 9C. – Additional Conflicts of Interest in this Brochure for additional detail. However, FIWA charges FTS 0.02% for Brinker Capital Program accounts. 6 FTS does not pay a management fee to Capital Group. The Capital Group Program utilizes Capital Group ETFs and/or the American Funds family of mutual funds where Capital Group and/or an affiliated entity or entities of Capital Group receive compensation through the management of those funds. Please refer to the corresponding Capital Group funds or American Funds prospectus or prospectuses and Item 9C. – Additional Conflicts of Interest in this Brochure for additional detail. However, FIWA charges FTS 0.02% for Capital Group Program accounts. This FIWA fee is included in the investment advisory fee paid by the client, as reflected on the Statement of Investment Selection, and does not reflect an additional charge to the client. 7 FTS does not pay a management fee to Russell. The Russell Program utilizes Russell Investment Company funds where Russell and/or an affiliated entity or entities of Russell receive compensation through the management of those funds. Please refer to the corresponding prospectuses of the Russell funds and Item 9C. – Additional Conflicts of Interest in this Brochure for additional detail. However, FIWA charges FTS 0.02% for Russell Program accounts. This FIWA fee is included in the investment advisory fee paid by the client, as reflected on the Statement of Investment Selection, and does not reflect an additional charge to the client. 8 FTS does not pay a management fee to The Vanguard Group, Inc. The Vanguard Program utilizes Vanguard mutual funds and ETFs that receive compensation through the management of those funds. Please refer to the corresponding prospectuses of the Vanguard mutual funds and ETFs and Item 9C. – Additional Conflicts of Interest in this Brochure for additional detail. However, FIWA charges FTS 0.02% for Vanguard Program accounts opened beginning June 1, 2017. This FIWA fee is included in the investment advisory fee paid by the client, as reflected on the Statement of Investment Selection, and does not reflect an additional charge to the client. a) NFS Minimum Account Fees FIWA charges FTS a minimum fee for each investment advisory account. This minimum fee varies by program (e.g., Fund Strategist Portfolio, Passageway One, Passageway Focus, etc.). As a result, FTS has a conflict of interest in recommending investment advisory accounts only when it expects the investment advisory account, including Passageway accounts, will be funded at a level sufficient to cover this minimum fee. To help mitigate this conflict of interest, FTS absorbs the cost of the minimum fee rather than passing it on to our IARs. By not allocating this cost to IARs, FTS reduces the financial incentive for IARs to recommend advisory accounts based on the need to cover the minimum fee. 2) Passageway Program Standard Fee Schedule: Investment advisory fees (referred to as the “Program Fee” in the Investment Management Agreement) for Passageway generally follow the below fee schedule*, but investment advisory fees can be lower. Clients should refer to their Investment Policy Statement or their Statement of Investment Selection to see the negotiated advisory fee schedule for their specific Passageway account(s). Value of Account Advisory Fee First $250,000 Next $250,000 1.50% 1.35% 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 23 of 61  Next $250,000 Next $250,000 Next $1,000,000 Balance Above $2,000,000 1.25% 1.10% 1.00% 0.80% *In the Passageway One Program, if the client selects to receive the Tax Overlay Service, this optional service has an additional fee on top of the Passageway Program Standard Fee Schedule, which means that the total fees can be in excess of the total Passageway Program Standard Fee Schedule. 3) Tax Overlay Service Fee Schedule: Passageway Account Value Passageway One Program Tax Overlay Fee* Tax Overlay Fee* All Eligible Passageway Programs Excluding the Passageway One Program $0 - $10M $10M-$25M Greater than $25,000,000 0.08% 0.08% 0.08% 0.10% 0.08% 0.05% *The Tax Overlay Service is subject to a minimum annual dollar fee of $40 per year per Passageway Program Account that uses the Tax Overlay Service. D. Client Householding Investment Advisory Fees Clients who have a tiered investment advisory fee schedule (see ‘Passageway Program Standard Fee Schedule’ above) can potentially reduce their investment advisory fees when FTS investment advisory accounts are linked together to aggregate total assets under management (hereafter referred to as “Householding”). By Householding FTS investment advisory accounts, the client can potentially reach a subsequent tier on the investment advisory fee schedule that has a lower advisory fee For example, if a client has two Passageway accounts in the Advisor Directed Program using the standard tiered investment advisory fee schedule (see above) and each of these accounts has a balance of $150,000, the combined assets of the two Passageway accounts would be $300,000. Instead of each investment advisory account receiving an investment advisory fee charge of 1.5%, the Householding feature will result in the first $250,000 receiving a 1.5% charge, and the next $50,000 receiving a charge of 1.35%. Householding FTS investment advisory accounts will not always result in a lower investment advisory fee if the combined assets of the Householded accounts do not reach a subsequent tier of the client’s standard advisory fee schedule. For example, if the client has two Passageway accounts Householded each holding $100,000 and the first tier of the investment advisory fee schedule goes from $0 - $250,000, then the client would not receive a reduction in investment advisory fees because the total Householded amount is $200,000, which is below the minimum amount for the next tier ($250,000.01). If the client has a flat percentage investment advisory fee (e.g., 1.40%) rather than a tiered investment advisory fee schedule, the client will not receive any reduction of investment advisory fees regardless of the value of combined assets when FTS investment advisory accounts are Householded. 1) Householding Advisory Fees Criteria For investment advisory accounts to qualify for Householding, the FTS investment advisory accounts must meet certain conditions. The current conditions for Householding are: • Each of the Householded investment advisory accounts through FTS being linked together must have the same IAR or IARs associated. For example, if a client with a Passageway account that has an IAR (John Doe) and their spouse has a different IAR (Jane Smith) who handles their Passageway account, the Passageway accounts will not be Householded because the clients have different IARs. • Each Householded FTS investment advisory account must be open (i.e., the investment advisory 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 24 of 61  relationship has not been terminated) at the end of the calendar quarter. For example, if a client has two Passageway accounts that meet all the conditions to receive Householding but terminates one of the FTS investment advisory accounts during the calendar quarter including up to the last day of the calendar quarter, then the FTS investment advisory accounts would not be Householded. • Each Householded FTS investment advisory account must have the same mailing address listed with FTS. If a client or clients have two or more separate mailing addresses, even if the client or clients are related or part of the same family (e.g., spouse, children, trust, etc.), the FTS investment advisory accounts are not eligible for Householding. A client should never provide FTS with a mailing address that is not their own address. If a client provides FTS with another individual’s address, that individual at the other address would receive the client’s statements and other communications from FTS, FIWA and NFS rather than the client; and • If the client has additional non-advisory accounts (e.g., brokerage accounts, annuities, 529 Plans, etc.), these accounts and assets are not eligible for Householding. Provided that the above listed criteria are met and continue to be met, Householding will be applied to the applicable investment advisory accounts through FTS. Investment advisory accounts through FTS that are linked for Householding are not required to be opened on the same day to be eligible for Householding. Clients are not required to take any steps to apply for Householding. Important Consideration for Householding – When investment advisory accounts through FTS are Householded together, clients receive only one Quarterly Performance Report that reflects all of the Householded investment advisory accounts through FTS. 2) How to Opt Out of Householding Clients desiring to receive separate Quarterly Performance Reports for their investment advisory accounts will need to opt-out of Householding, which can result in paying more in investment advisory fees. Clients can opt-out of Householding by providing a written request to: Fifth Third Securities, Inc. Attn: FTS Compliance Department 38 Fountain Square Plaza MD: 1090XB Cincinnati, OH 45263 However, if a client chooses to opt-out of Householding, the client or clients will not receive the potential benefit of lower investment advisory fees. 3) Termination of Householding by FTS FTS can at any time choose to cease offering Householding or change the conditions of when or how investment advisory accounts through FTS are Householded. If FTS ceases offering Householding or changes the conditions for Householding, FTS will mail clients a written notification approximately 30 calendar days in advance of the change(s) taking effect. 4) Ineligible Accounts for Householding Advisory Fees Householding is not available for any of the following account types: • Investment advisory accounts offered through affiliated entities, such as FTB (e.g., PCS and IM&T programs), Fifth Third Wealth Advisors, LLC (“FTWA”), and Franklin Street Advisors, Inc. • FTS brokerage accounts, including those custodied at NFS. • Variable annuities, variable universal life contracts, 529 Plans, or other mutual fund accounts held directly at the investment company. • Insurance products, contracts, annuities, or other accounts held through Fifth Third Insurance 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 25 of 61  Agency, Inc. E. IAR Compensation A client’s IAR is generally paid a portion of the investment advisory fees (generally a percentage) charged for a Passageway account. The specific amount the IAR will receive will depend on several factors, including but not limited to, the role the IAR has with FTS (e.g., Investment Executive), how long the IAR has been associated with FTS, and the total amount of revenue attributable to the IAR in a calendar year. Specifically, IARs who meet certain revenue thresholds or tiers (e.g., dollar amounts such as $300,000) are eligible for a higher payout percentage of the investment advisory fees, commissions, sales loads, trail commissions, and/or fees from the sales and services associated with the IAR. For example, an IAR whose revenue totaled $200,000 earns less as a percentage than an IAR whose revenue has totaled $400,000. These tiers create a conflict of interest as it provides a financial incentive for the IAR to increase the revenue associated with them. To help address this conflict of interest, FTS has created an IAR compensation schedule with multiple tiers in which an IAR can earn a higher payout. By creating multiple tiers with smaller percentage increases, this decreases the financial incentive for an FTS IAR to act inappropriately to obtain a higher payout percentage. IARs in an “Investment Executive” role for five or more years or in a partnership with another Investment Executive who has been in the role for five or more years, FTS pays a portion of the investment advisory fees from Passageway accounts to the Investment Executive as the investment advisory fees are earned. For all other IARs who can offer investment advisory services through FTS, FTS will advance the first year’s estimated investment advisory fees of a new Passageway account to an IAR based upon the market value of the assets in the first month the assets are invested within the Passageway account. Then, in the approximate thirteenth month since the opening of the Passageway account, FTS will pay the IAR in advance for that month’s anticipated investment advisory fees based upon the market value of the Passageway account. 1) Compensation Conflicts of Interest As a result of the receipt of compensation, when an IAR makes a recommendation to a client and that client opens a Passageway account, the IAR has a conflict of interest because it is anticipated that the IAR will receive a portion of the investment advisory fees associated with that Passageway account. The investment advisory fees earned by an IAR at FTS can be greater than what the IAR would receive at another registered investment advisor firm. The Passageway investment advisory fees can be more or less than what an IAR would receive if a client conducted their transactions in a brokerage account or in an investment advisory account through another FTS investment advisory program, rather than a Passageway account, and paid separately for the investment advice. As a result, your IAR has a financial incentive to offer a Passageway account over a brokerage account or another investment advisory account through another FTS investment advisory program. a) Bonuses & Performance Based Compensation Some IARs are eligible for bonuses or other performance-based compensation. This performance-based compensation is based on a number of factors and generally includes the overall revenue associated with the IAR, which will often include FTS, Fifth Third Insurance Agency, Inc. (“FTIA”), and/or FTB activities and revenue. Certain individuals who are in a role with FTB and oversee an FTB branch office have the potential to receive performance-based compensation based in whole or in part on the branch’s performance metrics. The branch receives credit for FTS related revenue, including investment advisory fees resulting from your Passageway account. b) Recruitment Compensation FTS provides recruitment compensation to IARs who join FTS. There are generally three types of recruitment 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 26 of 61  compensation methods that FTS can use when an IAR joins our firm. (1) Forgivable Draw Compensation The forgivable draw recruitment compensation will generally be broken into two segments. In the first segment, the IAR will generally receive a bi-weekly forgivable draw for the first 6 calendar months and a higher payout percentage for the first 6 calendar months. In the second segment, the IAR will generally receive either a forgivable or non-forgivable draw and a higher payout percentage for the subsequent 12 calendar months. The determining factor whether the draw is forgivable or non-forgivable in the second segment is dependent upon either the amount of revenue associated with the IAR for that time period or the amount of the total market value of the assets brought to FTS during that time period. Generally, recruitment compensation is limited to a time period of no greater than 24 calendar months to allow the IAR to transition to FTS. However, depending on the individual circumstances of the IAR, FTS could deviate from these stated timeframes by going longer or shorter for either segment, or having an overall longer or shorter time period for the recruitment compensation. FTS has established written policies and procedures, controls, and processes that are reasonably designed to provide a supervisory structure that oversees the Passageway Program and FTS’ IARs. (2) Upfront Forgivable Loan or Promissory Note An upfront forgivable loan (or promissory note) is an upfront payment paid by FTS to the IAR when the IAR joins our firm. The IAR doesn’t have to repay the loaned amount if the IAR stays with FTS for the duration of the loan or note and the IAR meets specified revenue targets within defined time periods (e.g., monthly, quarterly). The specific length of time period of the upfront forgivable loan can vary from IAR to IAR. However, generally, a larger upfront forgivable loan will result in a longer time period the upfront forgivable loan will last. An example of how the upfront forgivable loan generally works, if an IAR received a three-year upfront forgivable loan and the IAR meets the revenue threshold in March, then 1/36 or approximately 2.78% of the upfront forgivable loan has been forgiven by FTS and the IAR no longer needs to pay back this amount. An upfront forgivable loan creates a conflict of interest for the IAR because the IAR has a financial incentive to meet monthly revenue thresholds. However, with respect to Passageway accounts, these IARs are subject to a fiduciary duty to act in the best interests of Passageway clients when making recommendations. FTS helps address this conflict by having a separate group of securities registered principals that review the sales activities of Passageway, and these registered principals do not directly receive compensation from the recommendations made by IARs. (3) Sign-On Bonus A sign-on bonus is an upfront payment provided to an IAR upon joining FTS. This bonus is structured to incentivize a long-term relationship and is contingent upon the IAR remaining with FTS for a specified period and meeting certain production or performance expectations during that time. The specific terms, including the amount of the sign-on bonus and the applicable time horizon, can vary based on individual circumstances and business considerations. A sign-on bonus creates a conflict of interest by providing a financial incentive tied to an IAR’s continued employment and performance. However, under the Passageway Program these IARs have a fiduciary duty to Passageway clients for their Passageway accounts when making recommendations. We help mitigate this conflict through established supervisory and compliance processes, including independent review of applicable transactions by supervisory personnel who do not receive compensation based on the recommendations made by IARs. (4) Minimum Guaranteed Payout Percentage FTS generally pays our IARs a percentage of the commissions, sales loads, trail commissions, and/or fees received from the sales and services associated with the IAR (otherwise known as the “payout percentage”). 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 27 of 61  An IAR in the role of an Investment Executive or a Private Bank Investment Executive, when that IAR is initially registered with FTS, is provided with a minimum guaranteed payout percentage. This guarantees that the Investment Executive or Private Bank Investment Executive’s payout percentage will be at a certain percentage for a specified time period. The minimum guaranteed payout percentage is used even if the actual compensation associated with the Investment Executive or Private Bank Investment Executive’s activities is lower than normally required. It is anticipated that the minimum guaranteed payout percentage will be higher than the standard payout percentage when an Investment Executive or Private Bank Investment Executive initially starts with FTS. When we provide an Investment Executive or Private Bank Investment Executive with a minimum guaranteed payout percentage, we do so to help reduce the conflict of interest that can occur when an Investment Executive or Private Bank Investment Executive initially starts with FTS and is making recommendations to clients. The length of time that the minimum guaranteed payout percentage is in place can vary from IAR to IAR, but when we offer the minimum guaranteed payout percentage, it will generally last 24 months from the date the IAR starts with FTS or enters a new role with FTS. However, depending on the individual circumstances of the IAR, we could deviate from these stated timeframes by going longer or shorter for either segment, or having an overall longer or shorter time period for the recruitment compensation. (5) Back-End Asset Based Bonus A back-end asset-based bonus is a payment that is earned by an IAR after joining FTS, contingent upon achieving specified asset levels within a defined period of time. This bonus is typically calculated based on the amount of client assets transitioned to or maintained with FTS and is payable only if the applicable asset thresholds and retention requirements are met. The structure, measurement period, and payout timing of a back-end asset-based bonus are anticipated to vary depending on individual circumstances and business considerations. The Back-End Asset Based Bonus creates a conflict of interest due to the financial incentive provided to the IAR to encourage the transfer or retention of assets. However, under the Passageway Program these IARs have a fiduciary duty to Passageway clients for their Passageway accounts when making recommendations. We help mitigate this conflict through supervisory and compliance controls, including independent review of applicable transactions by supervisory personnel who do not receive compensation based on the assets gathered or the recommendations made by IARs. Furthermore, we help mitigate this conflict of interest by having the Back-End Asset-Based Bonus not tied to any specific product type or service (e.g., brokerage assets versus investment advisory/Passageway). c) Retention Compensation Upon occasion, we provide retention compensation to IARs to remain with FTS. A retention bonus is a payment that is provided to an IAR in connection with their continued registration and performing securities- related activities with FTS over a specified period of time. This bonus is typically contingent upon the IAR remaining with FTS through the applicable retention period, and in some cases, meeting certain performance, production, or asset retention expectations during that time. The structure, amount, and duration of a retention bonus are anticipated to vary based on individual circumstances and business considerations. A retention bonus creates a conflict of interest because it provides a financial incentive for the IAR to remain with us and maintain client relationships with FTS. However, under the Passageway Program these IARs have a fiduciary duty to Passageway clients for their Passageway accounts when making recommendations. We help mitigate this conflict through established supervisory and compliance processes, including independent review of Passageway accounts by supervisory personnel who do not receive compensation based on retention-related incentives or recommendations. d) Retirement Compensation IARs in the role of an Investment Executive have the potential to participate in the receipt of compensation 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 28 of 61  after their retirement from FTS and the securities industry. An Investment Executive’s eligibility in FTS retirement compensation program is dependent upon a number of factors, including but not limited to, the Investment Executive’s tenure with FTS, an Investment Executive’s age, completion of pre-retirement criteria, and/or compliance with various regulatory requirements to receive compensation after their termination from FTS and the securities industry. An Investment Executive’s retirement compensation (payout percentage) is based on the total revenue earned in the rolling 12-months prior to retiring. The payout percentage based upon last rolling 12-months creates a conflict of interest for the retiring Investment Executive since it creates a financial incentive for the retiring Investment Executive to increase their revenue so they can receive more compensation in their retirement. We help mitigate this conflict by having a separate group of securities registered review the activities of IARs. These registered principals do not directly receive compensation from the recommendations made by IARs and will at times use tools and systems designed to aid their supervisory reviews based upon various risk-based information. Additionally, we have provisions in IAR’s compensation plans that provide for the recovery, withholding, repayment, or “clawback” of compensation due to violation of policy, procedures, or state and federal laws or regulations. 2) IAR Forfeiture of Compensation Certain activities or failure to perform certain activities will or can result in the forfeiture of an IAR’s receipt of their portion of the investment advisory fee. This includes the following: • FTS requires its IARs to conduct an annual review meeting with Passageway clients. If an annual review is not conducted in a calendar year starting the year after the Passageway account is opened, the IAR will have their portion of investment advisory fees for that Passageway account forfeited until a review has been conducted with the applicable Passageway client. Once the annual review has been conducted, the IAR will begin to receive the portion of the investment advisory fees for that Passageway account again. • As part of the due diligence of the securities made available in the Advisor Directed and the Passageway One Programs for IARs to manage, securities will be removed from the available list when the security does not meet certain criteria. Once a security is removed from the available list, the IAR will have a specified time period to have the security or securities removed from the Advisor Directed or Passageway One Programs Account. If an IAR does not sell, exchange, or work with the client to transfer the removed security or securities from an Advisor Directed or Passageway One Programs account within the prescribed time period, then the IAR’s portion of the investment advisory fees are forfeited until the security is no longer held in the Advisor Directed or Passageway One Programs account. Once the removed security is no longer in the Advisor Directed Passageway One Programs account, the IAR will receive the portion of the investment advisory fees for that Passageway account again. Notwithstanding this process, an IAR can seek an exception from FTS to this process for non- qualified accounts (e.g., Individual, Transfer on Death, Joint accounts) where the IAR would not be required to remove the applicable security for up to one year. If an IAR’s exception request is approved by FTS, the client is sent a written notification informing them that the security or securities no longer meets the due diligence requirements but are being retained in the Passageway account. In this scenario, the IAR continues to receive the investment advisory fees associated with the Passageway account. • When a Passageway account’s value is below $25,000, the IAR does not receive any compensation associated with your Passageway account. Additionally, when a Passageway account’s value is between $25,000 and $49,999.99, your IAR does not receive compensation from the Passageway account unless the client has total household assets of $50,000 or more with FTS. 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 29 of 61  In addition to the aforementioned reasons, FTS can, as a part of disciplinary action, cause the forfeiture or withholding of an IAR’s portion of investment advisory fees associated with a specific Passageway account or accounts when an IAR acts materially different from FTS’ expectations or policies and procedures. F. Mutual Fund and ETP Fees FTS does not charge a sales commission or load for investments in mutual funds or ETPs. However, a client that already owns certain securities that have contingent deferred sales charge (e.g., class B and C share mutual funds) will be subject to that fund company’s charges. Liquidation of these investments reduces the value the client will have to invest in Passageway. Clients should carefully review the securities they will use to fund a Passageway account prior to choosing to establish a Passageway account. In addition, each mutual fund and ETP have their own expenses, which are described in each mutual fund and ETP’s prospectus. These fees and expenses generally include a management fee, trading costs associated with the underlying securities of the fund, and other expenses, which can also include Rule 12b-1 fees or similar fees for mutual funds. The fees and expenses of a mutual fund and ETP reduce the performance of the account and are imbedded in the net return of the mutual fund or ETP. Therefore, the client should review both the total direct and indirect fees and expenses of mutual funds and ETPs. Some mutual funds have different share classes available, and these share classes will have different expenses, including the internal expenses. FTS and Portfolio Managers will utilize the cheapest share class of mutual funds that is available to FTS or the Portfolio Manager at the time of the purchase. However, some mutual funds have different share classes that are not available to FTS or the Portfolio Manager, and these share classes of mutual funds can be cheaper than those purchased in the client’s Passageway account. Some investment Companies (issuers of mutual funds) pay Rule 12b-1 fees to FTS for mutual funds that are held in a Passageway account. When this occurs, FTS will accept the 12b-1 fees and then have the 12b-1 fees reimbursed directly to the client’s Passageway account the following month the 12b-1 is credited to FTS. For clarity, if part or all of the 12b-1 fee is retained by NFS, the mutual fund company, or any other party other than FTS, these 12b-1 fees are not credited back to client’s Passageway account since FTS did not receive these 12b-1 fees. Passageway accounts can be invested in alternative mutual funds which can have higher operating expenses compared to traditional mutual funds, and some alternative mutual funds are considerably more expensive. G. Additional Costs Charged by Custodian FTS and the custodian for Passageway accounts, NFS, assesses additional costs and fees. These costs are not included in the investment advisory fees described above. These costs include but are not limited to the following: wire fees, overnight mailing fee, foreign security movement fee, and stop payment on check fee. Refer to the Investment Advisory Account Fee Schedule at the end of this Brochure. H. Miscellaneous Fees Although commissions and transaction fees are not charged to the client’s account for securities transactions placed by FTS, there are securities transactions affected through or with another broker-dealer other than NFS that can include commissions and transaction fees. These securities transactions can include commissions, mark-ups, mark-downs, or dealer spreads paid to market makers or other principals from whom securities were obtained. This type of trade is often referred to as “step out trades” or “trading away”. The effects of these trades are indirectly borne by the client and are not covered by the investment advisory fees discussed above. The Portfolio Manager for your Passageway account (which can include FIWA) can determine that placing your trades with NFS is in your best interest. However, the Portfolio Manager has the ability to place a client’s trades with a broker-dealer other than NFS if the Portfolio Manager believes that doing so is consistent with its obligation to obtain best execution. FTS does not decide when securities transactions are placed with NFS or away from NFS. In addition, FTS does not impose a restriction on a Portfolio Manager’s 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 30 of 61  ability to trade away, as the Portfolio Manager has a fiduciary duty to the clients. In some instances, step out trades are executed without any additional commission, mark-up, or mark-down, but in many instances, the broker-dealer executing the step out trade will sometimes impose a commission or a mark-up or mark-down on the securities transaction. Additionally, some Portfolio Managers executing trades in US Treasuries will incur a system cost from the portal through which the trades are processed. These additional costs are often not reflected on trade confirmations Passageway clients receive or on their account statements. Often, the executing broker will embed the costs into the price of the trade execution, making it difficult for you to determine the exact added cost for the securities transaction executed away from NFS. Clients should review the Form ADV Part 2A Brochure of the Portfolio Manager of the Passageway program selected for more information. Clients can request the Program Manager’s Form ADV Part 2A brochure from your IAR. Please refer to Exhibit A at the end of this Brochure for more information regarding Portfolio Managers that have engaged in “step out” trades, which are generally going to result in additional costs to the client, such as markup/markdowns and commissions. A “step out” trade is when a Portfolio Manager, FIWA, or Envestnet directs a securities transaction or a portion of a transaction to a broker other than the Fidelity or NFS. Step out trades are generally done in an attempt to obtain best execution or to obtain a security from the broker which might otherwise be unavailable (e.g., participate in a new issued security). The information provided in Exhibit A has been provided by the corresponding Portfolio Managers, and FTS cannot attest to the accuracy of this information as the step out trading can include trading activity that has occurred at other financial firms as well as FTS. I. Trade Errors If FTS, FIWA, or a Portfolio Manager makes an error when submitting a trade order on a client’s behalf, it is the policy of FTS that the trade error be corrected as soon as possible and in such a manner the client is not disadvantaged and bears no loss as a result of the error. Upon the identification of a trade error, FTS will work with NFS and/or FIWA to take the appropriate steps necessary to rectify the error. If correcting a trade error results in a loss or a gain within the client’s account, FTS, FIWA, and/or the Portfolio Manager will retain any gain or absorb any loss. J. Best Execution As a registered investment advisor, FTS and the Portfolio Managers used in Passageway have a fiduciary duty to seek to obtain the best trade execution in Passageway accounts. Clients should understand that we may not always obtain the lowest possible transaction cost, and best execution does not mean the best price will be obtained. In addition, we may execute transactions at different prices or costs, and the execution quality received by one client may differ from the execution quality received by another client depending on the type of security, market conditions, order size, account restrictions, or other relevant factors. Several factors are utilized in analyzing overall best trade execution quality, including but not limited to, execution capability, timeliness of affecting trades, ability to execute orders of significant size, service, costs, system capabilities, system security, financial stability of firm executing the trade, and other relevant considerations. These factors combined are collectively referred to as “best execution”. To aid in our best execution obligations, FTS periodically and systematically conducts a sample review of equity securities transactions executed through NFS to help confirm FTS continues to meet our best execution obligations with our clients. Portfolio Managers that direct transactions for Passageway Accounts are responsible for satisfying best execution obligations, and the Portfolio Manager can choose to place a trade at a firm other than NFS if that Portfolio Manager believes they need to in order to meet their best execution obligation (often referred to as “trading away”). See Exhibit A for details on Portfolio Managers that had step out transactions in the previous calendar year. K. Trade Allocations and Block Trading FIWA and Portfolio Managers can pool securities trades for the same security for multiple client accounts to 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 31 of 61  create large blocks of trades. This is done to help achieve best price execution for the total pool of accounts and/or to help avoid conflicts of interest of favoring one client over another. Once the trades have been executed, the securities or proceeds are allocated back to the pool of client accounts at an average price for the block trade as a whole. Portfolio Managers have their own allocation policies and will direct how trade executions are allocated. FTS has no control over a Portfolio Manager’s allocation policies except for when FTS and our IARs act as the Portfolio Manager. For more information on block trading please see FIWA’s ADV Part 2A Brochure. A current copy can be requested from your IAR or can be obtained directly from the SEC’s website (https://adviserinfo.sec.gov/firm/brochure/301896) and select “Fidelity Managed Account Xchange” under Brochure Name. L. Non-Managed Assets and Worthless Securities FTS generally does not permit securities to be held in a Passageway account that are not part of the asset management of the Passageway account unless it is an Unsupervised Asset (discussed below) or is a worthless security. However, if a security is deemed to be worthless (has no market value) and you do not have a brokerage account with FTS where this worthless security can be held, then that worthless security can be held in the Passageway account with the client’s understanding that the worthless security or securities are not being managed by FTS, FIWA, or a Portfolio Manager. M. Unsupervised Assets In some cases, a client may want to transfer a security or investment into a Passageway account but not want that security or investment immediately managed as part of the account's investment strategy. Clients can want this approach for a variety of reasons, including a desire to defer the tax consequences associated with liquidating the asset. A client or an IAR may request that a security or investment be designated as an Unsupervised Asset within a Passageway account by completing an Unsupervised Assets Administration Form. Clients may obtain the form from their IAR or access it at https://www.53.com/ftsdisclosure, and are to submit the completed form to their IAR for processing. Upon receipt of a completed Unsupervised Assets Administration Form, the request will be evaluated by both FTS and FIWA. A security or investment will be treated as an Unsupervised Asset only if the request is approved by both FTS and FIWA. Requests may be denied for a variety of reasons, including, but not limited to, circumstances in which FTS or FIWA reasonably believes that the client does not intend to liquidate the security or investment and have the proceeds managed within the Passageway account, or where the client intends to retain the proposed Unsupervised Asset for an extended period of time inconsistent with the purpose of have the proceeds of the Unsupervised Asset managed. If FTS or FIWA do not agree to the request to have a security or investment treated as an Unsupervised Asset, written notice will be provided by FTS to the client. Important Considerations: 1) If a client does not intend for a security or investment to ultimately be managed within a Passageway account, the client should neither request nor agree to designate that security or investment as an Unsupervised Asset. Only securities or investments that you reasonably expect to be transferred into and managed as part of a Passageway account should be considered for a request as an Unsupervised Asset. 2) The discretionary authority granted by client to FTS and our IARs includes the authority on determining when to liquidate an Unsupervised Asset and include the proceeds of the Unsupervised Asset into the management of the Passageway account without the prior consent of the client. If a client does not want FTS and our IARs to determine when an Unsupervised Asset should be liquidated and incorporated into the management of a Passageway account, the client should have those security(ies) or investment(s) held in a brokerage account instead of having the security(ies) or investment(s) established as an Unsupervised Asset in a Passageway account. Since Unsupervised Assets are not part of the active management of a Passageway account, FTS does not charge an Investment Advisory Fee (see Item 4.C. – Investment Advisory Fee Information for further 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 32 of 61  details) on an Unsupervised Asset until it is liquidated. As a result, there is financial incentive and a conflict of interest for FTS and our IARs to liquidate an Unsupervised Asset and have the proceeds incorporated into the management of the Passageway account as FTS and our IAR(s) on the Passageway account will make more in compensation. N. Holding a Client’s Order or Instruction FTS, at its own discretion and without consultation with the Passageway client, may choose not to immediately act upon a Passageway client’s order to place a transaction or series of transactions (e.g., buy, sell, exchange, transfer, withdrawal) or act upon a client’s instruction if FTS believes that the client is the subject of financial abuse or is engaged or potentially engaged in a criminal activity (directly or indirectly). Examples of client instructions that FTS or FTS’ IARs may choose not to act upon immediately include, but are not limited to, executing securities transactions, money movement instructions including wire and check movements, termination of advisory services, change in beneficiary or beneficiaries, and trading authorization of a third-party. In the instances where FTS does not immediately act upon a Passageway client’s order to place a transaction or act upon a client’s instruction, FTS will attempt to promptly conduct a review in order to determine the appropriate course of action, which can include, but is not limited to, contacting the client, State and/or federal authorities, or the Passageway client’s Trusted Contact. FTS can choose not to act upon a client’s instructions or order for up to 15 calendar days, or for a longer period if permitted by applicable State laws/regulations, or as directed by State or federal authorities. Item 5 – Account Requirements and Types of Clients A. Minimum Account Requirement Each Passageway account requires a certain minimum dollar value of either cash or marketable securities that are acceptable to FTS before FTS approves an account. The Passageway account minimums are as follows: • Advisor Directed Program - $50,000 • AllianceBernstein Program - $50,000 • Aspire Program - $50,000 • BlackRock Program - $50,000 • Brinker Capital Program - $50,000 • Cantor Fitzgerald Program - $50,000 • Capital Group Program - $50,000 • FEG Program - $50,000 • Frontier Program - $50,000 • Goldman Sachs ETF Program - $50,000 • Goldman Sachs Mutual Fund Program - $50,000 • John Hancock Program - $50,000 • Passageway Focus Program - $10,000 • Passageway One Program - $100,000* • Richard Bernstein Program - $50,000 • Russell Program - $50,000 • SMA Program - $100,000+* • Symmetry Program - $50,000 • Vanguard Program - $50,000 • Voya Program - $50,000 • Wilshire Program - $50,000 *Portfolio Managers that are available under the Passageway One Program and the SMA Program establish 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 33 of 61  their own minimum amount of assets in order for them to provide investment management services. Clients can ask their FTS IAR for the minimum amount a specific Portfolio Manager requires to manage assets. In addition, FTS, FIWA, or the Portfolio Manager, at their discretion, can terminate a Passageway account if the Passageway account falls below the account-opening minimum. B. Changes to a Client’s Financial Situation Passageway clients are required to promptly notify FTS in writing of any material changes to their information previously provided to FTS. Some examples include: Investment objective Investment time horizon • • Risk tolerance • Net worth • Annual income • • Address Failure by the client to provide FTS with current, accurate information could adversely affect FTS and Program Manager’s ability to effectively manage the client’s assets within Passageway. C. Types of Clients Passageway is available to individuals, high net worth individuals, trusts, estates, foundations, charitable institutions, corporations, private pension plans, and other business entities or organizations with sufficient liquid assets to participate in Passageway. Passageway is not intended for government entities (federal, state, or municipal) or for public pension plans. Item 6 – Portfolio Manager Selection and Evaluation A. Selection and Review of Portfolio Managers FTS utilizes FIWA to conduct initial and ongoing due diligence on SMA Programs, except for the Portfolio Managers solely reviewed by FTS. FIWA’s review of Portfolio Managers is based on, among other things, Portfolio Manager’s responses to a compliance questionnaire, Form ADV review, proxy voting procedures, and performance relative to the Portfolio Manager’s peer group and benchmark. FIWA’s review will result in the recommendation of new Portfolio Managers and the removal of previously approved Portfolio Managers. FIWA reviews both qualitative and quantitative data prior to adding or removing of a Portfolio Manager from Passageway. For more information regarding FIWA’s Portfolio Manager Selection and Evaluation please refer to FIWA’s ADV Part 2A. FIWA’s review of Portfolio Managers is independent from FTS. Upon occasion, FTS conducts ongoing due diligence on some of the Portfolio Managers available in the SMA Program in which FIWA does not perform ongoing due diligence. For these Portfolio Managers, FTS reviews various quantitative data, such as performance against benchmark, alpha (measurement of risk), and performance over various time periods. In addition, FTS has selected additional Portfolio Managers and programs (e.g., FIWA, Aspire, AllianceBernstein, BlackRock, Brinker Capital, Cantor Fitzgerald, Capital Group, FEG, Frontier, Goldman Sachs, Symmetry, FTB, Russell, Vanguard, and Wilshire) to participate in Passageway. Selection and ongoing retention of Portfolio Managers and programs is based upon various factors, including but not limited to: • Investment strategy • Management fee • Historical performance • Portfolio Manager’s ADV Part 1 and 2 • Marketing materials 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 34 of 61  • Additional quantitative and qualitative information FTS’ ongoing review of Portfolio Managers’ performance does not include a calculation or determination as to the accuracy of any performance information that is provided or made available by the Portfolio Manager. A Portfolio Manager can utilize a third-party to review and verify their performance calculation(s). Please refer to Portfolio Manager’s ADV Part 2A for more information. Performance information prepared by Portfolio Managers that is separate from the quarterly performance reports prepared by FIWA is not calculated on a uniform and consistent basis. When a Portfolio Manager is removed by FIWA or FTS, clients utilizing this Portfolio Manager are notified by their IAR of this event. The IAR will work with clients to identify another Portfolio Manager or Passageway program that corresponds with their investment objectives and risk tolerance. B. Related Entities as Portfolio Manager FTS does not have any related entities that act as a Portfolio Manager in Passageway. C. FTS’ IARs as Portfolio Managers in Advisor Directed and Passageway One Programs In the Advisor Directed Program, FTS’ IARs act as the Portfolio Manager, and in the Passageway One Program, FTS’ IARs have the availability to act as a Portfolio Manager. See below for additional information related to the investment management services provided by FTS in the Advisor Directed Program and in the Passageway One Program where an FTS IAR(s) is acting as a Portfolio Manager. 1) Advisory Business Please see Item 4.B. Passageway Investment Management Programs for descriptions of the Advisor Directed and Passageway One Programs and details on the ability to place reasonable investment restrictions on a Passageway account. 2) Methods of Analysis, Investment Strategies, and Risk of Loss Portfolio Managers utilize various sources of information, which can include but is not limited to, financial newspapers and magazines, inspection of corporate activities, research materials prepared by others, corporate rating services, annual reports, prospectuses, materials provided by FIWA, filings with the U.S. Securities and Exchange Commission, and other publicly available tools and information sources. An IAR of FTS will meet with a prospective client to interview and complete an investor profile. During this interview the IAR gathers information regarding the client’s risk tolerance, investment objectives, and financial information. With this data, the IAR assists the client in determining whether Passageway is appropriate for them and recommends one or more Passageway programs to the client. If a Passageway program is recommended, an asset allocation model is recommended in conjunction with the Passageway program. Each Passageway account is invested in securities aligned with the client’s selected risk tolerance. However, in the Advisor Directed and Passageway One Programs, FTS can invest a client’s account in a portfolio corresponding to a risk tolerance that is one level more conservative than the client’s selected risk tolerance. The client’s Statement of Investment Selection or Investment Policy Statement reflects the selected asset allocation model. As noted above, the applicable Portfolio Manager is responsible for the selection and monitoring of investments in the Passageway account after the client has signed the Statement of Investment Selection and funded the Passageway account. Information about the Portfolio Manager’s investment methodology, the types of investments that can be used, and the risks associated with those investments, can be found in the corresponding Portfolio Manager’s ADV Part 2A brochure and/or the investment’s prospectus, if applicable. A copy of Portfolio Manager’s ADV Part 2A brochure is provided to the client at or prior to the establishment of the Passageway account. Clients can request another copy of their Portfolio Manager’s ADV Part 2A brochure at any time by contacting their IAR or contacting FTS at the phone number listed on the cover page of this Brochure. Diversification and asset allocation can help reduce the risk of a portfolio, but they do not remove all risk or 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 35 of 61  chance of loss of the original amount invested or the gains earned in a Passageway account. Periodically the Passageway account is rebalanced to help provide consistency with the client’s ongoing investment objectives and the asset allocation. Different types of investments or investment strategies involve varying degrees of risk, and it should not be assumed that the future performance of any specific investment or investment strategy will be profitable. This includes the investments and investment strategies recommended or undertaken by FTS or other Portfolio Managers of Passageway. Investments are not obligations of, and are not guaranteed by, FTS, FTB or any of our other affiliates, and are not Federal Deposit Insurance Corporation (“FDIC”) or government insured. Investments are subject to risks, including possible loss of the principal amount invested. Losses can occur with any investment or strategy, including conservative investments. The more risk the client is willing to bear, the greater the potential for loss of the principal amount invested by the client or loss of unrealized gains on assets held in the Passageway account. Additional information about the risks concerning a particular mutual fund or ETP can be found in the respective mutual fund or ETP’s prospectus. Clients of Passageway should be prepared to bear the risk of loss associated with having a Passageway account. Portfolio goals and objectives are not guaranteed and may not be achieved. Past performance does not guarantee future results. Passageway accounts and the securities in the client’s Passageway account can be subject to the following risks: a) Risk of Asset Value Loss All Passageway programs and various models provided by Portfolio Managers, including the conservative models, involve the risk of loss including the loss of the original investment amount or loss of the unrealized gains on assets. Clients should have a willingness to incur such losses in connection with investments in the Passageway, especially if the client invests for a shorter period of time. By investing in Passageway, clients can lose money by investing in stocks, bonds, mutual funds, ETPs, or other securities or by the investment strategy or strategies used by the applicable Portfolio Manager. Many factors affect each investment’s or Passageway account’s performance. Nearly all investments and Passageway accounts are subject to volatility in non-U.S. markets, through either direct investment exposure or indirect effects in U.S. markets from events occurring abroad, including adverse political, social, economic, or market occurrences. Additionally, investments or Passageway accounts that pursue debt exposure are subject to risks, including, but not limited to, prepayment risk, default risk, and interest rate risk. In addition, funds, ETPs, and investment strategies that pursue strategies that concentrate in specific sectors or industries or are otherwise subject to particular segments of the market (e.g., healthcare, technology, real estate, financial, or international) can be significantly impacted by events affecting those sectors, industries, or markets. Mutual funds or ETPs that invest in other funds bear all the risks inherent in the underlying investments in which those funds invest. Strategies that pursue leveraged risk, including investment in derivatives — such as options, swaps (interest rate, total return, and credit default) and futures contracts — and forward-settling securities, magnify market exposure and losses. Mutual funds, ETPs, and Passageway accounts are also subject to operational risks, which can include risk of loss or losses arising from failures in internal processes or systems, or people, such as routine processing errors or major systems failures, or from external events, such as exchange outages. b) Interest Rate Risk The bond market is volatile, and bonds and other fixed income securities carry interest rate risk. Interest rate risk is generally expected to occur when the interest rate changes, but interest rate risk can also occur when market expectations of interest rate changes (or lack thereof) do not occur. Interest rates and bond prices generally have an inverse relationship; meaning that when interest rates increase the values of bonds decrease (and the opposite will generally occur when interest rates decrease). Generally, the longer the duration of a bond, the greater the impact on the valuation of the bond. For example, an interest rate increase will generally have a greater impact (an expected decrease in value) on a 20-year bond versus 5-year bond by the same issuer with same or similar terms. Fixed income securities also carry inflation risk and 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 36 of 61  credit and default risks for both issuers and counterparties. Most bond funds do not have a maturity date, so holding the bond funds until maturity to avoid losses caused by price volatility is not feasible. In addition, investments in certain bond structures are less liquid than other investments. Therefore, they are anticipated to be more difficult to trade effectively and can trade at a significant discount (loss) when sold. c) Credit Risk Issuers of debt and other counterparties may be unable to make interest or principal payments when due or otherwise honor their debt obligations. Credit rating changes of the issuer can adversely affect the value of the debt instrument or security. Additionally, changes in the financial condition of an issuer or counterparty(ies) and/or changes in specific economic or political conditions that affect a particular type of security or issuer, can increase the risk of default by an issuer or counterparty, which can affect a security or instrument’s credit quality or value. Lower-quality debt securities involve greater risk of default or price changes due to changes in the credit quality of the issuer. d) Cybersecurity Risk Companies, markets, investment companies, including ETPs and mutual fund companies, and services providers, like FTS, Portfolio Managers, FIWA, and NFS, use significant amounts of technologies in their day- to-day functions. As a result, these entities and those individuals who use these services or have investments in companies are subject to numerous cybersecurity risks. Cybersecurity risks include, but are not limited to, compromised company, employee or client data, disruption of services, corruption or loss of data, inability to perform services (e.g., trading, valuation, issuance of reports, communications), and financial losses. e) Artificial Intelligence (“AI”) Risk Technology advances in AI and machine learning technologies (e.g., ChatGPT, Gemini, Grok, etc.) create risks for users of these technologies, including FTS, Portfolio Managers, FIWA, and NFS. AI is a fast-evolving technology that has several risks associated with it, including but not limited to the following: • Confidential information Exposure: Accidental or intentional use of confidential or sensitive information into AI or machine learning technologies can result in the dataset being accessible by other AI technologies and/or users which could lead to unauthorized disclosure or misuse of client or firm data. • Bias and Factual Inaccuracies Risks: AI can be prone to algorithmic biases and present false or misleading information as factually accurate, known as “hallucinations”. AI hallucinations can be created by flawed data training, AI’s misinterpreting data or patterns, source of data is inaccurate, or the AI model will struggle to accurately understand real-world knowledge or factual information. • Model Risk: Models (e.g., portfolio management models, predicative models, risk assessment models, etc.) created, managed, or assisted by AI, can behave unpredictably if trained on biased, incomplete, or outdated data. This can lead to model issues such as poor investment decisions or misaligned risk assessments. • Regulatory Uncertainty: The legal and regulatory landscape governing AI is still developing and may go through rapid changes. Future changes in laws or regulations will impact on how AI can be used by financial institutions, potentially requiring changes to business practices or technology infrastructure, which could negatively impact FTS, Portfolio Managers, FIWA, and NFS current and future use of AI. f) Derivatives Risk A derivative can be defined as a financial instrument or contract which derives its value from one or more underlying financial instruments such as an asset, index, or interest rate. A mutual fund or ETP’s use of derivatives (sometimes referred to as alternative funds) can reduce the returns of your Passageway account and/or increase the volatility Passageway clients are exposed to. Derivatives are also subject to counterparty risk, which is the risk that the other party in the transaction will not fulfill its contractual obligation. Derivatives may give rise to a form of leverage, and when leverage is used in a mutual fund, ETP, or other 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 37 of 61  security or investment strategy there is greater risk and often higher costs. g) Direct Indexing Risk Direct Indexing involves purchasing individual securities to help replicate a selected market index. This investment strategy carries risks, including but not limited to: • Client-Imposed Restrictions: Customization requests by a client can lead to overweight positions in certain sectors or securities, increasing volatility or negatively impacting performance of the Passageway account. • Higher Costs: Compared to traditional index funds or ETFs, direct indexing can involve higher transaction costs and management fees. • Operational Risk: Frequent trading and rebalancing can introduce errors or delays that impact performance. • Tax Complexity: While tax-loss harvesting can be beneficial to a client, it requires careful management and can result in unintended tax consequences. Tax benefits are not guaranteed and will vary based on market conditions, applicable tax laws, and the client’s on-going communication with the IAR servicing their Passageway account regarding their tax needs. Failure to communicate your tax needs to the IAR can result in portfolio management decisions that do not align with your intended tax outcomes. FTS does not provide tax advice, and any tax-related strategies implemented within your account will be based solely on the information you provide. • Tracking Error Risks: See risk titled “Tracking Error” for details on these risks. Direct Indexing is not in the best interest for all investors. Clients not seeking the potential tax harvesting benefits (such as helping offset capital gains, carry forward losses, customization for potential better tax efficiency) should consider other Portfolio Managers that use another investment strategy. Consider your investment objectives, risk tolerance, and consult with a tax professional before choosing a Portfolio Manager that uses a Direct Indexing strategy. h) Investments in a Passageway Account Passageway account will be invested in various securities, which will depend on the individual Passageway program selected by the client. These securities will employ various investment strategies, and each investment strategy has a number of risks associated with it. Therefore, Passageway accounts and the securities held within the Passageway account are subject to these risks and clients can lose a substantial amount of their original investment in Passageway. For more information regarding the risks associated with a mutual fund or ETP, please refer to the corresponding prospectus. i) ETFs An ETF is a fund that trades on an exchange throughout the trading day, similar to stocks, and often seeks to track an index (e.g., S&P 500® Index), commodity or commodities (e.g., oil, natural gas, gold, precious metals, etc.), or a basket of assets based upon a theme, territory, or sector (e.g., healthcare, energy, international stock, consumer staples, dividend appreciation, emerging markets China, etc.). As a result, ETFs often do not have the objective to outperform what they are tracking. However, some ETFs are actively managed and do not seek to track a certain index or basket of assets. ETFs can also have unique risks depending on their structure and underlying investments. ETFs can trade at a premium (above) or discount (below) to their net asset value (“NAV”), and ETFs can also be affected by the market fluctuations of their underlying investments. If FTS or a client decides to terminate the Passageway account during a down market or when ETFs are experiencing a large volume of redemptions, the value of the ETFs can be significantly below the NAV of the underlying assets held in the ETFs. ETFs can experience further below market valuations if the ETF has invested in illiquid or investments that have experienced less liquidity causing the ETF to take below desired valuations to cover redemptions from shareholders. Additionally, some ETFs have not experienced a 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 38 of 61  down market, and there can be unknown risks associated with ETFs. j) Exchange Traded Notes (“ETNs”) An ETN is an unsecured debt obligation of the issuer (usually an investment bank or another financial institution) that often seeks to track a market or strategy and provide returns linked to the performance of a specified index, minus applicable fees. ETNs trade on an exchange throughout the trading day similar to stocks and ETFs but they do not buy or hold assets to replicate or approximate the performance of the underlying index. In addition, ETNs generally do not seek to outperform what they are tracking. Because ETNs are debt instruments, they carry credit risk, meaning a client’s return depends on the financial stability and creditworthiness of the issuer. ETNs can also trade at a premium (above) or discount (below) their indicative value, particularly when market supply and demand fluctuate or if the issuer suspends new issuance. If FTS or a client decides to terminate the Passageway account during periods of market stress, reduced liquidity, or concerns about the issuer’s financial health, the value of ETNs may be significantly impacted. Additionally, ETNs can include maturity dates as well as call provisions or early redemption features depending on the specific terms of the ETN, and some may have limited trading activity, which can increase volatility and reduce liquidity. As with ETFs, some ETNs track complex or less-tested strategies, and there may be unknown risks associated with ETNs. k) ESG, SRI, Faith Based, and Similar Investments and Investment Strategies Portfolio Managers that engage in Environmental, Social, and Governance (“ESG”), Socially Responsible Investing (“SRI”), Faith Based Investing, or similar investment strategy or strategies will generally choose to avoid investments and/or companies that might otherwise be considered appropriate investment options due to factors that can run contrary to the ESG, SRI, or Faith Based investment strategy. As a result, clients selecting a Portfolio Manager or having a Portfolio Manager invest in ESG, SRI, Faith Based, or similar investment strategy can result in lower returns than if the Portfolio Manager had used a non-ESG, SRI, Faith Based, or similar investment strategy or investments. Furthermore, Portfolio Manager’s selection process to include and/or exclude investments can be based upon a number of factors, such as imposing a minimum revenue associated with the activity seeking to be avoided (such as Adult Entertainment). As a result, even if a client selects a Portfolio Manager with an ESG, SRI, Faith Based, or similar investment strategy, the client could still be invested in investments or companies that the client is seeking to avoid. Additionally, clients selecting a Portfolio Manager with an investment strategy or focus on ESG, SRI, Faith Based, or other similar investment strategy should refer to the mutual fund or ETF’s prospectus and/or the Portfolio Manager’s Form ADV Part 2A for more details on the ESG, SRI, or Faith Based investment strategy. FTS does not guarantee that a client’s specific ESG, SRI, or Faith Based goals or client’s interpretation of what the ESG, SRI, Faith Based or similar investment strategy will be represented by a Portfolio Manager or the underlying investments selected. ESG, SRI, Faith Based, or similar investment strategies can be interpreted differently. For example, a Portfolio Manager that has an investment strategy to invest in “clean energy” might consider companies involved in solar and nuclear energy as clean energy options. Whereas a client may not consider solar and nuclear energy sectors as “clean energy.” l) Foreign Exposure Foreign securities, like domestic U.S. securities, are subject to market volatility risk, performance of underlying assets, regulatory risks, economic developments, and other factors that can significantly impact the valuation of a fund or security. In addition, foreign securities are subject to foreign interest rate(s), currency exchange rate, regulatory, geopolitical risks, and other risks, all of which can be greater in emerging markets. These risks are particularly significant for funds that focus on a single country, region, or emerging markets. Foreign markets will at times be more volatile than U.S. markets and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates can also be extremely volatile and can lead to significant losses. As an example, a fund’s underlying assets could have a positive performance; 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 39 of 61  however, the fund’s value could decrease due to current currency exchange rate changes. m) Legislative and Regulatory Risk Securities and investment strategies used in the Passageway account can be adversely affected by new laws or changes to existing laws or regulations. Changes to laws, regulations, or government policies can impact the securities markets as a whole, specific industries, individual issuers of securities, and individual securities. These changes can affect the value, liquidity, or performance of your investments and could occur without prior notice. n) Money Market Fund Clients could lose money by investing in a money market fund. Although a money market fund generally seeks to preserve the value of a client’s investment at $1.00 per share, FTS, Portfolio Manager, and the fund cannot guarantee it will preserve the value of $1.00. A client’s investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. FTS, Portfolio Manager, NFS and its affiliates, the money market fund’s sponsor, have no legal obligation to provide financial support to money market funds and client is not to expect that the money market fund’s sponsor will provide financial support to the fund at any time. o) Municipal Bonds The municipal market is affected by adverse tax, legislative, or political changes, and by the financial condition of the issuers of municipal securities. Municipal funds normally seek to earn income and pay dividends that are expected to be exempt from federal income tax. If a fund investor is a resident in the state of issuance of the bonds held by the fund, interest dividends may also be exempt from state and local income taxes. Income that is exempt from regular federal income tax can be subject to state, local, or federal alternative minimum tax. Certain funds normally seek to invest only in municipal securities generating income exempt from both federal income taxes and the federal alternative minimum tax; however, outcomes cannot be guaranteed, and the funds sometimes generate income subject to these taxes. For federal tax purposes, a fund’s distribution of gains attributable to a fund’s sale of municipal or other bonds are generally taxable as either ordinary income or long-term capital gains. Redemptions, including exchanges, can result in a capital gain or loss for federal and/or state income tax purposes. Tax code changes could affect the municipal bond market. Tax laws are subject to change, and tax law changes or proposed changes can cause the prices of tax-exempt securities to decrease and/or affect the tax-exempt status of securities and securities that hold tax-exempt securities. p) Stock Markets and Investments Stock markets are volatile and can decline significantly in a short amount of time in response to adverse issuer, political, regulatory, market, or economic developments. Different parts of the market can react differently to these developments. Value and growth stocks can perform differently from other types of stocks. Growth stocks can be more volatile. Value stocks can continue to be undervalued by the market for long periods of time. In addition, stock investments are subject to risk related to market capitalization as well as company-specific risk. Depending on the number of factors, such as, market events, the client’s risk tolerance, and the Portfolio Manager’s investment strategy or strategies, a Portfolio Manager may not make any changes to the investment strategies, or the investments used in Passageway account even when the stock markets incur significant losses. FTS or Portfolio Managers can invest in alternative mutual funds or ETPs, which can use investment strategies that differ from the buy-and-hold strategy typical in the fund industry. Compared to a traditional mutual fund, an alternative fund typically holds more non-traditional investments and can employ more complex trading strategies. Some examples of assets that can be held in alternative mutual funds include, but are not limited to, managed futures, arbitrage, commodities, leveraged loan, global real estate, master limited partnerships, and option contracts. Clients considering a Passageway Program that utilizes alternative investments should be aware of their unique characteristics and risks. In addition to the risks listed above, 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 40 of 61  some of these risks can include, but are not limited to: • Investment Structure: An alternative mutual fund made up of other mutual funds (often referred to as “fund of funds”) can offer greater diversification than a single-strategy or even multi-strategy alternative mutual fund or traditional mutual fund. At the same time, this greater diversification can lead to a flattening of return and potentially less transparency. There can also be an inability to re-allocate or adapt in a way that is beneficial to the overall performance of a particular fund of funds. • Leverage Risk: Using derivatives, such as commodity futures and options to increase the alternative mutual fund’s combined long and short exposure creates leverage, which can magnify the alternative mutual fund’s potential for gain or loss and, therefore, amplify the effects of market volatility on the alternative mutual fund’s share price. • Liquidity Risk: Liquidity risk exists when particular investments of an alternative mutual fund or ETP would be difficult to purchase or sell, possibly preventing the alternative mutual fund or ETP from selling such illiquid securities at an advantageous time or price, or possibly requiring the alternative mutual fund or ETP to dispose of other investments at unfavorable times or prices in order to satisfy the alternative mutual fund or ETP obligations. • Strategy Risk: In addition to the usual market and investment specific risks mutual funds have, alternative mutual funds can carry additional risks from the strategies they use. For example, market- neutral funds tend to have significant portfolio turnover risk that will generally result in higher costs. Similarly, a distressed bond fund is likely to have significant credit risk. q) Tracking Error Tracking error risk generally applies to securities (such as an ETP) and investment strategies used by Portfolio Managers (such as Direct Indexing) that attempt to track a market index (such as S&P 500® Index) and the deviation of actual performance the client realizes from the performance of the market index it attempts to track. Tracking error can result from numerous factors including but not limited to trading costs, management fees, cash holdings, market conditions - particularly sudden and extreme market changes, client-imposed restrictions, imperfect weighting between the securities and the market index, and changes to the composition of the market index. It is anticipated that tracking error risk will cause the performance of a client’s Passageway account or the security or securities within a Passageway account to be less or more than the market index. r) Additional Risks For more risks specific to the underlying assets and the investment strategy used by a Portfolio Manager, please refer to the Portfolio Manager’s ADV Part 2A and the mutual fund or ETP’s prospectus. A Portfolio Manager’s ADV Part 2A and mutual funds prospectus can be requested from FTS at any time through one of FTS’ IARs. 3) Performance Based Fees FTS does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 4) Voting Client Securities FTS does not accept authority to vote proxies for Passageway client securities. As the program sponsor of Passageway, FTS does not select individual securities (e.g., stocks, bonds) on behalf of clients. Within the Passageway programs that manage individual securities, the Portfolio Managers, excluding FTS’ IARs, are designated with discretionary authority to vote proxies on behalf of the client as a part of the account management. For additional details on a specific Portfolio Manager’s proxy voting policy please refer to the Portfolio Manager’s ADV Part 2A. D. Class Actions and Other Legal Proceedings 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 41 of 61  On occasion, securities currently or previously held in a client’s account are the subject of a class action lawsuit or other legal proceedings. FTS and our IARs have no obligation to monitor or determine if securities currently or previously held by the client are subject to pending or resolved legal actions. In addition, FTS and our IARs have no duty to assess a client’s eligibility for participation in any class action settlement or other legal proceeding, nor to file or submit claims on a client’s behalf. Furthermore, FTS and our IARs have no obligation or responsibility to initiate litigation or otherwise seek to recover damages on behalf of clients who believe they have been injured by the result of actions, misconduct, or negligence of issuers whose securities the client holds. Item 7 – Client Information Provided to Portfolio Managers FTS utilizes FIWA to oversee the technology platform that aids FTS in providing the advisory services under Passageway. Therefore, FIWA has access to all client information that FTS enters into the FIWA system. Additionally, Envestnet Asset Management, Inc. has access to client information for Passageway accounts since Envestnet provides systems that FIWA oversees. This information would include, but is not limited to, client name, address, account holdings, transactional activity, net worth, risk tolerance, investment objective, tax bracket, annual income, and the Passageway program selected by the client. Portfolio Managers available in the SMA are provided with information available on NFS statements, which includes, but is not limited to, 1) client’s name, 2) account number, 3) account holdings, 4) client’s address, and 5) transactional activity, but these Portfolio Managers are not provided with a client’s social security number, net worth, phone number, or date of birth. FTB, AllianceBernstein, Aspire, BlackRock, Brinker Capital, Cantor Fitzgerald, Capital Group, FEG, Frontier, Goldman Sachs, Russell, Symmetry, Vanguard, and Wilshire are provided with information about the applicable Passageway account to manage or advise on the account, such as, account holdings, transactions, and the selected asset allocation model. However, these Portfolio Managers are not provided with personal identifiable information about the client (e.g., client name, social security number, date of birth, phone number, or address). In the Advisor Directed Program, FTS, through its IARs, acts as the Portfolio Manager, and in the Passageway One Program, FTS’ IARs can act as the Portfolio Manager. IARs servicing the client’s Advisor Directed or Passageway One Programs account have access to all applicable information related to the client. Item 8 – Client Contact with Portfolio Managers FTS does not place any restrictions on a client’s ability to contact Portfolio Managers. Clients do have the availability to discuss the management of their Passageway account with their IAR, including the activities of the Portfolio Managers. In the Advisor Directed Program, the IAR is the Portfolio Manager, and the clients have the ability to directly contact the IAR at any time. In the Passageway One Program, the IAR can act as a Portfolio Manager, and the clients have the ability to directly contact the IAR at any time. Item 9 – Additional Information A. Disciplinary Information Below are regulatory events associated with FTS for the past 10 years, but these regulatory events are not limited to FTS’ registered investment advisor. Many of these regulatory events involve FTS’ broker-dealer and not the investment advisory business of FTS. Additional regulatory events involving FTS’ broker-dealer that date further back than 10 years and additional details regarding the below listed FINRA disciplinary actions are found at https://brokercheck.finra.org/firm/summary/628. 1) FINRA – 05/08/2018 Without admitting or denying the findings, FTS consented to the findings that FTS failed to fully comply with an undertaking from a previous Acceptance Waiver and Consent entered into with FINRA in 2009. In 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 42 of 61  addition, FTS made material misstatements and omissions in approximately 77% of a sample set of 250 variable annuity exchanges randomly selected and reviewed by FINRA from among 1,431 variable annuity exchanges. Misstatements and omissions about the cost or benefits of the variable annuity exchange made the exchange appear more beneficial to the customer. FTS also failed to implement a supervisory structure reasonably designed to ensure that its registered representatives obtained and assessed accurate information about the customer’s existing and proposed variable annuities prior to affecting the exchanges. These activities did not involve FTS’ registered investment advisor, nor did it involve FTS’ Passageway Program. 2) SEC – 07/18/2023 FTS settled allegations of wrongdoing by the SEC, in which the SEC alleged that 79 municipal bond underwriting offerings sold to broker-dealers and/or registered investment advisors failed to comply with municipal bond offering disclosure requirements under Rule 15c2-12 of the Securities Exchange Act of 1934 and found that FTS’ policies and procedures weren’t reasonably designed to determine if the broker dealers and/or registered investment advisors satisfied the exemption requirements under Rule 15c2-12. FTS agreed to cease-and-desist from future violations of those provisions, be censured, and pay $442,465.59 in disgorgement plus prejudgment interest of $67,506.09 to the SEC and a $200,000 civil money penalty. Additional details regarding this Order are found at https://www.sec.gov/files/litigation/admin/2023/34-97937.pdf. These activities did not involve FTS’ registered investment advisor, nor did it involve FTS’ Passageway Program. 3) SEC – 09/29/2023 FTS settled allegations of wrongdoing by the SEC, where from January 2019 to 2022, FTS employees sent and received Off-Channel Communications that related to the business of the broker-dealer and registered investment advisor. Due to the fact that these communications were not sent or received on FTS systems, FTS failed to surveil, maintain, or preserve these communications. As a result, FTS was required to cease- and-desist from further violation of SEC Rules related to retention of required books and records, pay a civil money penalty in the amount of $8,000,000, and take remedial measures including the hiring of an independent consultant. Additional details regarding this Order are found at https://www.sec.gov/files/litigation/admin/2023/34-98627.pdf. B. Other Financial Industry Activities and Affiliations 1) Fifth Third Securities - Broker-Dealer & Municipal Advisor FTS is registered both as a broker-dealer with FINRA and as a registered investment advisor and municipal advisor with the SEC (registration does not imply a certain level of skill or training). Principal executive officers of the broker-dealer are also officers of the registered investment advisor. IARs of FTS also act as brokerage representatives of FTS, and they solicit other services and products separate from the investment advisory services provided through Passageway. When an IAR acts in the capacity of a brokerage representative, they receive compensation for these separate activities done under FTS’ broker-dealer. Clients are under no obligation to engage FTS and our IARs for these separate brokerage products and services. 2) Related Entities a) Fifth Third Bank, National Association (FTB) FTS is a wholly owned subsidiary of FTB. FTB is a federally chartered institution and is not a registered investment advisor under the U. S. Securities & Exchange Commission. It is anticipated that FTB will benefit from the compensation for services provided through Passageway. In addition, FTS IARs can recommend or refer clients to FTB, where FTB provides investment advisory services. These services are separate from the advisory accounts and services offered by FTS. If a client opens an investment advisory account with FTB based on a recommendation or referral from FTS or an FTS IAR, FTS and our IAR(s) receive ongoing compensation from FTB. The processes, procedures, and 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 43 of 61  documentation required to open and maintain an account with FTB also differ from those of FTS and may be less burdensome than FTS’ requirements. These compensation arrangements, along with the differences in processes and requirements, create conflicts of interest for both FTS and our IARs. To help mitigate these conflicts of interest, FTB performs supervisory reviews of recommendations and referrals made by FTS and our IARs to validate that such recommendations are based on the client’s individual needs and best interest, rather than on the compensation received by FTS and our IARs. b) Fifth Third Insurance Agency, Inc. (FTIA) FTIA is a licensed insurance agency, which is a wholly owned subsidiary of FTB. FTS’ IARs act as insurance agents for Fifth Third Insurance Agency. FTS and its IARs offer insurance products and services to advisory clients outside of Passageway accounts. Clients are under no obligation to engage FTIA or its insurance agents for these separate services and products for which a customary commission is received. These insurance products are separate from Passageway and are not considered managed assets within Passageway. c) Franklin Street Advisors, Inc. (Franklin Street Advisors) Franklin Street Advisors is a registered investment advisor that is a wholly owned subsidiary of FTB and is an affiliated entity of FTS. Franklin Street Advisors is not a Program Manager currently available in the Passageway Program; therefore, FTS does not consider the affiliated entity, Franklin Street Advisors, a conflict of interest to Passageway clients or prospective clients. FTS operates independently from Franklin Street Advisors, although the two entities share certain resources, such as technology applications and other support services provided through Fifth Third Bank. d) Fifth Third Wealth Advisors, LLC (FTWA) FTWA is a wholly owned, indirect subsidiary of FTB and an adviser registered with the U.S. Securities and Exchange Commission. FTWA is not a Program Manager currently available in the Passageway Program; therefore, FTS does not consider the affiliated entity, FTWA, a conflict of interest to Passageway clients or prospective clients. FTS operates independently from FTWA, although the two entities share certain resources, such as technology applications and other support services provided through Fifth Third Bank. e) Comerica Securities, Inc. (Comerica Securities) Comerica Securities is a wholly owned subsidiary of FTB and is a broker-dealer and member FINRA/SIPC. Comerica Securities is not a Program Manager available in the Passageway Program and currently does not provide investment advisory services to retail customers; therefore, FTS does not consider the affiliated entity, Comerica Securities, a conflict of interest to Passageway clients or prospective clients. The two entities share certain resources, such as technology applications and other support services provided through Fifth Third Bank. C. Additional Conflicts of Interest Conflicts of interest related to FTS and its affiliated entities are listed under Item 9.B. Other Financial Industry Activities and Affiliations. Below are conflicts of interests that FTS has when we offer and provide services under the Passageway Program. 1) Conflicts Related to Active Trading and No Charge Investments: FTS does not charge Passageway clients a ticket charge or commission for securities transactions placed in a Passageway account. However, FTS is charged by NFS for securities transactions of certain investments in Passageway accounts. Therefore, FTS has an incentive to lower or limit the number of securities transactions in investments that NFS charges FTS. To help mitigate this conflict of interest, FTS’ IARs and Portfolio Managers do not directly share in the costs of securities transactions when they are placed in a Passageway account, nor does FTS notify IARs of which investments NFS charges FTS. 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 44 of 61  2) Conflicts Related to IAR Compensation FTS’ IARs are compensated based on the accounts that the IAR services. Please refer to Item 4.E. IAR Compensation for more information regarding additional conflicts of interest related to IAR Compensation. The amount of compensation received by FTS and its IARs, as a result of the client’s participation in the Passageway Program, can be more than what FTS and its IAR would receive if the client paid separately for investment advice, brokerage, and other services. Therefore, FTS and its IARs have a financial incentive to recommend the Passageway Program over other investments or services. A conflict of interest exists for an IAR when they recommend a Passageway program to a client. An IAR has a conflict of interest when recommending a Passageway program where the internal fee is lower than another Passageway program since the IAR will receive more compensation as a result (see Item 4.C. Investment Advisory Fee Information for more information about this conflict of interest). 3) Conflicts Related to IAR Production Standards As part of an IAR’s continued registration and/or employment with FTS, FTS has established minimum production standards based upon the tenure of the IAR with FTS. Failure by an IAR to meet FTS’ minimum production standards results in an evaluation of the overall performance and activity of the IAR, which can lead to the deregistration and/or termination of employment. To help mitigate this conflict of interest, when an IAR does not meet the production standards, FTS does not automatically deregister or terminate the employment of the IAR, but first FTS conducts and evaluation to help determine the rationale for the IAR’s current production. The evaluation can include but is not limited to the workplace behaviors (e.g., showing up to the office, hours being worked), frequency of contact with clients, client follow-ups, personal events (e.g., death of a family member), and other activities related to the IAR’s work activities. 4) Conflict Related to Recommending Passageway Account vs. Compass Account FTS IARs must satisfy certain eligibility requirements to offer and provide investment advisory services through Compass. Accordingly, an IAR who does not meet the additional eligibility criteria established by FTS has a conflict of interest when recommending Passageway or Summit instead of Compass, as the IAR would not be authorized to provide advisory services through Compass. 5) Conflicts Related to Recommending Passageway Account vs. Brokerage Account Due to the on-going relationship and the advisory fees associated with a Passageway account, FTS and FTS’ IARs have a financial conflict of interest when recommending a Passageway Account over a Brokerage Account as FTS and FTS IARs have the possibility to earn more compensation than they potentially would in a Brokerage Account. FTS helps address this conflict by having a separate group of securities registered principals that review the solicited Passageway Accounts by IARs, and these registered principals do not directly receive compensation from the recommendations made by FTS’ IARs. Furthermore, FTS helps address this conflict by requiring FTS’ IARs to complete paperwork with clients when recommending the opening of a new Passageway Account. This paperwork outlines the types of services the client is seeking (e.g., on-going reviews of accounts and assets). Clients who are not seeking to have FTS or FTS’ IARs to provide on-going management of their account, should not open a Passageway Account. 6) Conflicts Related to Mutual Fund Revenue Sharing FTS has fee arrangements with some mutual fund companies (which also includes companies that offer ETPs) that issue mutual funds that are available for purchase in the Passageway Program. These payments often referred to as “revenue sharing.” However, each of these revenue sharing arrangements with mutual fund companies (which also includes companies that offer ETPs) are solely related to FTS’ Institutional Brokerage business and do not apply to the mutual funds held in Passageway accounts. Under these revenue sharing arrangements, the mutual fund company can pay FTS a fee based that is based off: 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 45 of 61  1. The amount of client sales; 2. Assets invested in the mutual company’s mutual funds; and/or 3. A fixed fee. The actual amounts that FTS receives can vary from one mutual fund company to another and can have a minimum dollar amount prior to FTS being eligible to receive a revenue sharing payment. In all cases, such revenue sharing payments will be paid to FTS from the mutual fund company’s own resources and not directly from client funds or assets. Such arrangements will have no impact on the fees being charged to clients by FTS, the IAR, or the Portfolio Manager(s). FTS provides marketing support to the mutual fund company and allows the mutual fund company to access FTS’ IARs so that the mutual fund company can promote their mutual funds. This revenue share arrangement creates a conflict of interest by incentivizing FTS to have clients invest in mutual funds that provide revenue share instead of mutual funds that do not make revenue sharing payments to FTS. FTS does not share revenue sharing payments with Portfolio Managers, and therefore, there is no direct financial incentive for a Portfolio Manager to select a mutual fund for a Passageway account over another mutual fund because of FTS’ revenue sharing arrangement. Furthermore, FTS does not directly share revenue sharing payments with its IARs. Since FTS’ IARs receive no direct portion of the revenue share that is received by FTS, FTS does not believe its IARs have a conflict of interest when selecting one mutual fund over another mutual fund as a result of these revenue sharing arrangements. Lastly, in order to mitigate this conflict of interest, currently FTS does not receive revenue share payments on any of the assets in mutual funds that are held in Passageway accounts. Please visit the bottom of https://www.53.com/investments/mutual-funds.html for the list of the mutual fund companies that FTS has a revenue sharing arrangement. 7) Conflicts Related to Interest on Cash Holdings NFS shares credit interest compensation with FTS on cash balance holdings held in Passageway accounts. To help mitigate this conflict of interest, FTS requires clients to select a core account investment vehicle (a/k/a sweep option) for available cash balances instead of allowing the Passageway account to remain in cash. Even when a client selects a core account investment vehicle, there are situations when a Passageway account will still end up holding a cash balance. As a result, FTS will receive credit interest from this cash balance holding. Additionally, we do not directly share with IARs the credit interest income received from cash holdings in a Passageway account, and lastly, the interest earned on cash holdings in a Passageway account that FTS receives from NFS are reimbursed directly to the client’s Passageway account. These reimbursements for cash holdings occur in the same quarter or the following quarter that FTS receives the interest from NFS. Furthermore, FTS Clients can select an available core account investment vehicle or change the core account investment vehicle at any time for their Passageway Account by contacting their IAR. Additional information regarding the available investment options for your core account investment vehicle can be found at 53.com/ftsdisclosure under “Core Account Investment Vehicle Disclosure Summary”. 8) Conflicts Related to Clearing Firm (NFS) a) No Cost Transactions As mentioned above in Item 4.C., FTS pays NFS clearance and execution fees for trades placed in Passageway accounts. These clearance and execution fees are in part based upon the type of security involved in the transaction (e.g., listed equity, over-the-counter equities, municipal bonds, mutual funds, etc.). However, NFS makes transactions in certain mutual funds and ETPs available to FTS at no cost if the mutual fund or ETPs is part of NFS’ NTF Mutual Funds Program, NTF Managed Account Program, and iNTF Managed Account Program. The availability of no cost transactions creates a conflict of interest for FTS by providing the availability to have transactions in certain mutual funds and ETPs at no cost while transactions in other mutual funds and ETPs not part of NFS’ NTF Mutual Funds Program, NTF Managed Account Program, and 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 46 of 61  iNTF Managed Account Program are assessed a charge or fee. To help mitigate this conflict of interest, FTS does not distribute to IARs the list of mutual funds and ETPs on NFS’ NTF Mutual Funds Program, NTF Managed Account Program, and iNTF Managed Account Program. Furthermore, FTS has contracted with FIWA to perform initial and ongoing due diligence on some or all the mutual funds and ETPs available in the Passageway Program, which includes all of the mutual funds and ETPs that are available on NFS’ NTF Mutual Funds Program, NTF Managed Account Program, and iNTF Managed Account Program. FTS conducts additional due diligence on the mutual funds and ETPs after FIWA has approved or continues to approve the mutual funds and ETPs. b) NFS Credits & Discounts NFS provides FTS with credits in the form of receipt of payment to FTS and the offset or reduction of fees and expenses owed by FTS to NFS when FTS meets certain criteria established by NFS. These credits include singular or infrequent credits (e.g., credit as part of contract renewal or update) and recurring credits at (e.g., monthly, or annual intervals). One of these credits is calculated based on net flows to NFS, defined as incoming cash and securities transfers less outgoing transfers. Accordingly, FTS has conflicts of interest in both promoting transfers of cash and securities to NFS and retaining those assets with NFS. This credit excludes cash and securities associated with the Deconversion Credit referenced below. FTS’ receipt of these NFS credits represents a conflict of interest. To help mitigate the conflict of interest these credits create, FTS and NFS have limited the criteria that have to be met by FTS to receive these credits. For example, the receipt of these credits are not dependent on the amount of assets FTS has with NFS, the amount or volume of transactions placed through NFS, the amount of charges/fees assessed by NFS to FTS, any commissions earned by NFS for placement of trades, the number of clients or accounts FTS has with NFS (with the exception of the Deconversion Credit), and does not prevent FTS to place a security transaction or transactions through another firm if FTS believes it is in the client’s best interest. In addition, in connection with Fifth Third Bancorp’s acquisition of Comerica Incorporated and its subsidiaries, including Comerica Bank, N.A., NFS will provide FTS with: (1) a one-time credit to offset costs associated with the conversion of accounts and assets from Ameriprise Financial Services, LLC (“Ameriprise”) to NFS (the “Deconversion Credit”), (2) an increase to an existing annual credit provided by NFS to FTS, and (3) discounted fees from NFS’s affiliated entity, Fidelity Institutional Wealth Adviser LLC, for investment advisory accounts. The Deconversion Credit is contingent on the volume of assets and accounts transferred. If the transferred assets and accounts fall below a specified threshold, NFS will not provide the Deconversion Credit. Additionally, if a specified percentage or more of the assets and accounts transferred to NFS in connection with this conversion are subsequently moved away from NFS within a defined period after the conversion, FTS is to negotiate with NFS to determine whether FTS will reimburse a portion of the Deconversion Credit. As a result, FTS has conflicts of interest related both to encouraging the transfer of accounts and assets from Ameriprise to NFS and to retaining those accounts and assets after the transfer. To help mitigate these conflicts, the Deconversion Credit is not tied to the transfer of specific asset types and does not depend on future transactions occurring at NFS. 9) Conflicts Related to Receipt of Educational, Marketing, & Other Financial Support FTS and our IARs have a conflict of interest as a result of when Portfolio Managers, service providers, and products companies, such as mutual fund companies, unit investment trust sponsors, annuity companies, life insurance companies, ETP companies, or their affiliates, reimburse or cover the costs for FTS and/or our IARs for the following activities: marketing, business and client development, educational enhancement, and/or due diligence reviews incurred by FTS and/or an IAR related to the promotion or sale of the Portfolio Manager services or product company’s products (e.g., mutual fund, ETP). This compensation is also used to subsidize the cost of education programs, such as conferences we offer to our IARs, which include travel and travel-related expenses, meals, overnight lodging, speakers, and entertainment. 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 47 of 61  Portfolio Managers, products companies, and service providers that participate in these events gain the opportunity to interact with our IARs and their supervisors, and it is anticipated that these interactions will result in additional sales of those products or services associated with those Portfolio Managers and product companies. Accordingly, a conflict of interest exists where we offer opportunities to Portfolio Managers, products companies, and service providers that are willing to cover expenses and/or pay us to cover expenses as compared to Portfolio Managers, products companies, and service providers that do not. IARs do not directly receive a portion of this compensation. However, IARs’ attendance and participation in these events can be expected to lead IARs to recommend and direct investments to the Portfolio Managers, products companies, and service providers that provide this compensation as compared to Portfolio Managers, products companies, and service providers that do not. 10) Conflicts Related to Receipt of Gifts and Business Entertainment: IARs can receive business entertainment from product or service providers. Examples of business entertainment include, but are not limited to, an occasional meal or a ticket to an event (e.g., concert, game, local event). This creates a conflict of interest for the IAR where the IAR recommends the product or Portfolio Manager associated with the company who has provided the business entertainment. To help mitigate this conflict, FTS generally limits the amount of business entertainment that can be received by its IARs per product or service company when the business entertainment is not associated with training, an FTS meeting, or a meeting with an FTS client. This limit does not apply to business entertainment of de minimis value as long as the value of the business entertainment received is below $40. Additionally, IARs can receive gifts from product companies and Portfolio Managers. This creates a conflict of interest for the IAR where the IAR recommends the product or Portfolio Manager associated with the company who has provided the gift. To help mitigate this conflict, FTS and regulatory rules prohibit the receipt of gifts over a set limit per company and per calendar year. IARs are required to report to FTS when they receive a gift that was provided by a product or service company with the exception of promotional items of small dollar value (e.g., water bottle with the company logo on the bottle, pens, notebooks, t-shirt). 11) Conflicts Related to the AllianceBernstein Program AllianceBernstein makes investment recommendations and model recommendations that include mutual funds and/or ETFs made available, issued, advised, and/or sub-advised by AllianceBernstein or affiliated entity(ies) of AllianceBernstein . AllianceBernstein does not limit the available investment options to mutual funds and ETFs offered by or affiliated entity of AllianceBernstein but include other mutual funds and/or ETFs of non-affiliated entities. This creates a financial incentive for AllianceBernstein to recommend AllianceBernstein affiliated mutual funds and ETFs over mutual funds and ETFs issued by non-affiliated entities of AllianceBernstein. By recommending investments within the AllianceBernstein Program, and therefore the client’s account, this can limit the growth potential of client’s account(s) and/or increase the risk of the client’s account(s) that can lead to greater losses if other investment options were available or were invested. 12) Conflicts Related to the BlackRock Program BlackRock makes investment recommendations and model recommendations that include mutual funds and/or ETFs made available, issued, advised, and/or sub-advised by BlackRock or affiliated entity(ies) of BlackRock. BlackRock does not limit the available investment options to mutual funds and ETFs offered by or affiliated entity of BlackRock but includes other mutual fund and/or ETFs of non-affiliated entities. This creates a financial incentive for BlackRock to recommend BlackRock affiliated mutual funds and ETFs over mutual funds and ETFs issued by non-affiliated entities of BlackRock. By recommending the investment options that include affiliated investments within the BlackRock Program, and therefore the client’s account, this can limit the growth potential of client’s account(s) and/or increase the risk of the client’s account(s) that can lead to greater losses if other investment options were available or were invested. 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 48 of 61  13) Conflicts Related to the Brinker Capital Program Brinker Capital makes investment recommendations and model recommendations solely of Brinker Destination funds that Brinker Capital serves as the investment adviser and the funds are affiliated products of Brinker Capital. Brinker Capital limits the available investment options both initially and on an on-going basis to Brinker Destination funds. By restricting the investment options available within the Brinker Capital Program, and consequently the client’s account, this can limit the growth potential of client’s account(s) and/or increase the risk of the client’s account(s) that can lead to greater losses if other investment options were available or were invested. See Brinker’s Form ADV Part 2A for more information. 14) Conflicts Related to the Capital Group Program Capital Group makes investment recommendations and model recommendations that include mutual funds and/or ETFs that are distributed by Capital Group or an affiliated entity for which Capital Group or the affiliated entity serves as the investment adviser. Capital Group does not limit the available investment options to mutual funds and ETFs offered by or affiliated entity of Capital Group but include other mutual fund and/or ETFs of non-affiliated entities. This creates a financial incentive for Capital Group to recommend Capital Group affiliated mutual funds and ETFs over mutual funds and ETFs issued by non-affiliated entities of Capital Group. By recommending the investment options that include affiliated investments within the Capital Group Program, and therefore the client’s account, this can limit the growth potential of client’s account(s) and/or increase the risk of the client’s account(s) that can lead to greater losses if other investment options were available or were invested. See Capital Group’s Form ADV Part 2A for more information. 15) Conflicts Related to the John Hancock Program Manulife makes investment recommendations and model recommendations that include mutual funds and/or ETFs made available, issued, advised, or sub-advised by Manulife or affiliated entity(ies) of Manulife. Manulife does not limit the available investment options to mutual funds and ETFs offered by or affiliated entity of Manulife but include other mutual fund and/or ETFs of non-affiliated entities. This creates a financial incentive for Manulife to recommend Manulife affiliated mutual funds and ETFs over mutual funds and ETFs issued by non-affiliated entities of Manulife. By recommending the investment options that include affiliated investments within the John Hancock Program, and therefore the client’s account, this can limit the growth potential of client’s account(s) and/or increase the risk of the client’s account(s) that can lead to greater losses if other investment options were available or were invested. See Manulife’s Form ADV Part 2A for more information. 16) Conflicts Related to the Russell Program Russell makes investment recommendations and model recommendations solely of funds that are made available by affiliated entity Russell Investment Company that Russell serves as the investment adviser and the funds are affiliated products of Russell. Russell limits the available investment options both initially and on an on-going basis to funds of Russell Investment Company. By restricting the investment options within the Russell Program, and therefore client’s account, this can limit the growth potential of client’s account(s) and/or increase the risk of the client’s account(s) that can lead to greater losses if other investment options were available or were invested. See Russell’s Form ADV Part 2A for more information. 17) Conflicts Related to the Symmetry Program Symmetry makes investment recommendations and model recommendations that will include mutual funds and/or ETFs made available, issued, advised, or sub-advised by Symmetry or affiliated entity(ies) of Symmetry. Depending on the selected strategy, Symmetry-affiliated funds can constitute up to 100% of the investments held in a client’s account. By restricting the investment options within the Symmetry Program, and therefore client’s account, this can limit the growth potential of client’s account(s) and/or increase the risk of the client’s account(s) that can lead to greater losses if other investment options were available or were invested. See Symmetry’s Form ADV Part 2A for more information. 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 49 of 61  18) Conflicts Related to the Vanguard Program Vanguard makes investment recommendations and model recommendations solely or primarily of mutual funds and ETFs made available, issued, advised, or sub-advised by Vanguard or affiliated entity(ies) of Vanguard. Vanguard limits the available investment options both initially and on an on-going basis to mutual funds and ETFs offered by Vanguard or affiliated entity(ies) of Vanguard. By restricting the investment options within the Vanguard Program, and therefore the client’s account, this can limit the growth potential of client’s account(s) and/or increase the risk of the client’s account(s) that can lead to greater losses if other investment options were available or were invested. See Vanguard’s Form ADV Part 2A for more information. 19) Conflicts Related to the Voya Program Voya makes investment recommendations and model recommendations that will include mutual funds and/or ETFs made available, issued, advised, or sub-advised by Voya or affiliated entity(ies) of Voya. Depending on the selected strategy, Voya-affiliated funds can constitute up to 100% of the investments held in a client’s account. By restricting the investment options within the Voya Program, and therefore client’s account, this can limit the growth potential of client’s account(s) and/or increase the risk of the client’s account(s) that can lead to greater losses if other investment options were available or were invested. See Voya’s Form ADV Part 2A for more information. 20) Conflicts Related to the Tax Overlay Service The Tax Overlay Service is an added service (if selected by the client), and as a result, carries an additional fee that is assessed to FTS. As a result, the Tax Overlay Service fee decreases the total amount of fees that FTS and our IARs receive when a client chooses to use the Tax Overlay Service. Therefore, FTS and our IARs have a conflict of interest associated with the Tax Overlay Service, because there is a financial incentive not to provide the Tax Overlay Service. D. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 1) Code of Ethics FTS has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. FTS' Code of Ethics is based upon the principle that FTS and its employees owe a fiduciary duty to clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with the firm and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. The Code of Ethics is designed to help maintain the high ethical standards long maintained by FTS continue to be applied. The purpose of the Code of Ethics is to preclude activities which lead to or give the appearance of conflicts of interest, insider trading and other forms of prohibited or unethical business conduct. FTS’ fiduciary duty means that FTS has an affirmative duty of utmost good faith to act solely in the best interest of its clients. FTS and its employees are subject to the following specific fiduciary obligations when dealing with investment advisory clients: • The duty to have a reasonable, independent basis for the investment advice provided; • The duty to help confirm that investment advice is suitable to meeting the client’s individual investment objectives, needs and circumstances; and • A duty to be loyal to clients. To implement the Code of Ethics, all FTS access persons are required to acknowledge their receipt of the FTS’ Code of Ethics. FTS’ IARs are further subject to specific personal securities transactions and holdings reporting requirements. FTS’ IARs are prohibited from buying or selling securities (or related securities such as warrants, options, or futures) either prior to or subsequent to submitting a trade for a Passageway client with the intent to benefit from a price fluctuation generated from the Passageway client’s trade. Nevertheless, FTS’ IARs can invest in the same securities (or related securities such as warrants, options, or futures) that they recommend to 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 50 of 61  Passageway clients. Our IARs can also recommend securities to Passageway clients at or about the same time as our IARs buy or sell the same securities in their personal accounts. This creates a potential conflict of interest, including the risk that our IARs’ personal trading could influence, or appear to influence, investment recommendations, or that our IARs’ personal trades could receive more favorable timing or pricing than trades for Passageway clients. To help address these conflicts, FTS’ IARs are required to adhere to FTS’s Code of Ethics outlined above that emphasizes our IARs’ fiduciary duty to avoid serving their own personal interests ahead of our clients. FTS’ IARs are also subject to specific personal securities transactions and holdings reporting requirements, and FTS reviews these transactions and holdings reports. FTS’ IARs are prohibited from purchasing initial public offerings in their own personal accounts under FTS’ Code of Ethics, and our IARs must receive pre-clearance before investing in private securities offerings (e.g., Regulation D offerings). FTS’ Code of Ethics further includes the FTS policy prohibiting the use of material non-public information. FTS requires that all access persons must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. Any individual not in observance of the above may be subject to termination or other disciplinary actions. Advisory clients or prospective advisory clients can receive the full version of FTS’ Code of Ethics by making a written request to: Fifth Third Securities, Inc. Attn: Compliance Department 38 Fountain Square Plaza MD: 1090XB Cincinnati, OH 45263 E. Review of Accounts FTS’ IARs periodically review client Passageway accounts. Reviews by IARs can include the client’s current asset allocation, the managed securities in the Passageway account, and the Portfolio Manager, if the Portfolio Manager is not the IAR. In addition, IARs will generally attempt to meet with Passageway clients each calendar year and review their financial and investment goals, risk tolerance, and other information relevant to maintaining an appropriate investment strategy for the client, as well as review the investment management of the Passageway account. These reviews with Passageway clients can be conducted in-person, telephonically, or by a videoconferencing system (e.g., Microsoft Teams). Generally, if FTS is unable to conduct a review with a Passageway client for two consecutive calendar years, FTS will commence with termination of the advisory relationship with the Passageway client in the third year unless a review with the client is able to occur. However, FTS understands that in certain client situations meeting with an FTS IAR may not be practical and in those circumstances (e.g., military service member deployed overseas), FTS can choose not to terminate the advisory relationship with the Passageway client. Portfolio Managers periodically review Passageway accounts. These reviews by Portfolio Managers will sometimes result in rebalancing a Passageway account back to or a close approximate of the asset allocation selected by the client. For more information regarding a specific Portfolio Manager’s review of accounts please refer to their Form ADV Part 2A. F. Quarterly Performance Reports On a quarterly basis, FIWA sends Passageway clients a statement containing a description of the activity that occurred in the client’s account(s) during the previous quarter including, but not limited to, the following: • Securities holdings • Account value 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 51 of 61  • Transactions occurred in the account, including contributions and withdrawals • Investment advisory fees charged for the period FTS does not independently verify the accuracy of the performance information provided by FIWA on client quarterly performance reports. In addition, clients receive either monthly statements from NFS if securities transactions (e.g., purchases, sales, or transfers) occur in the Passageway account or quarterly statements from NFS if no transactions occur in the Passageway account. FTS strongly recommends clients to compare the holdings and transactions listed on NFS statements against the quarterly performance reports provided by FIWA. The client should promptly alert their IAR or FTS if the client identifies any discrepancies between these statements. FIWA performance statements reflect a trade-date basis, and NFS statements reflect a settlement-date basis. This means transactions that occur at the end of a quarter that have not settled will appear on the FIWA statement but will not appear on the NFS statement. When FTS or a client terminates the Investment Management Agreement and the corresponding Passageway account, the client will not receive a quarterly performance report for the quarter in which the Passageway account was terminated. G. Client Referrals and Other Compensation FTS currently does compensate individuals who are securities registered with FTS for qualified client referrals to FTS. To qualify for the referral fee the following conditions must be met: 1) the client is not an existing client of FTS at the time of the referral, 2) the client agrees to and has an appointment with a Registered Representative of FTS, and 3) the client has a minimum of $50,000 in investable assets. If these three conditions are met, individuals who are securities registered with FTS would receive a $25 referral fee. A referral fee is not contingent upon the client opening an account (Investment Advisory or Brokerage), purchasing any security or investment, or FTS receiving any type of compensation from the client or their investable assets. FTS pays on-going compensation to IARs who are made available to some Passageway clients to assist with their Passageway account when their primary IAR is unavailable. Assistance provided by these IARs will generally be around the administration of the accounts, such as Passageway account balance inquiries, specific information requests about the client’s Passageway account holdings (e.g., current value of a security, date(s) when a specific security was purchased or sold, prospectus request, etc.), and information about Portfolio Managers, as applicable. Assistance to Passageway clients would not include specific Passageway recommendations, recommendations to change Investment Advisory Programs, or asset allocation changes to an existing Passageway account without the involvement of the primary IAR. These IARs that receive the nominal fee are registered as IARs with FTS and applicable clients will receive a copy of the IAR’s Investment Advisory Supplemental Brochure (Form ADV 2B) in addition to their primary IAR’s Investment Advisory Supplemental Brochure. 1) FTS Education Summit Each year, FTS holds an educational meeting to provide enhanced training for our top Financial Professionals, including our IARs. FTS provides travel, food, entertainment, lodging accommodations, and other expenses for our Financial Professionals who are invited to the FTS Education Summit. FTS generally invites the Financial Professionals who have produced the most revenue based upon the specific role of the Financial Professional. Criteria for qualifying for an invitation to the FTS Education Summit can change from year-to-year, but it is anticipated that the criteria will generally involve the overall performance of the IAR. 2) FTB President’s Circle Each year, FTB holds the President’s Circle meeting for top-performing FTB employees based upon role, including our IARs. Invitation to the FTB President’s Circle is generally based on the overall revenue to FTB 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 52 of 61  for a period of time. The revenue counted towards being invited to the FTB’ President’s Circle includes revenue associated with FTS’ transactions and accounts. FTS generally has no final determination for the criteria of the FTB’s President’s Circle, but FTS does have input as to the general structure to help ensure that the criteria complies with FTS’ standards and regulatory rules. IARs who are not invited cannot attend the FTS Education Summit or FTS President’s Circle. These factors create a conflict of interest for IARs if they would like to be invited to these events. To help mitigate this conflict, FTS employs a separate group of principals who generally review the recommendations of IARs that result in securities transactions or opening investment advisory accounts. Additionally, criteria for an invitation to these events is not based solely on the revenue of a single product, product or service type, and the time period in which the overall revenue is based will be for a longer period of time (generally between 9-12 months). 3) Area and Regional Meetings IARs can also receive recognition in area and/or regional meetings. Examples of recognition can include verbal recognition, trophies, plaques, or other physical awards. H. Financial Information 1) Balance Sheet FTS is not required to provide a balance sheet with this Brochure because we do not solicit prepayment of more than $1,200 in fees per client, six months or more in advance. 2) Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients FTS is not aware of any financial impairment that will preclude us from meeting our contractual commitments to our advisory clients. 3) Bankruptcy Petitions in Previous Ten Years FTS has not been the subject of a bankruptcy petition in the last ten years. (Remainder of the Page Intentionally Left Blank) 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 53 of 61  Appendix A Step Out Transactions by Portfolio Manager Average Commission - Cents per share (CPS)+ 2025 Approximate % of Step Out Client Trades+ Alliance Bernstein AB Large Cap Growth N/A N/A AB Municipal Income SMA 77% $0 AB Strategic Research Balanced (non-CISH) 0% $0 AB Strategic Research Balanced - CISH 0% $0 AB Sustainable Global Thematic ADR N/A N/A 2025 Approximate % of Step Out Client Trades+ Average Commission - Cents per share (CPS) (Information below was provided by FIWA) Fidelity Institutional Wealth Adviser/Envestnet AB Concentrated Growth 0.00% AB Dynamic Multi-Asset Income 0/100 0.00% AB Dynamic Multi-Asset Income 20/80 0.14% AB Dynamic Multi-Asset Income 40/60 0.22% AB Dynamic Multi-Asset Income 60/40 0.10% AB Large Cap Growth 0.00% AB Sustainable Global Thematic ADR 0.00% Aspire Core 20/80 Income Focused ETF MAP 0.00% Aspire Core 30/70 Income Focused ETF MAP 3.19% Aspire Core 40/60 Balanced ETF MAP 0.13% Aspire Core 50/50 Balanced ETF MAP 0.41% Aspire Core 60/40 Balanced ETF MAP 5.41% Aspire Core 70/30 Growth ETF MAP 5.88% Aspire Core 80/20 Growth ETF MAP 13.06% Aspire Core 90/10 Growth ETF MAP 3.97% $0 - 0.0503 CPS BlackRock 100/0 Global Allocation (GA) Selects 54.92% BlackRock 20/80 Global Allocation (GA) Selects 36.54% BlackRock 20/80 Global Allocation (GA) Selects Tax-Aware 35.13% BlackRock 40/60 Global Allocation (GA) Selects 46.93% BlackRock 40/60 Global Allocation (GA) Selects Tax-Aware 50.26% BlackRock 60/40 Global Allocation (GA) Selects 63.46% BlackRock 60/40 Global Allocation (GA) Selects Tax-Aware 60.12% BlackRock 80/20 Global Allocation (GA) Selects 66.68% BlackRock 80/20 Global Allocation (GA) Selects Tax-Aware 61.48% BlackRock Capital Appreciation SMA 0.00% BlackRock Equity Dividend SMA 0.29% BlackRock Large Cap Core SMA 0.00% BlackRock Large Cap Value SMA 0.00% Boston Partners All Cap Value Equity 0.00% Boston Partners Large Cap Value Managed Account 0.00% Brinker Capital Destinations Aggressive 0.00% Passageway Managed Account Wrap Fee Program Brochure Page 54 of 61 +Information provided by the Potfolio Manager.  Appendix A Step Out Transactions by Portfolio Manager Brinker Capital Destinations Aggressive (Tax-Aware) 0.00% Brinker Capital Destinations Aggressive Equity 0.00% Brinker Capital Destinations Aggressive Equity (Tax-Aware) 0.00% Brinker Capital Destinations Balanced Income 0.09% Brinker Capital Destinations Balanced Income (Tax-Aware) 0.00% Brinker Capital Destinations Conservative 0.00% Brinker Capital Destinations Conservative (Tax-Aware) 0.00% Brinker Capital Destinations Defensive 0.00% Brinker Capital Destinations Defensive (Tax-Aware) 0.00% Brinker Capital Destinations Diversified Income 0.00% Brinker Capital Destinations Diversified Income (Tax-Aware) 4.49% Brinker Capital Destinations Moderate 0.00% Brinker Capital Destinations Moderate (Tax-Aware) 0.00% Brinker Capital Destinations Moderately Aggressive 1.26% Brinker Capital Destinations Moderately Aggressive (Tax-Aware) 0.00% Brinker Capital Destinations Moderately Conservative 0.00% Brinker Capital Destinations Moderately Conservative (Tax-Aware) 0.00% Cantor Fitzgerald 11-19 Years Aggressive 0.00% Cantor Fitzgerald 11-19 Years Conservative 0.00% Cantor Fitzgerald 11-19 Years Moderate 0.00% Cantor Fitzgerald 20 Plus Years Moderate 0.00% Cantor Fitzgerald 2-5 Years Conservative 0.00% $0 - 0.0503 CPS Cantor Fitzgerald 6-10 Years Moderate 0.00% 33.00% 1.47% Cantor Fitzgerald ESG 11-19 Years Capital Group Active-Passive Conservative Growth and Income Model (F3) Capital Group Active-Passive Conservative Income and Growth Model (F3) 2.36% Capital Group Active-Passive Conservative Income Model (F3) 0.00% Capital Group Active-Passive Conservative Income Model 1.83% Capital Group Active-Passive Global Growth Model (F3) 0.00% Capital Group Active-Passive Global Growth Model 3.15% Capital Group Active-Passive Growth and Income Model (F3) 0.00% Capital Group Active-Passive Growth and Income Model 1.62% Capital Group Active-Passive Growth Model (F3) 0.00% Capital Group Active-Passive Growth Model 4.61% Capital Group Active-Passive Moderate Growth and Income Model (F3) 0.00% Capital Group Active-Passive Moderate Growth and Income Model 3.26% Capital Group Active-Passive Moderate Growth Model 3.54% 0.28% Capital Group Active-Passive Preservation Model (F3) Capital Group Active-Passive Retirement Income Model - Conservative (F3) 0.00% Capital Group Active-Passive Retirement Income Model - Conservative 0.49% Capital Group Active-Passive Retirement Income Model - Enhanced (F3) 0.00% Passageway Managed Account Wrap Fee Program Brochure Page 55 of 61 +Information provided by the Potfolio Manager.  Appendix A Step Out Transactions by Portfolio Manager Capital Group Active-Passive Retirement Income Model - Enhanced 0.10% Capital Group Active-Passive Retirement Income Model - Moderate (F3) 0.00% Capital Group Active-Passive Retirement Income Model - Moderate 2.40% ClearBridge Dividend Strategy Portfolios 0.00% ClearBridge Large Cap Growth ESG Portfolios 0.83% ClearBridge Large Cap Growth Portfolios 0.75% ClearBridge Large Cap Value Portfolios 0.00% ClearBridge Mid Cap Portfolios 0.00% Columbia Contrarian Core 0.00% Dana Catholic ESG Equity 0.00% Dana Concentrated Dividend Equity 0.00% Dana Large Cap Equity 0.00% Dana Small Cap Equity 0.00% Federated Strategic Value Dividend Managed Account 0.00% FEG Balanced Portfolio 0.09% FEG Capital Preservation 0.00% FEG Diversifying Strategies Portfolio 2.71% FEG Equity Portfolio 1.78% FEG Fixed Income Portfolio 0.00% FEG Income & Growth 0.45% FEG Moderate Growth Portfolio 0.70% FEG Moderate Portfolio 0.04% $0 - 0.0503 CPS Fiera All Cap Growth Managed Account 0.00% Fiera Large Cap Growth Managed Account 0.00% Fiera SMID Growth Managed Account 0.00% First Trust Morningstar Multi-Discipline 60/40 Managed Account 0.00% Frontier Balanced Strategy 0.37% Frontier Conservative Strategy 0.00% Frontier Faith-Based Balanced Strategy 1.05% Frontier Faith-Based Conservative Strategy 0.00% Frontier Faith-Based Moderate Growth Strategy 0.99% Frontier Moderate Growth Strategy 0.00% Frontier Tax Managed Conservative Strategy 0.00% Frontier Tax Managed Moderate Growth Strategy 0.00% Goldman Sachs Multi-Manager (non-GS) 20/80 ETF Model Portfolio 39.28% Goldman Sachs Multi-Manager (non-GS) 30/70 ETF Model Portfolio 50.83% Goldman Sachs Multi-Manager (non-GS) 40/60 ETF Model Portfolio 48.08% Goldman Sachs Multi-Manager (non-GS) 50/50 ETF Model Portfolio 45.04% Goldman Sachs Multi-Manager (non-GS) 60/40 ETF Model Portfolio 48.94% Goldman Sachs Multi-Manager (non-GS) 70/30 ETF Model Portfolio 53.99% Goldman Sachs Multi-Manager (non-GS) 80/20 ETF Model Portfolio 48.28% 45.35% Goldman Sachs Multi-Manager (non-GS) 90/10 ETF Model Portfolio Goldman Sachs Multi-Manager 20/80 ETF Model Portfolio 47.82% Goldman Sachs Multi-Manager 20/80 Mutual Fund Model Portfolio 0.00% Passageway Managed Account Wrap Fee Program Brochure Page 56 of 61 +Information provided by the Potfolio Manager.  Appendix A Step Out Transactions by Portfolio Manager Goldman Sachs Multi-Manager 30/70 ETF Model Portfolio 54.91% Goldman Sachs Multi-Manager 30/70 Mutual Fund Model Portfolio 0.00% Goldman Sachs Multi-Manager 40/60 ETF Model Portfolio 57.40% Goldman Sachs Multi-Manager 40/60 Mutual Fund Model Portfolio 0.00% Goldman Sachs Multi-Manager 50/50 ETF Model Portfolio 56.30% Goldman Sachs Multi-Manager 50/50 Mutual Fund Model Portfolio 0.13% Goldman Sachs Multi-Manager 60/40 ETF Model Portfolio 54.22% Goldman Sachs Multi-Manager 60/40 Mutual Fund Model Portfolio 0.03% Goldman Sachs Multi-Manager 70/30 ETF Model Portfolio 62.25% Goldman Sachs Multi-Manager 70/30 Mutual Fund Model Portfolio 0.07% Goldman Sachs Multi-Manager 80/20 ETF Model Portfolio 62.17% Goldman Sachs Multi-Manager 80/20 Mutual Fund Model Portfolio 0.00% Goldman Sachs Multi-Manager 90/10 ETF Model Portfolio 61.99% Goldman Sachs Multi-Manager 90/10 Mutual Fund Model Portfolio 0.00% Goldman Sachs S&P 4 0.69% Goldman Sachs S&P Competitive Advantage 1.31% Great Lakes Advisors Large Cap Core 0.00% Great Lakes Advisors Large Cap Value 0.00% GS Mid Cap Growth 0.00% GW&K Small/Mid Cap Core Strategy 0.00% Harding Loevner Global ADR Managed Account 2.50% Harding Loevner International ADR Managed Account 23.42% $0 - 0.0503 CPS Janus Henderson Concentrated Growth Managed Account 0.00% Janus Henderson Mid Cap Growth Managed Account 0.00% Janus Henderson Overseas ADR Managed Account 0.00% Passageway One 10.73% PMC Active Foundation - Aggressive 0.00% PMC Active Foundation - Capital Preservation 0.00% PMC Active Foundation - Conservative 0.21% PMC Active Foundation - Conservative Growth 0.55% PMC Active Foundation - Growth 0.04% PMC Active Foundation - Moderate 0.95% PMC Active Foundation - Moderate Growth 1.43% Raub Brock Dividend Growth Portfolio 0.00% Russell Inv Tax-Managed Balanced Growth Model Strategy (Class M) 0.00% Russell Inv Tax-Managed Balanced Model Strategy (Class M) Russell Inv Tax-Managed Conservative Model Strategy (Class M) 0.73% 0.00% Russell Inv Tax-Managed Equity Growth Model Strategy (Class M) 0.00% Russell Inv Tax-Managed Growth Model Strategy (Class M) 0.00% Russell Inv Tax-Managed Moderate Growth Model Strategy (Class M) 0.00% Russell Inv Tax-Managed Moderate Model Strategy (Class M) 0.00% Russell Investments Balanced Growth Model Strategy Class M 0.00% Russell Investments Balanced Model Strategy Class M 0.44% Russell Investments Conservative Model Strategy Class M 0.00% Passageway Managed Account Wrap Fee Program Brochure Page 57 of 61 +Information provided by the Potfolio Manager.  Appendix A Step Out Transactions by Portfolio Manager Russell Investments Equity Growth Model Strategy Class M 0.00% Russell Investments Growth Model Strategy Class M 0.00% Russell Investments Moderate Growth Model Strategy Class M 3.74% Russell Investments Moderate Model Strategy Class M 0.00% Symmetry Panoramic 0/100 0.00% Symmetry Panoramic 10/90 0.00% Symmetry Panoramic 100/0 0.00% Symmetry Panoramic 20/80 0.00% Symmetry Panoramic 30/70 0.00% Symmetry Panoramic 40/60 0.00% Symmetry Panoramic 50/50 0.00% Symmetry Panoramic 60/40 0.00% Symmetry Panoramic 70/30 0.00% Symmetry Panoramic 80/20 0.00% Symmetry Panoramic 90/10 0.00% Symmetry Panoramic TM 0/100 87.50% Symmetry Panoramic TM 100/0 0.00% Symmetry Panoramic TM 20/80 0.00% Symmetry Panoramic TM 30/70 0.00% Symmetry Panoramic TM 40/60 0.00% Symmetry Panoramic TM 50/50 0.00% Symmetry Panoramic TM 60/40 0.00% $0 - 0.0503 CPS Symmetry Panoramic TM 70/30 0.00% Symmetry Panoramic TM 80/20 0.00% Symmetry Panoramic TM 90/10 0.00% Symmetry PrecisionCore 0/100 3.09% Symmetry PrecisionCore 10/90 0.00% Symmetry PrecisionCore 100/0 0.00% Symmetry PrecisionCore 20/80 0.36% Symmetry PrecisionCore 30/70 1.01% Symmetry PrecisionCore 40/60 0.22% Symmetry PrecisionCore 50/50 0.20% Symmetry PrecisionCore 60/40 0.11% Symmetry PrecisionCore 70/30 0.34% Symmetry PrecisionCore 80/20 0.00% Symmetry PrecisionCore 90/10 0.00% Symmetry Tax-Managed Structured 100/0 0.00% Symmetry Tax-Managed Structured 20/80 0.00% Symmetry Tax-Managed Structured 30/70 0.00% Symmetry Tax-Managed Structured 40/60 0.00% Symmetry Tax-Managed Structured 50/50 0.00% Symmetry Tax-Managed Structured 60/40 0.00% Symmetry Tax-Managed Structured 70/30 0.00% Symmetry Tax-Managed Structured 80/20 0.00% Passageway Managed Account Wrap Fee Program Brochure Page 58 of 61 +Information provided by the Potfolio Manager.  Appendix A Step Out Transactions by Portfolio Manager Symmetry Tax-Managed Structured 90/10 0.00% Symmetry TM PrecisionCore 10/90 0.00% Symmetry TM PrecisionCore 100/0 0.00% Symmetry TM PrecisionCore 20/80 0.00% Symmetry TM PrecisionCore 30/70 0.00% Symmetry TM PrecisionCore 40/60 0.00% Symmetry TM PrecisionCore 50/50 0.35% Symmetry TM PrecisionCore 60/40 0.44% Symmetry TM PrecisionCore 70/30 0.27% Symmetry TM PrecisionCore 80/20 0.00% Symmetry TM PrecisionCore 90/10 0.00% Symmetry US Sector Momentum 62.55% TJIM Core Equity 0.00% Vanguard CRSP 10%Equity/90%Fixed Income 15.55% Vanguard CRSP 100%Equity 28.96% Vanguard CRSP 100%Fixed Income 26.78% Vanguard CRSP 20%Equity/80%Fixed Income 20.75% Vanguard CRSP 30%Equity/70%Fixed Income 26.59% $0 - 0.0503 CPS Vanguard CRSP 40%Equity/60%Fixed Income 33.90% Vanguard CRSP 50%Equity/50%Fixed Income 34.78% Vanguard CRSP 60%Equity/40%Fixed Income 34.88% Vanguard CRSP 70%Equity/30%Fixed Income 37.11% Vanguard CRSP 80%Equity/20%Fixed Income 39.59% Vanguard CRSP 90%Equity/10%Fixed Income 44.71% Wakefield Biblically Responsible Equity 0.00% Wakefield Large Cap Equity 0.00% WCM Focused Growth International 27.10% WCM Quality Growth Global ADR 6.51% Wilshire Active Income 0.30% Wilshire Active Tax Free Income 0.00% Wilshire Diversified Alternatives 0.00% Zacks All Cap Core 0.06% Zacks Dividend Strategy 0.00% Zacks Focus Growth Strategy 0.19% Zacks Mid Cap Core Strategy 0.00% Zacks Preferred Income Strategy 0.00% Zacks Small Cap Equity Average Commission - Cents per share (CPS)+ 0.00% 2025 Approximate % of Step Out Trades+ Great Lakes Advisors Great Lakes Advisors Large Cap Core 0% $0 Great Lakes Advisors Large Cap Value 0% $0 Great Lakes Balanced Tax Exempt 0% $0 Great Lakes Balanced Taxable 0% $0 Passageway Managed Account Wrap Fee Program Brochure Page 59 of 61 +Information provided by the Potfolio Manager.  Appendix A Step Out Transactions by Portfolio Manager Average Commission - Cents per share (CPS)+ 2025 Approximate % of Step Out Client Trades+ PIMCO PIMCO Corporate Bond Ladder 1-5 Year Managed Account 100% $0 PIMCO Corporate Bond Ladder 3-11 Year Managed Account 100% $0 PIMCO Municipal Bond Ladder 1-6 Year Managed Account 100% $0 PIMCO Targeted Municipal Bond Ladder 3-11 Year Managed Account PIMCO Targeted Municipal Bond Ladder 3-17 Year Managed Account 100% 100% $0 $0 Passageway Managed Account Wrap Fee Program Brochure Page 60 of 61 +Information provided by the Potfolio Manager.  Investment Advisory Account Service Fee Schedule*,1 Effective Date July 8, 2026 Fee Description Fee Frequency Aged Legal Items Fee $25.00 Per item Varies Per applicable occurrence American/Global Depositary Receipt Fee2 Bounced or Return Check Fee3 $50.00 Per item Country/State Taxes4 Varies Per applicable transaction Debit Interest Charge NFBLR5 plus 3% Accrues daily, charged monthly Foreign Security Movement Fee $75.00 Per security Foreign Tax Fee6 Varies Per applicable occurrence Options Regulatory Fee7 Varies Per options transaction Overnight Mailing Fee $10.00 Per delivery Physical Reorganization Fee $25.00 Per item Precious Metals Fee Varies8 Per security SEC Section 31 Fee9 Varies Per applicable transaction Stop Payment on Check Fee3 $30.00 Per item Trade Settlement Extension Fee3 $30.00 Per extension Transfer Agent – Register/Ship Fee10 $25.00 Per certificate Outgoing Wire Transfer Fee $15.00 Per wire Important Disclosures * This Investment Advisory Account Service Fee Schedule discloses only account-level service fees and does not include investment advisory fees. For information on the investment advisory fees, refer to your Statement of Investment Selection or Advisory Supplemental Brochure. To learn more about fees and charges for Fifth Third Securities investment advisory programs (e.g., Compass, Passageway, Summit), review the corresponding Form ADV 2A brochure at 53.com/ftsdisclosure. 1 All Fees are subject to change and can vary by program and arrangement (e.g., Investment Advisory, Standard, Preferred, Private Bank, Online). Certain fees (e.g., regulatory, state and foreign government fees, etc.) are outside of the control of National Financial Services, LLC and Fifth Third Securities and can be changed or added at any time without prior notice. 2 American Depositary Receipts (ADRs) and Global Depositary Receipts (GDRs) may have administrative, or management type, fees associated with them which are passed through to shareholders. Refer to the ADR or GDR’s prospectus for information on pass through fees. 3 Fee is comprised of the combined fees assessed and paid to National Financial Services, LLC and Fifth Third Securities. 4 Fee represents charge assessed by some foreign governments on purchases and sells of securities of companies incorporated in thei r countries. The fee corresponds to the amount of tax, as set forth under applicable foreign tax laws. It is generally a percentage or scheduled amount based on the total purchase or sale amount of the securiti es subject to tax. The fee is passed on from the foreign government to the client. When applicable, the fee will appear on the trade confirmation. 5 The National Financial Base Lending Rate (NFBLR) is set at the discretion of National Financial Services, LLC after considering commercially recognized interest rates, industry conditions regarding the extension of margin credit and general credit conditions. 6 Fee represents charge assessed by some foreign governments on income generated from securities of companies incorporated in their countries. The fee corresponds to the amount of tax, as set forth under applicable foreign tax laws. It is generally a percentage or scheduled amount based on the income generated from the securiti es subject to tax. The fee is passed on from the foreign government to the client. When applicable, the fee will appear on the monthly or quarterly account statement. 7 Fee represents charge assessed by the Options Clearing Corporation (OCC) on all options transactions that are passed on to you and will be displayed on the trade confirmation as Activity Assessment Fee. 8 Fee varies based on several factors regarding the precious metal including, but not limited to, package weight, value, delivery location, and insurance required to ship. 9 Fee represents charge assessed by the SEC (Section 31 Fee) that is passed on to you and will be displayed on the trade confirmation as Activity Assessment Fee. The fee is calculated on the investment amount (principal) of applicable transactions. More information on the Section 31 Fee can be found on the SEC’s website. 10 This fee generally appears in your account as DRS Registration. Fifth Third Bank, N.A. provides access to investments and investment services through various subsidiaries, including Fifth T hird Securities. Fifth Third Securities is the trade name used by Fifth Third Securities, Inc., member FINRA/SIPC, a registered broker-dealer and a registered investment advisor registered with the U.S. Securities and Exchange Commission (SEC). Registration does not imply a certain level of skill or training. Securities, Investments, Investment Advisory Services, and Insurance: Are Not FDIC Insured Offer No Bank Guarantee Are Not Insured By Any Federal Government Agency May Lose Value Are Not A Deposit 07/08/2026 Passageway Managed Account Wrap Fee Program Brochure Page 61 of 61 

SUMMIT MANAGED ACCOUNT FIRM BROCHURE (Form ADV Part 2A) 38 Fountain Square Plaza Cincinnati, OH 45263 Phone: (888) 889-1025 www.53.com/invest SEC File No. 801-63623 Date of Brochure: July 08, 2026 This Summit Managed Account Firm Brochure (“Brochure”) provides information about the qualifications and business practices of Fifth Third Securities, Inc. If you have any questions about the contents of this Brochure, please contact us at 888-889-1025. 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 Fifth Third Securities, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. This Brochure provides information about Fifth Third Securities, Inc. and the Summit Managed Account Program. You should review the information and consider all factors, including but not limited to, investment risks, fees, and conflicts of interest prior to becoming a client of the Summit Managed Account Program. Fifth Third Securities is the trade name used by Fifth Third Securities, Inc., a member FINRA/SIPC and a registered investment advisor with the U.S. Securities & Exchange Commission. Registration does not imply a certain level of skill or training. Securities and investment advisory services offered through Fifth Third Securities: Are Not FDIC Insured Offer No Bank Guarantee May Lose Value Are Not Insured By Any Federal Government Agency Are Not A Deposit 07/08/2026 Summit Managed Account Firm Brochure Page 1 of 36  Item 2 – Material Changes This document represents the initial filing of this Brochure. In the future, this section will be used to describe the material changes to the Fifth Third Securities, Inc. Brochure as updates are made to this July 8, 2026 version. a) b) c) d) Item 3 – Table of Contents ITEM 1 – COVER PAGE .................................................................................................................................... 1 ITEM 2 – MATERIAL CHANGES ..................................................................................................................... 2 ITEM 3 – TABLE OF CONTENTS ................................................................................................................... 2 ITEM 4 – ADVISORY BUSINESS ...................................................................................................................... 4 A. ABOUT FIFTH THIRD SECURITIES ............................................................................................................................ 4 B. SUMMIT INVESTMENT MANAGEMENT PROGRAM ..................................................................................................... 4 1) Fiduciary Duties ........................................................................................................................................... 6 2) Limitation of Products and Types of Products (FTS vs Other Broker-Dealers or Registered Investment Advisers) .......................................................................................................................................................... 6 3) Limitation of Products and Types of Products (between FTS programs and services) ............................... 6 4) Fidelity Institutional Wealth Adviser, LLC (“FIWA”) .................................................................................... 7 5) Best Execution ............................................................................................................................................. 7 6) Non-Managed Assets and Worthless Securities ......................................................................................... 7 7) Unsupervised Assets ................................................................................................................................... 7 8) Holding a Client’s Order or Instruction ....................................................................................................... 8 9) Terminating Summit Asset Management Services ..................................................................................... 8 10) Class Action and Other Legal Proceedings ................................................................................................ 9 C. AVAILABILITY OF CUSTOMIZED SERVICES FOR INDIVIDUAL CLIENTS ............................................................................... 9 D. WRAP FEE PROGRAMS ......................................................................................................................................... 9 E. ASSETS UNDER MANAGEMENT .............................................................................................................................. 10 ITEM 5 – FEES AND COMPENSATION ......................................................................................................... 10 A. INVESTMENT ADVISORY FEES AND COMPENSATION ................................................................................................... 10 1) Investment Advisory Fees ........................................................................................................................... 10 2) Fixed Income Related Costs ........................................................................................................................ 11 3) Householding & Investment Advisory Fees ................................................................................................. 11 Householding Advisory Fees Criteria ................................................................................................................. 11 How to Opt Out of Householding ...................................................................................................................... 12 Termination of Householding by FTS ................................................................................................................ 12 Ineligible Accounts for Householding Advisory Fees ......................................................................................... 12 B. PAYMENT OF FEES ............................................................................................................................................... 13 C. ADDITIONAL FEES AND EXPENSES ........................................................................................................................... 13 1) Fixed Income Markups & Markdowns ........................................................................................................ 13 2) Other Fees ................................................................................................................................................... 13 a) Mutual Fund and ETP Fees ................................................................................................................................ 13 b) Mutual Fund Share Classes ............................................................................................................................... 13 D. PREPAYMENT OF FEES .......................................................................................................................................... 13 E. ADDITIONAL COMPENSATION AND CONFLICTS OF INTEREST ........................................................................................ 13 1) Mutual Fund Rule 12b-1 Fees ..................................................................................................................... 14 2) Fixed Income Markups & Markdowns ........................................................................................................ 14 3) Conflicts of Interest when Recommending Summit over other Investment Advisory Programs ................ 14 4) NFS Minimum Account Fees ....................................................................................................................... 14 5) Payment of Investment Advisory Fees to IARs ............................................................................................ 14 6) Compensation Conflicts of Interest ............................................................................................................. 15 7) Bonuses & Performance Based Compensation ........................................................................................... 15 8) Conflicts Related to Active Trading and No Charge Investments ............................................................... 15 9) Recruitment Compensation ........................................................................................................................ 15 07/08/2026 Summit Managed Account Firm Brochure Page 2 of 36  a) b) c) Forgivable Draw Compensation ........................................................................................................................ 15 Upfront Forgivable Loan or Promissory Note.................................................................................................... 16 Sign-On Bonus ................................................................................................................................................... 16 10) Minimum Guaranteed Payout Percentage ............................................................................................... 16 11) Back-End Asset Based Bonus .................................................................................................................... 17 12) Retention Compensation .......................................................................................................................... 17 13) Retirement Compensation ........................................................................................................................ 17 14) IAR Forfeiture of Compensation ................................................................................................................ 18 15) Conflicts Related to IAR Production Standards ......................................................................................... 18 16) Conflicts Related to Recommending Summit Account vs. Brokerage Account ......................................... 19 17) Conflicts Related to Mutual Fund Revenue Sharing .................................................................................. 19 18) Conflicts Related to Receipt of Educational, Marketing, & Other Financial Support ................................ 19 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................... 20 ITEM 7 – TYPES OF CLIENTS ......................................................................................................................... 20 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ...................... 20 A. METHODS OF ANALYSIS AND INVESTMENT STRATEGIES .............................................................................................. 20 B. MATERIAL, SIGNIFICANT, OR UNUSUAL RISKS RELATING TO INVESTMENT STRATEGIES .................................................... 21 1) Risk of Asset Value Loss .............................................................................................................................. 21 2) Interest Rate Risk ........................................................................................................................................ 22 3) Credit Risk ................................................................................................................................................... 22 4) Cybersecurity Risk ....................................................................................................................................... 22 5) Artificial Intelligence (“AI”) Risk .................................................................................................................. 22 6) Derivatives Risk ........................................................................................................................................... 23 C. RISKS ASSOCIATED WITH PARTICULAR TYPES OF SECURITIES ........................................................................................ 23 1) Investments in a Summit Account ............................................................................................................... 23 2) ETFs ........................................................................................................................................................... 23 3) ETNs ........................................................................................................................................................... 23 4) ESG, SRI, Faith Based, and Similar Investments and Investment Strategies ............................................... 24 5) Foreign Exposure ......................................................................................................................................... 24 6) Legislative and Regulatory Risk .................................................................................................................. 24 7) Money Market Fund ................................................................................................................................... 24 8) Municipal Bonds.......................................................................................................................................... 25 9) Stock Markets and Investments .................................................................................................................. 25 10) Tracking Error ........................................................................................................................................... 26 11) Additional Risks ......................................................................................................................................... 26 ITEM 9 – DISCIPLINARY INFORMATION ................................................................................................... 26 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .................................... 27 A. FIFTH THIRD SECURITIES – BROKER-DEALER & MUNICIPAL ADVISOR ........................................................................... 27 B. FIFTH THIRD BANK, NATIONAL ASSOCIATION (FTB) .................................................................................................. 27 C. FIFTH THIRD INSURANCE AGENCY, INC. (FTIA) ......................................................................................................... 27 D. FRANKIN STREET ADVISORS, INC. (FRANKLIN STREET ADVISORS) ................................................................................. 27 E. FIFTH THIRD WEALTH ADVISORS, LLC (FTWA) ........................................................................................................ 27 F. COMERICA SECURITIES, INC. (COMERICA SECURITIES) ................................................................................................ 28 ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING ............................................................................................................................ 28 A. CODE OF ETHICS .................................................................................................................................................. 28 B. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS .............................................................................................. 28 C. PERSONAL TRADING ............................................................................................................................................. 29 D. CONFLICTS RELATED TO RECEIPT OF GIFTS AND BUSINESS ENTERTAINMENT .................................................................. 29 ITEM 12 – BROKERAGE PRACTICES ............................................................................................................. 29 A. BROKER-DEALER SELECTION FOR CLIENT TRANSACTIONS ........................................................................................... 29 1) Research and Other Soft Dollar Benefits ..................................................................................................... 30 07/08/2026 Summit Managed Account Firm Brochure Page 3 of 36  a) b) c) NFS Credits & Discounts .................................................................................................................................... 30 Conflicts Related to Interest on Cash Holdings ................................................................................................. 30 Conflicts Related to Clearing Firm (NFS) ........................................................................................................... 31 2) Trade Errors ................................................................................................................................................ 32 B. ORDER AGGREGATION.......................................................................................................................................... 32 ITEM 13 – REVIEW OF ACCOUNTS ............................................................................................................... 32 A. FREQUENCY AND NATURE OF REVIEW OF CLIENT ACCOUNTS OR FINANCIAL PLANS ........................................................ 32 B. FACTORS PROMPTING REVIEW OF CLIENT ACCOUNTS OTHER THAN A PERIODIC REVIEW ................................................. 32 C. CONTENT AND FREQUENCY OF ACCOUNT REPORTS TO CLIENTS ................................................................................... 32 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ........................................................... 33 A. FTS EDUCATION SUMMIT ..................................................................................................................................... 33 B. FTB PRESIDENT’S CIRCLE ...................................................................................................................................... 33 C. AREA AND REGIONAL MEETINGS ............................................................................................................................ 33 D. COMPENSATION TO NON-SUPERVISED PERSONS FOR CLIENT REFERRALS ...................................................................... 33 ITEM 15 – CUSTODY ......................................................................................................................................... 34 ITEM 16 – INVESTMENT DISCRETION ....................................................................................................... 34 ITEM 17 – VOTING CLIENT SECURITIES .................................................................................................... 34 ITEM 18 – FINANCIAL INFORMATION ........................................................................................................ 35 A. BALANCE SHEET .................................................................................................................................................. 35 B. FINANCIAL CONDITIONS LIKELY TO IMPAIR ABILITY TO MEET CONTRACTUAL COMMITMENTS TO CLIENTS ........................... 35 C. BANKRUPTCY FILINGS ........................................................................................................................................... 35 INVESTMENT ADVISORY ACCOUNT SERVICE FEE SCHEDULE ......................................................... 36 Item 4 – Advisory Business A. About Fifth Third Securities Fifth Third Securities, Inc. (“FTS”, “we”, “our”, or “us”) is a registered broker-dealer member of Financial Industry Regulatory Authority (“FINRA”) and SIPC (www.SIPC.org), and a registered investment adviser with the U.S. Securities and Exchange Commission (registration does not imply a certain level of skill or training). FTS was established in 1925, and FTS became a registered investment adviser in November 2004. FTS is a direct wholly-owned subsidiary of Fifth Third Bank, National Association (“FTB”). FTB is a full-service bank (see Item 10 - Other Financial Industry Activities and Affiliations for more information). Brokerage and investment advisory services and fees differ, and it is important for clients to understand the differences between these two types of services. IMPORTANT – Read before you open a Summit Account – The FTS’ Customer Relationship Summary (Form CRS) provides important information about both brokerage and investment advisory services, and clients should review Form CRS prior to making any decision to engage FTS for either brokerage or investment advisory services. The current version of FTS’ Form CRS can be requested from your Investment Advisor Representative (“IAR”) or found by going to the website 53.com/ftsdisclosure. B. Summit Investment Management Program FTS is the sponsor of the Summit Managed Account Program (“Summit”), a program that provides investment management services to clients (also referred to as “you” or “your”) utilizing equities (exchange- traded stocks, stocks traded over-the-counter), mutual funds (which could include fund of funds), exchange traded funds (“ETFs”) and exchange traded notes (“ETNs”) (also collectively referred to herein as exchange traded products or “ETPs”), fixed income securities (e.g., corporate bonds, municipal bonds, government bonds, etc.), publicly traded real estate investment trusts (“REITs”), or a combination of these investments. With respect to mutual funds and ETPs, our IARs can only recommend and purchase products that appear on FTS’ approved product list. Additional services included in Summit are brokerage and custodial services for Summit accounts, performance reporting, and assistance with investment style selection and asset allocation strategies. 07/08/2026 Summit Managed Account Firm Brochure Page 4 of 36  Summit provides investment management services for various investment styles and objectives. Summit is not intended for investors who want to frequently switch investments from one style or strategy to another in reaction to short-term trends. You cannot independently buy or sell securities within your Summit account. If you want to execute your own trades using the assets that would fund your Summit account, you should not open a Summit account and evaluate at opening a brokerage account instead. In Summit, FTS, through our IARs, acts as the Portfolio Manager. An IAR of FTS will meet with a prospective client to discuss and complete an investor profile. During this discussion, the IAR gathers information regarding the client’s risk tolerance, investment objectives, and other financial information. With this data, the IAR assists the client in determining whether Summit is appropriate for the client and recommends an investment style and an asset allocation strategy or strategies for the Summit account to the client. A client choosing to open a Summit account will sign an Investment Management Agreement and an Advisory Supplemental Form or the Statement of Investment Selection with FTS, as well as an agreement to open an account with National Financial Services LLC (“NFS”). An advisory relationship exists between the client and FTS once the 1) Investment Management Agreement and 2) Statement of Investment Selection or Advisory Supplemental Form have been reviewed and accepted by FTS’ Principal Review Desk. If FTS’ Principal Review Desk does not accept the Investment Management Agreement, Advisory Supplemental Form, or the Statement of Investment Selection, there is no advisory relationship between FTS and the client. Summit is accessed through the Fidelity Managed Account Xchange (“FMAX”) platform, of which Fidelity Institutional Wealth Adviser LLC (“FIWA”) is the platform manager. Additionally, FIWA provides due diligence services to FTS for some or all of the mutual funds and ETPs available within Summit. Clients grant FTS discretionary authority to manage Summit account assets. Such discretionary authority allows FTS to make all investment decisions with respect to the client’s Summit account(s) when FTS deems it appropriate and without prior consultation with the client, to buy, sell, exchange, convert and otherwise trade in any equity, mutual fund, ETP, fixed income security, or publicly traded REIT. In addition, this discretionary authority allows FTS to invest a Summit client’s accounts/assets in a lower risk tolerance up to one level than the client has selected. Please see below for a list of risk tolerances in the Summit Program, which are listed in order of the riskiest to the least risky. For example, if a client has selected the risk tolerance as Aggressive Growth, then when FTS deems it appropriate, FTS could move the client’s account/assets to reflect a Growth risk tolerance. However, in this example FTS would not be able to move the client’s account/assets to reflect a Moderate Growth or lower risk tolerance since they are more than one level below the client’s stated risk tolerance. Furthermore, this discretionary authority does not allow FTS to invest in a higher risk tolerance than what the client has selected. Risk Tolerances Aggressive Growth Growth Moderate Growth Moderate Conservative Growth Conservative Capital Preservation NFS is FTS’ clearing brokerage and custodial services provider, to custody client assets invested by the client in Summit. NFS is a registered broker/dealer and is not an affiliated entity of FTS. Most or all security transactions for Summit accounts are executed through NFS as the clearing broker/dealer. However, FTS sometimes trades with other broker/dealers to achieve best execution, obtain a wider variety of securities, 07/08/2026 Summit Managed Account Firm Brochure Page 5 of 36  or take advantage of favorable mark-ups or mark-downs available elsewhere. FTS can at any time change the clearing broker and custodian for the client’s account. The discretion granted by you to FTS includes the discretion to select broker-dealers for the execution of transactions to achieve best execution. FTS and our IARs have no authority or duty to manage any of the client’s assets that are: (1) not within Summit or another investment advisory program offered by FTS (i.e., Compass Managed Account Program and the Passageway Managed Account Program), or (2) are designated as Unsupervised Assets (see Item 4.B.7. – Unsupervised Assets) within FTS investment advisory accounts. Participating in the Summit program entails risk. For more information about some of these risks please see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss. 1) Fiduciary Duties Under federal law, a registered investment adviser, such as FTS, is a fiduciary to its investment advisory clients (a/k/a Summit clients). FTS’ fiduciary duty includes, but is not limited to, a duty of care and a duty of loyalty. The duty of loyalty requires FTS, and our IARs, not to place our own interest ahead of our Summit clients’ interests. FTS is to make appropriate disclosures to our Summit clients, which is done through several documents, such as this Brochure. These disclosures help provide material information relating to the investment advisory relationship and FTS. The duty of care requires, among other things, the duty of FTS to provide advice that is in the best interest of our Summit clients, a duty to monitor the client’s managed investments in Summit accounts, and the ongoing suitability of those investments, over the course of the investment advisory relationship. As part of FTS’ duty of care, it our responsibility to understand the client’s objectives for the investments which we manage under Summit, the client’s risk tolerance (e.g., how much risk and losses you are willing to take for the potential of gains in your Summit account), and other financial profile information (e.g., annual income, estimated net worth, liquid assets, federal tax bracket, etc.). This information is needed to have a reasonable belief that the advice we provide is in the best interest of the Summit client. Critically Important Client Responsibility: You need to promptly notify the FTS’ IAR that you work with of changes to your risk tolerance, investment objectives, or financial circumstances that differ from the financial profile information that you previously provided to FTS, so that your Summit account can be reevaluated for potential changes. Additionally, when FTS provides investment advice to clients of Summit regarding their retirement plan account or individual retirement account, FTS is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way FTS makes money creates conflicts with your interests, so FTS operates under a rule that requires us to act in the client’s best interest and not put our interest ahead of our clients. 2) Limitation of Products and Types of Products (FTS vs Other Broker-Dealers or Registered Investment Advisers) FTS offers a wide range of investment products, advisory services, and other services to help meet your financial needs. However, we do not offer the same investment products, or product types that are available through other broker-dealers or registered investment advisers. This limitation is due to various reasons that include, but are not limited to, the product company has not passed our due diligence process, we do not have a contract with the product company, or the product, product type, or the product company is outside of our current business model, or the amount of risk associated with the company or product is too great. 3) Limitation of Products and Types of Products (between FTS programs and services) In Summit, FTS offers equities, mutual funds, ETPs, fixed income securities (e.g., corporate bonds, municipal bonds, and government bonds), and publicly traded REITs. However, through our broker-dealer and other investment advisory programs offered by FTS, a wider selection of approved products and product types are available. 07/08/2026 Summit Managed Account Firm Brochure Page 6 of 36  4) Fidelity Institutional Wealth Adviser, LLC (“FIWA”) FIWA oversees the technology platform on which Summit functions for Summit Accounts. FTS has access to tools and related services as well as research and additional information about investment products offered through the FMAX platform, which assists FTS’ IARs in building personalized solutions for FTS’ clients. For more information about the FMAX platform and the research and risk ratings of investment products on FMAX, as well as other investment tools and related services, please see FIWA’s ADV Part 2A Brochure describing FMAX. Additionally, FIWA provides due diligence services to FTS for the majority or all of the mutual funds and ETPs available through Summit. 5) Best Execution As a registered investment adviser, FTS and our IARs have a fiduciary duty to seek to obtain the best trade execution in Summit accounts. Clients should understand that we may not always obtain the lowest possible transaction cost, and best execution does not mean the best price will be obtained. In addition, we may execute transactions at different prices or costs, and the execution quality received by one client may differ from the execution quality received by another client depending on the type of security, market conditions, order size, account restrictions, or other relevant factors. Several factors are utilized in analyzing overall best trade execution quality, including but not limited to, execution capability, timeliness of affecting trades, ability to execute orders of significant size, service, costs, system capabilities, system security, financial stability of firm executing the trade, and other relevant considerations. These factors combined are collectively referred to as “best execution.” FTS can choose to place a trade at a firm other than NFS if we believe we need to in order to meet their best execution obligation (often referred to as “trading away”). To aid in our best execution obligations, FTS periodically and systematically conducts a sample review of equity securities transactions executed through NFS to help confirm FTS continues to meet our best execution obligations with our clients. 6) Non-Managed Assets and Worthless Securities FTS generally does not permit securities to be held in a Summit account that are not part of the asset management of the Summit account unless it is an Unsupervised Asset (discussed below) or is a worthless security. However, if a security is deemed to be worthless (has no market value) and you do not have a brokerage account with FTS where this worthless security can be held, then the worthless security can be held in the Summit account with the client’s understanding that the worthless security or securities are not being managed by FTS, our IARs, or FIWA. 7) Unsupervised Assets In some cases, a client may want to transfer a security or investment into a Summit account but not want that security or investment immediately managed as part of the account's investment strategy. Clients can want this approach for a variety of reasons, including a desire to defer the tax consequences associated with liquidating the asset. A client or an IAR may request that a security or investment be designated as an Unsupervised Asset within a Summit account by completing an Unsupervised Assets Administration Form. Clients may obtain the form from their IAR or access it at https://www.53.com/ftsdisclosure, and are to submit the completed form to their IAR for processing. Upon receipt of a completed Unsupervised Assets Administration Form, the request will be evaluated by both FTS and FIWA. A security or investment will be treated as an Unsupervised Asset only if the request is approved by both FTS and FIWA. Requests may be denied for a variety of reasons, including, but not limited to, circumstances in which FTS or FIWA reasonably believes that the client does not intend to liquidate the security or investment and have the proceeds managed within the Summit account, or where the client intends to retain the proposed Unsupervised Asset for an extended period of time inconsistent with the purpose of having the proceeds of the Unsupervised Asset managed. If FTS or FIWA do not agree to the request to have a security or 07/08/2026 Summit Managed Account Firm Brochure Page 7 of 36  investment treated as an Unsupervised Asset, written notice will be provided by FTS to the client. Important Concepts: 1) If a client does not intend for a security or investment to ultimately be managed within a Summit account, the client should neither request nor agree to designate that security or investment as an Unsupervised Asset. Only securities or investments that you reasonably expect to be transferred into and managed as part of a Summit account should be considered for a request as an Unsupervised Asset. 2) The discretionary authority granted by a client to FTS and our IARs includes the authority on determining when to liquidate an Unsupervised Asset and include the proceeds of the Unsupervised Asset into the management of the Summit account without the prior consent of the client. If a client does not want FTS and our IARs to determine when an Unsupervised Asset should be liquidated and incorporated into the management of a Summit account, the client should have those security(ies) or investment(s) held in a brokerage account instead of having the security(ies) or investment(s) established as an Unsupervised Asset in a Summit account. Since Unsupervised Assets are not part of the active management of a Summit account, FTS does not charge an Investment Advisory Fee (see Item 5 – Fees and Compensation for further details) on an Unsupervised Asset until it is liquidated. As a result, there is financial incentive and a conflict of interest for FTS and our IARs to liquidate an Unsupervised Asset and have the proceeds incorporated into the management of the Summit account as FTS and our IAR(s) on the Summit account will make more in compensation. 8) Holding a Client’s Order or Instruction FTS, at its own discretion and without consultation with the Summit client, may choose not to immediately act upon a Summit client’s order to place a transaction or series of transactions (e.g., buy, sell, exchange, transfer, withdrawal) or act upon a client’s instruction if FTS believes that the client is the subject of financial abuse or is engaged or potentially engaged in a criminal activity (directly or indirectly). Examples of client instructions that FTS or FTS’ IARs may choose not to act upon immediately include, but are not limited to, executing securities transactions, money movement instructions including wire and check movements, termination of advisory services, change in beneficiary or beneficiaries, and trading authorization of a third- party. In the instances where FTS does not immediately act upon a Summit client’s order to place a transaction or act upon a client’s instruction, FTS will attempt to promptly conduct a review in order to determine the appropriate course of action, which can include, but is not limited to, contacting the client, State and/or federal authorities, or the Summit client’s Trusted Contact. FTS can choose not to act upon a client’s instructions or order for up to 15 calendar days, or for a longer period if permitted by applicable State laws/regulations, or as directed by State or federal authorities. 9) Terminating Summit Asset Management Services Either FTS or the client can terminate participation in Summit at any time by providing thirty (30) days prior written notice to the other party. The client will be charged a pro-rated investment advisory fee for the portion of any billing period during which the account is open (see Item 5 – Fees and Compensation for further details) unless the client terminates the Investment Management Agreement within (5) business days from the client signing the Investment Management Agreement. If a client terminates the Investment Management Agreement within five (5) business days from the client signing the Investment Management Agreement, then the client is not charged with an investment advisory fee. FTS reserves the right to distribute the assets of a client’s account in-kind (a delivery or transfer of securities held in the Summit account instead of in cash), liquidate any and all assets in the Summit account, send to the address of record any security in certificate form, and/or send to the address of record any available cash balance upon termination of the account by either party unless the Summit client provides alternative instructions. FTS will generally evaluate a Summit account for termination if there has been no IAR-initiated transactional activity (e.g., buys or reallocations) for a period greater than 18 months (withdrawals from the Summit account are excluded). If after the completion of the review FTS determines that it is appropriate to terminate the Summit account, FTS will terminate the Investment Management Agreement by providing thirty (30) days prior written notice to the client. Upon notification that an account owner has died, the Investment 07/08/2026 Summit Managed Account Firm Brochure Page 8 of 36  Management Agreement is immediately terminated, and the client’s account is no longer a Summit account. Any subsequent trades placed based upon instructions from the executor, heirs, or beneficiaries are subject to standard fees and commissions of a brokerage account. For the fees associated with brokerage accounts, see the Standard Commission and Fee Schedule at 53.com/ftsdisclosure for more information. 10) Class Action and Other Legal Proceedings On occasion, securities currently or previously held in a client’s account are the subject of a class action lawsuit or other legal proceedings. FTS and our IARs have no obligation to monitor or determine if securities currently or previously held by the client are subject to pending or resolved legal actions. In addition, FTS and our IARs have no duty to assess a client’s eligibility for participation in any class action settlement or other legal proceeding, nor to file or submit claims on a client’s behalf. Furthermore, FTS and our IARs have no obligation or responsibility to initiate litigation or otherwise seek to recover damages on behalf of clients who believe they have been injured by the result of actions, misconduct, or negligence of issuers whose securities the client holds. C. Availability of Customized Services for Individual Clients Clients have the opportunity to place reasonable investment restrictions on the types of investments that will be managed on the client's behalf within Summit accounts. The client must provide these investment restriction requests to FTS in writing. If FTS, our IARs, or FIWA deems the restriction request unreasonable, FTS will notify the client of the rejection of the restriction request in writing. Clients can request two types of restrictions on their Summit account: 1) individual security restrictions, and 2) industry restrictions. Clients may not impose restrictions which apply to underlying securities held in any mutual fund, ETP, or other pooled investment product. Individual security restrictions only apply to that specific security that is identified by a symbol or CUSIP, and the restriction will not apply to other securities that hold that individual security, such as mutual funds, ETPs or other pooled investment products. For example, if a client has an accepted restriction request for Microsoft stock (symbol ‘MSFT’), the client’s Summit account will not purchase shares of Microsoft stock. However, a mutual fund held in the client’s Summit account can be invested in Microsoft, and therefore, the client has an indirect investment still in Microsoft. Industry restrictions apply to general sectors of industry. Some examples of industry restrictions include, but are not limited to, Resorts & Casinos, Tobacco, Wineries & Distilleries, and Auto Manufacturers. Clients do not have the ability to determine what securities are included or excluded within an industry restriction, nor can clients determine the criteria that are used to include or exclude a security within an industry restriction. If a client requests an industry restriction in a Summit account, the client accepts the FTS’, FTS’ IARs, or FIWA’s determination of what securities are included and excluded from the industry restriction. D. Wrap Fee Programs FTS offers multiple investment advisory services through various programs. One of those programs, the Passageway Managed Account Wrap Fee Program (“Passageway”), is a wrap fee program (e.g., generally does not have securities transaction-related costs in addition to the investment advisory fee). For clarity, Summit is not a wrap fee program. The product types and selection of portfolio managers available in Passageway accounts are different than the product types and selection of portfolio managers available in non-wrap fee accounts (Summit and Compass Managed Account Program). For example, Passageway has the availability of other firm third-party asset managers that will act as the Portfolio Manager Additionally, in the Passageway Advisor Directed program, FTS IARs are limited to managing mutual funds and ETPs; whereas Summit has the availability for FTS IARs to invest in equities, mutual funds, ETPs, fixed income products, and publicly traded REITs. Finally, in the Compass Managed Account Program (“Compass”), FTS IARs have the potential availability to invest in equities, mutual funds, ETPs, fixed income products, unit investment trusts (“UITs”), and publicly traded REITs. However, in each of these advisory programs, the investment advisory account management is driven by the 07/08/2026 Summit Managed Account Firm Brochure Page 9 of 36  client’s best interest as determined through evaluation by FTS’ IAR using profile information provided by the client, the client’s preferences including reasonable investment restrictions, and investment strategies aligned with the client’s risk tolerance. Clients should discuss with the IAR whether a wrap fee program would be appropriate based on factors, including but not limited to the types of investments the client wants to be invested in, the fee and expenses associated with such assets, and the anticipated trading activity in the account. FTS receives a portion of the wrap fee for Passageway. Clients should review all of the investment advisory services offered by FTS prior to making any decision to engage in Summit. The current versions of the Passageway Managed Account Wrap Fee Program Brochure and Firm Brochures for Summit and Compass (both non-wrap fee programs) can be requested from your IAR or found by going to the website 53.com/ftsdisclosure. E. Assets Under Management As of April 30, 2026, FTS had approximately $14,228,900,000 in assets under management that are managed on a discretionary basis. Item 5 – Fees and Compensation A. Investment Advisory Fees and Compensation Summit clients are assessed investment advisory fees on Summit accounts for the ongoing advice, portfolio management, and services provided by FTS and our IARs. Summit clients are also assessed separate account service fees described below and on Investment Advisory Account Fee Schedule that appears at the end of this Brochure. 1) Investment Advisory Fees Investment advisory fees are negotiable between FTS and the Summit client. As a result, Summit clients that have similar account balances and/or allocations can pay different investment advisory fees. Clients should refer to their Advisory Supplemental Form or the Statement of Investment Selection to see the negotiated advisory fee schedule for your specific Summit account(s). FTS includes cash and cash equivalents positions in the daily weighted average market value of the assets under management when FTS assesses investment advisory fees. As a result, clients should limit the amount of cash or cash equivalents held in their Summit account. For the initial calendar quarter in which a Summit account is opened, the initial advisory fee will be based upon the number of days the account is open in Summit, and the daily weighted average market value of the assets under management. Likewise, upon the termination of a Summit account, an advisory fee will be based upon the beginning date of the calendar quarter through the date of termination of the Summit account and the daily weighted average market value of the assets under management. Clients should be aware that the investment management services provided under Summit can be more or less expensive than if the services were purchased separately, provided through another investment advisory program offered by FTS, or purchased at another financial firm. A client could receive services similar to those offered in Summit from other financial services providers. When determining the cost of purchasing services separately or the cost of other investment advisory programs, clients should evaluate the costs of brokerage commissions charged, the volume of trading activity in the account, transaction fees, wire fees, trade-away fees, foreign security transfer fees, retirement account termination fees, custody charges, fees charged for investment management services, fees for performance reporting, and the internal costs of the assets purchased (e.g., mutual fund and ETP internal expenses). Investment advisory fees (referred to as the “Program Fee” in the Investment Management Agreement) for Summit generally follow the below fee schedule, but investment advisory fees can be lower. Clients should refer to their Advisory Supplemental Form or Statement of Investment Selection to see the negotiated advisory fee schedule for their specific Summit account(s). 07/08/2026 Summit Managed Account Firm Brochure Page 10 of 36  Standard Investment Advisory Fee Schedule Value of Account Advisory Fee First $250,000 Next $250,000 Next $250,000 Next $250,000 Next $1,000,000 Balance Above $2,000,000 1.50% 1.35% 1.25% 1.10% 1.00% 0.80% The maximum investment advisory fee for investment advisory programs offered through FTS is 1.50%. 2) Fixed Income Related Costs When FTS buys or sells fixed income securities (e.g., municipal bonds, corporate bonds, government bonds or securities) in your Summit account, FTS will act as the agent in the transaction. When acting as agent, FTS sources fixed income securities from other dealers (also known as a counterparty) in the market. The price FTS receives from the dealer will include a markup or markdown which is included in the price you receive in your Summit account. The markup or markdown charged varies based on several factors including, but not limited to, the type of security being bought or sold, maturity date, and size of the transaction. FTS does not act as a principal (i.e., trade from our own inventory) for fixed income securities transactions in a Summit account. 3) Householding & Investment Advisory Fees Clients who have a tiered investment advisory fee schedule (see the Standard Investment Advisory Fee Schedule above) can potentially reduce their investment advisory fees when FTS investment advisory accounts are linked together to aggregate total assets under management (hereafter referred to as “Householding”). FTS investment advisory accounts in the Summit, Compass, and Passageway programs are eligible for Householding. By Householding FTS investment advisory accounts, the client can potentially reach a subsequent tier on the investment advisory fee schedule that has a lower advisory fee. For example, if a client has two Summit accounts at FTS using the standard tiered investment advisory fee schedule (see above) and each of these accounts has a balance of $150,000, the combined assets of these accounts would be $300,000. Instead of each investment advisory account receiving an investment advisory fee charge of 1.5%, the Householding feature will result in the first $250,000 receiving a 1.5% charge, and the next $50,000 receiving a charge of 1.35%. Householding FTS investment advisory accounts will not always result in a lower investment advisory fee if the combined assets of the Householded accounts do not reach a subsequent tier of the client’s investment advisory fee schedule. For example, if the client has two investment advisory accounts Householded each with a balance of $100,000 and the first tier of the investment advisory fee schedule goes from $0 - $250,000, then the client would not receive a reduction in investment advisory fees because the total Householded amount is $200,000, which is below the minimum amount for the next tier ($250,000.01). If the client has a flat percentage investment advisory fee (e.g., 1.40%) rather than a tiered investment advisory fee schedule, the client will not receive any reduction of investment advisory fees regardless of the value of combined assets when FTS investment advisory accounts are Householded. a) Householding Advisory Fees Criteria For investment advisory accounts to qualify for Householding, the FTS investment advisory accounts must meet certain conditions. The current conditions for Householding are: • Each of the Householded investment advisory accounts through FTS being linked together must have the same IAR or IARs associated. For example, if a client with an FTS investment advisory account that has an IAR (John Doe) and their spouse has a different IAR (Jane Smith) who handles their FTS investment advisory account, the FTS investment advisory accounts will not be Householded 07/08/2026 Summit Managed Account Firm Brochure Page 11 of 36  because the clients have different IARs. • Each Householded FTS investment advisory account must be open (i.e., the investment advisory relationship has not been terminated) at the end of the calendar quarter. For example, if a client has two FTS investment advisory accounts that meet all the conditions to receive Householding but terminates one of the FTS investment advisory accounts during the calendar quarter including up to the last day of the calendar quarter, then the FTS investment advisory accounts would not be Householded. • Each Householded FTS investment advisory account must have the same mailing address listed with FTS. If a client or clients have two or more separate mailing addresses, even if the client or clients are related or part of the same family (e.g., spouse, children, trust, etc.), the FTS investment advisory accounts are not eligible for Householding. A client should never provide FTS with a mailing address that is not their own address. If a client provides FTS with another individual’s address, that individual at the other address would receive the client’s statements and other communications from FTS, FIWA, and NFS rather than the client; and • If the client has additional non-advisory accounts (e.g., brokerage accounts, annuities, 529 Plans, etc.), these accounts and assets are not eligible for Householding. Provided that the above-listed criteria are met and continue to be met, Householding will be applied to the applicable investment advisory accounts through FTS. Investment advisory accounts through FTS that are linked for Householding are not required to be opened on the same day to be eligible for Householding. Clients are not required to take any steps to apply for Householding. Important Consideration for Householding – When investment advisory accounts through FTS are Householded together, clients receive only one Quarterly Performance Report that reflects all of the Householded investment advisory accounts through FTS. Clients desiring to receive separate Quarterly Performance Reports for their FTS’ investment advisory accounts will need to opt-out of Householding, which can result in paying more in investment advisory fees. b) How to Opt Out of Householding Clients can opt-out of Householding by providing a written request to: Fifth Third Securities, Inc. Attn: FTS Compliance Department 38 Fountain Square Plaza MD: 1090XB Cincinnati, OH 45263 However, if a client chooses to opt-out of Householding, the client or clients will not receive the potential benefit of lower investment advisory fees. c) Termination of Householding by FTS FTS can at any time choose to cease offering Householding or change the conditions of when or how investment advisory accounts through FTS are Householded. If FTS ceases offering Householding or changes the conditions for Householding, FTS will mail clients a written notification approximately 30 calendar days in advance of the change(s) taking effect. d) Ineligible Accounts for Householding Advisory Fees Householding is not available for any of the following account types: • Investment advisory accounts offered through affiliated entities, such as FTB (e.g., PCS and IM&T programs), Fifth Third Wealth Advisors, LLC (“FTWA”), and Franklin Street Advisors, Inc. • FTS brokerage accounts, including those custodied at NFS. • Variable annuities, variable universal life contracts, 529 Plans, or other mutual fund accounts held 07/08/2026 Summit Managed Account Firm Brochure Page 12 of 36  directly at the investment company. • Insurance products, contracts, annuities, or other accounts held through Fifth Third Insurance Agency, Inc. B. Payment of Fees Investment advisory fees (referred to as the “Program Fee” in the Investment Management Agreement) are calculated at the beginning of each calendar quarter based upon the daily weighted average market value of the assets under management for the previous quarter. Investment advisory fees are automatically deducted from the client’s Summit account and are charged quarterly in arrears in the month following the end of the calendar quarter, generally based on the Standard Investment Advisory Fee Schedule (See Item 5.A. – Investment Advisory Fees and Compensation). C. Additional Fees and Expenses 1) Fixed Income Markups & Markdowns As outlined in Item 5.A. – Investment Advisory Fees and Compensation, Summit accounts are subject to transaction-related charges (markups and markdowns) when FTS buys or sells fixed income securities in your Summit account. 2) Other Fees FTS and the custodian for Summit accounts, NFS, assess additional costs and fees. These costs are not included in the investment advisory fees described above. These costs include but are not limited to the following: wire fee, overnight mailing fee, foreign security movement fee, and stop payment on check fee. Refer to the Investment Advisory Account Service Fee Schedule at the end of this Brochure. a) Mutual Fund and ETP Fees FTS does not charge a sales commission or load for investments in mutual funds or ETPs. However, a client that already owns certain securities that have contingent deferred sales charge (e.g., class B and C share mutual funds) will be subject to that fund company’s charges. Liquidation of these investments reduces the value the client will have to invest in Summit. Clients should carefully review the securities that will be used to fund a Summit account prior to choosing to establish a Summit account. In addition, each mutual fund and ETP have their own expenses, which are described in each mutual fund and ETP’s prospectus. These fees and expenses generally include a management fee, trading costs associated with the underlying securities of the fund, and other expenses, which can also include Rule 12b-1 fees or similar fees for mutual funds. The fees and expenses of a mutual fund and ETP reduce the performance of the account and are embedded in the net return of the mutual fund or ETP. Therefore, the client should review both the total direct and indirect fees and expenses of mutual funds and ETPs. See 5.E. – Additional Compensation and Conflicts of Interest for additional information on how FTS handles Rule 12b-1 fees in your Summit account. b) Mutual Fund Share Classes Some mutual funds have different share classes available, and these share classes have different expenses, including the internal expenses. FTS and our IARs will utilize the cheapest share class of mutual funds that is available to FTS and our IARs at the time of the purchase. However, some mutual funds have different share classes that are not available to FTS and our IARs, and these share classes of mutual funds can be cheaper than those purchased in the client’s Summit account. Summit accounts can be invested in alternative mutual funds which can have higher operating expenses compared to traditional mutual funds, and some alternative mutual funds are considerably more expensive. D. Prepayment of Fees FTS charges investment advisory fees to Summit clients quarterly in arrears; such fees are not paid in advance. E. Additional Compensation and Conflicts of Interest 07/08/2026 Summit Managed Account Firm Brochure Page 13 of 36  1) Mutual Fund Rule 12b-1 Fees Some investment companies (issuers of mutual funds) pay Rule 12b-1 fees to FTS for mutual funds held in a Summit account. When this occurs, FTS will accept these 12b-1 fees and then have these 12b-1 fees reimbursed directly to the client’s Summit account the following month the 12b-1 is credited to FTS. For clarity, if part or all of the 12b-1 fee is retained by NFS, the Investment company (mutual fund company), or any other party other than FTS, these 12b-1 fees are not credited back to the client’s Summit account since FTS did not receive these 12b-1 fees. 2) Fixed Income Markups & Markdowns When fixed income products are purchased or sold in a Summit account, there will be a markup or markdown costs made by the dealers involved in those transactions, which can include NFS or an affiliated entity of NFS. These charges are not separately itemized but are embedded in the price of the security. FTS does not reduce the investment advisory fees that Summit accounts are charged to offset these markups and markdowns. The amounts of the markup/markdown vary based on factors including the type of security, maturity, credit quality, and trading volume, and are not separately disclosed on trade confirmations by FTS or NFS. 3) Conflicts of Interest when Recommending Summit over other Investment Advisory Programs FTS pays fees to FIWA and/or Portfolio Managers (who are not IARs of FTS) in the Passageway Program. These fees range from 0.02% to 0.50% of the daily weighted average market value of the assets under management in Passageway accounts (excluding Advisor Directed Program accounts), of which 0.02% represents the fee that FIWA charges to FTS. When FTS pays these fees to FIWA and/or Portfolio Managers, it reduces the amount of compensation an IAR receives. As a result, an IAR has a conflict of interest in recommending Summit to a client versus other investment advisory programs under Passageway. Critically Important Conflict of Interest: FTS pays fees to FIWA and/or Portfolio Managers in other investment advisory programs in Passageway, which directly reduces the amount an IAR would receive in compensation. As a result, IARs have a financial incentive to recommend to a client a Summit account that will result in greater compensation to the IAR. In addition, FTS IARs must satisfy certain eligibility requirements to offer and provide investment advisory services through Compass. Accordingly, an IAR who does not meet the additional eligibility criteria established by FTS has a conflict of interest when recommending Passageway or Summit instead of Compass, as the IAR would not be authorized to provide advisory services through Compass. 4) NFS Minimum Account Fees FIWA charges FTS a minimum fee for each investment advisory account. This minimum fee varies by program (e.g., Summit, Passageway One, Passageway Focus). As a result, FTS has a conflict of interest to recommend investment advisory accounts only when it expects the investment advisory account, including Summit accounts, will be funded at a level sufficient to cover this minimum fee. To help mitigate this conflict of interest, FTS absorbs the cost of the minimum fee rather than passing it on to our IARs. By not allocating this cost to IARs, FTS reduces the financial incentive for IARs to recommend advisory accounts based on the need to cover the minimum fee. 5) Payment of Investment Advisory Fees to IARs A client’s IAR is generally paid a portion of the investment advisory fees (generally a percentage) charged for a Summit account. The specific amount the IAR will receive will depend on several factors, including but not limited to, the role the IAR has with FTS (e.g., Investment Executive), how long the IAR has been associated with FTS, and the total amount of revenue attributable to the IAR in a calendar year. Specifically, IARs who meet certain revenue thresholds or tiers (e.g., dollar amounts such as $300,000) are eligible for a higher payout percentage of the investment advisory fees, commissions, sales loads, trail commissions, and/or fees from the sales and services associated with the IAR. For example, an IAR whose revenue totaled $200,000 07/08/2026 Summit Managed Account Firm Brochure Page 14 of 36  earns less as a percentage than an IAR whose revenue has totaled $400,000. These tiers create a conflict of interest as they provide a financial incentive for the IAR to increase the revenue associated with them. To help address this conflict of interest, FTS has created an IAR compensation schedule with multiple tiers in which an IAR can earn a higher payout. By creating multiple tiers with smaller percentage increases, this decreases the financial incentive for an FTS IAR to act inappropriately to obtain a higher payout percentage. IARs in an “Investment Executive” role for five or more years or in a partnership with another Investment Executive who has been in the role for five or more years, FTS pays a portion of the investment advisory fees from Summit accounts to the Investment Executive as the investment advisory fees are earned. For all other IARs who can offer investment advisory services through FTS, FTS will advance the first year’s estimated investment advisory fees of a new Summit account to an IAR based upon the market value of the assets in the first month the assets are invested within the Summit account. Then, in the approximate thirteenth month since the opening of the Summit account, FTS will pay the IAR in advance for that month’s anticipated investment advisory fees based upon the market value of the Summit account. 6) Compensation Conflicts of Interest As a result of the receipt of compensation, when an IAR makes a recommendation to a client and that client opens a Summit account, the IAR has a conflict of interest because it is anticipated that the IAR will receive a portion of the investment advisory fees associated with that Summit account. The investment advisory fees earned by an IAR at FTS can be greater than what the IAR would receive at another registered investment adviser firm. The Summit investment advisory fees can be more than what an IAR would receive if a client conducted their transactions in a brokerage account and paid separately for the investment advice, or if the IAR recommended another investment advisory program offered through another FTS. As a result, your IAR has a financial incentive to offer a Summit account over a brokerage account or other investment advisory accounts through another FTS investment advisory program. 7) Bonuses & Performance Based Compensation Some IARs are eligible for bonuses or other performance-based compensation. This performance-based compensation is based on a number of factors and generally includes the overall revenue associated with the IAR, which will often include FTS, Fifth Third Insurance Agency, Inc. (“FTIA”), and/or FTB activities and revenue. Certain individuals who are in a role with FTB and oversee an FTB branch office have the potential to receive performance-based compensation based in whole or in part on the branch’s performance metrics. The branch receives credit for FTS-related revenue, including investment advisory fees resulting from your Summit account. 8) Conflicts Related to Active Trading and No Charge Investments FTS does not charge Summit clients a ticket charge or commission for securities transactions placed in a Summit account. However, FTS is charged by NFS for securities transactions of certain investments in Summit accounts. Therefore, FTS has an incentive to lower or limit the number of securities transactions in investments that NFS charges FTS. To help mitigate this conflict of interest, FTS’ IARs do not directly share in the costs of securities transactions when they are placed in a Summit account, nor does FTS notify IARs of which investments NFS charges FTS. 9) Recruitment Compensation FTS provides recruitment compensation to IARs who join FTS. There are generally three types of recruitment compensation methods that FTS can use when an IAR joins our firm. a) Forgivable Draw Compensation The forgivable draw recruitment compensation will generally be broken into two segments. In the first segment, the IAR will generally receive a bi-weekly forgivable draw for the first 6 calendar months and a higher payout percentage for the first 6 calendar months. In the second segment, the IAR will generally 07/08/2026 Summit Managed Account Firm Brochure Page 15 of 36  receive either a forgivable or non-forgivable draw and a higher payout percentage for the subsequent 12 calendar months. The determining factor whether the draw is forgivable or non-forgivable in the second segment is dependent upon either the amount of revenue associated with the IAR for that time period or the amount of the total market value of the assets brought to FTS during that time period. Generally, recruitment compensation is limited to a time period of no greater than 24 calendar months to allow the IAR to transition to FTS. However, depending on the individual circumstances of the IAR, FTS could deviate from these stated timeframes by going longer or shorter for either segment, or having an overall longer or shorter time period for the recruitment compensation. FTS has established written policies and procedures, controls, and processes that are reasonably designed to provide a supervisory structure that oversees the Summit Program and FTS’ IARs. b) Upfront Forgivable Loan or Promissory Note An upfront forgivable loan (or promissory note) is an upfront payment paid by us to the IAR when the IAR joins our firm. The IAR doesn’t have to repay the loaned amount if the IAR stays with us for the duration of the loan or note and the IAR meets specified revenue targets within defined time periods (e.g., monthly, quarterly). The specific length of time period of the upfront forgivable loan can vary from IAR to IAR. However, generally speaking, a larger upfront forgivable loan will result in a longer time period the upfront forgivable loan will last. An example of how the upfront forgivable loan generally works, if an IAR received a three-year upfront forgivable loan and the IAR meets the revenue threshold in March, then 1/36 or approximately 2.78% of the upfront forgivable loan has been forgiven by us and the IAR no longer needs to pay back this amount. An upfront forgivable loan creates a conflict of interest for the IAR because the IAR has a financial incentive to meet monthly revenue thresholds. However, with respect to Summit accounts, these IARs are subject to a fiduciary duty to act in the best interests of Summit clients when making recommendations. FTS helps address this conflict by having a separate group of securities registered principals that review the sales activities of Summit, and these registered principals do not directly receive compensation from the recommendations made by IARs. c) Sign-On Bonus A sign-on bonus is an upfront payment provided to an IAR upon joining FTS. This bonus is structured to incentivize a long-term relationship and is contingent upon the IAR remaining with FTS for a specified period and meeting certain production or performance expectations during that time. The specific terms, including the amount of the sign-on bonus and the applicable time horizon, can vary based on individual circumstances and business considerations. A sign-on bonus creates a conflict of interest by providing a financial incentive tied to an IAR’s continued employment and performance. However, with respect to Summit accounts, these IARs are subject to a fiduciary duty to act in the best interests of Summit clients when making recommendations. FTS helps address this conflict by having a separate group of securities registered principals that review the sales activities of Summit, and these registered principals do not directly receive compensation from the recommendations made by IARs. 10) Minimum Guaranteed Payout Percentage FTS generally pays our IARs a percentage of the commissions, sales loads, trail commissions, and/or fees received from the sales and services associated with the IAR (otherwise known as the “payout percentage”). An IAR in the role of an Investment Executive or a Private Bank Investment Executive, when that IAR is initially registered with FTS, is provided with a minimum guaranteed payout percentage. This guarantees that the Investment Executive or Private Bank Investment Executive’s payout percentage will be at a certain percentage for a specified time period. The minimum guaranteed payout percentage is used even if the actual compensation associated with the Investment Executive or Private Bank Investment Executive’s activities is lower than normally required. 07/08/2026 Summit Managed Account Firm Brochure Page 16 of 36  It is anticipated that the minimum guaranteed payout percentage will be higher than the standard payout percentage when an Investment Executive or Private Bank Investment Executive initially starts with FTS. When we provide an Investment Executive or Private Bank Investment Executive with a minimum guaranteed payout percentage, we do so to help reduce the conflict of interest that can occur when an Investment Executive or Private Bank Investment Executive initially starts with FTS and is making recommendations to clients. The length of time that the minimum guaranteed payout percentage is in place can vary from IAR to IAR, but when we offer the minimum guaranteed payout percentage, it will generally last 24 months from the date the IAR starts with FTS or enters a new role with FTS. However, depending on the individual circumstances of the IAR, we could deviate from these stated timeframes by going longer or shorter for either segment, or having an overall longer or shorter time period for the recruitment compensation. 11) Back-End Asset Based Bonus A back-end asset-based bonus is a payment that is earned by an IAR after joining FTS, contingent upon achieving specified asset levels within a defined period of time. This bonus is typically calculated based on the amount of client assets transitioned to or maintained with FTS and is payable only if the applicable asset thresholds and retention requirements are met. The structure, measurement period, and payout timing of a back-end asset-based bonus are anticipated to vary depending on individual circumstances and business considerations. The Back-End Asset Based Bonus creates a conflict of interest due to the financial incentive provided to the IAR to encourage the transfer or retention of assets. However, in Summit these IARs have a fiduciary duty to Summit clients for their Summit accounts when making recommendations. We help mitigate this conflict through supervisory and compliance controls, including independent review of applicable transactions by supervisory personnel who do not receive compensation based on the assets gathered or the recommendations made by IARs. Furthermore, we help mitigate this conflict of interest by having the Back-End Asset-Based Bonus not tied to any specific product type or service (e.g., brokerage assets versus investment advisory/Summit). 12) Retention Compensation Upon occasion, we provide retention compensation to IARs to remain with FTS. A retention bonus is a payment that is provided to an IAR in connection with their continued registration and performing securities- related activities with FTS over a specified period of time. This bonus is typically contingent upon the IAR remaining with FTS through the applicable retention period, and in some cases, meeting certain performance, production, or asset retention expectations during that time. The structure, amount, and duration of a retention bonus are anticipated to vary based on individual circumstances and business considerations. A retention bonus creates a conflict of interest because it provides a financial incentive for the IAR to remain with us and maintain client relationships with FTS. However, in Summit these IARs have a fiduciary duty to Summit clients for their Summit accounts when making recommendations. We help mitigate this conflict through established supervisory and compliance processes, including independent review of Summit accounts by supervisory personnel who do not receive compensation based on retention- related incentives or recommendations. 13) Retirement Compensation IARs in the role of an Investment Executive have the potential to participate in the receipt of compensation after their retirement from FTS and the securities industry. An Investment Executive’s eligibility in FTS retirement compensation program is dependent upon a number of factors, including but not limited to, the Investment Executive’s tenure with FTS, an Investment Executive’s age, completion of pre-retirement criteria, and/or compliance with various regulatory requirements to receive compensation after their termination from FTS and the securities industry. An Investment Executive’s retirement compensation (payout percentage) is based on the total revenue earned in the rolling 12-months prior to retiring. The payout percentage based upon last rolling 12-months creates a conflict of interest for the retiring Investment Executive since it creates a financial incentive for 07/08/2026 Summit Managed Account Firm Brochure Page 17 of 36  the retiring Investment Executive to increase their revenue so they can receive more compensation in their retirement. We help mitigate this conflict by having a separate group of securities registered principals review the activities of IARs. These registered principals do not directly receive compensation from the recommendations made by IARs and will at times use tools and systems designed to aid their supervisory reviews based upon various risk-based information. Additionally, we have provisions in the IARs’ compensation plans that provide for the recovery, withholding, repayment, or “clawback” of compensation due to violation of policy, procedures, or state and federal laws or regulations. 14) IAR Forfeiture of Compensation Certain activities or failure to perform certain activities will or can result in the forfeiture of an IAR’s receipt of their portion of the investment advisory fee. This includes the following: • FTS requires its IARs to conduct an annual review meeting with Summit clients. If an annual review is not conducted in a calendar year starting the year after the Summit account is opened, the IAR will have their portion of investment advisory fees for that Summit account forfeited until a review has been conducted with the applicable Summit client. Once the annual review has been conducted, the IAR will begin to receive the portion of the investment advisory fees for that Summit account again. • As part of the due diligence of the securities made available in Summit for IARs to manage, securities will be removed from the available list when the security does not meet certain criteria. Once a security is removed from the available list, the IAR will have a specified time period to have the security or securities removed from the Summit account as a managed asset. If an IAR does not sell, exchange, or work with the client to transfer the removed security or securities from an Summit account within the prescribed time period, then the IAR’s portion of the investment advisory fees are forfeited until the security is no longer held in the Summit account as a managed asset. Once the removed security is no longer in the Summit account, the IAR will receive the portion of the investment advisory fees for that Summit account again. Notwithstanding this process, an IAR can seek an exception from FTS to this process for non- qualified accounts (e.g., Individual, Transfer on Death, Joint accounts) where the IAR would not be required to remove the applicable security for up to one year. If an IAR’s exception request is approved by FTS, the client is sent a written notification informing them that the security or securities no longer meets the due diligence requirements but are being retained in the Summit account. In this scenario, the IAR continues to receive the investment advisory fees associated with the Summit account. • When a Summit account’s value is below $25,000, the IAR does not receive any compensation associated with your Summit account. Additionally, when a Summit account’s value is between $25,000 and $49,999.99, your IAR does not receive compensation from the Summit account unless the client has total household assets of $50,000 or more with FTS. In addition to the aforementioned reasons, FTS can, as a part of disciplinary action, cause the forfeiture or withholding of an IAR’s portion of investment advisory fees associated with a specific Summit account or accounts when an IAR acts materially different from FTS’ expectations or policies and procedures. 15) Conflicts Related to IAR Production Standards As part of an IAR’s continued registration and/or employment with FTS, FTS has established minimum production standards based upon the tenure of the IAR with FTS. Failure by an IAR to meet FTS’ minimum production standards results in an evaluation of the overall performance and activity of the IAR, which can lead to the deregistration and/or termination of employment. To help mitigate this conflict of interest, when an IAR does not meet the production standards, FTS does not automatically deregister or terminate the employment of the IAR, but first FTS conducts and 07/08/2026 Summit Managed Account Firm Brochure Page 18 of 36  evaluation to help determine the rationale for the IAR’s current production. The evaluation can include but is not limited to the workplace behaviors (e.g., showing up to the office, hours being worked), frequency of contact with clients, client follow-ups, personal events (e.g., death of a family member), and other activities related to the IAR’s work activities. 16) Conflicts Related to Recommending Summit Account vs. Brokerage Account Due to the on-going relationship and the advisory fees associated with a Summit account, FTS and FTS’ IARs have a financial conflict of interest when recommending a Summit Account over a Brokerage Account as FTS and FTS IARs have the possibility to earn more compensation than they potentially would in a Brokerage Account. FTS helps address this conflict by having a separate group of securities registered principals that review the solicited Summit Accounts by IARs, and these registered principals do not directly receive compensation from the recommendations made by FTS’ IARs. Furthermore, FTS helps address this conflict by requiring FTS’ IARs to complete paperwork with clients when recommending the opening of a new Summit Account. This paperwork outlines the types of services the client is seeking (e.g., on-going reviews of accounts and assets). Clients who are not seeking to have FTS or FTS’ IARs to provide on-going management of their account, should not open a Summit Account. 17) Conflicts Related to Mutual Fund Revenue Sharing FTS has fee arrangements with some mutual fund companies (which also includes companies that offer ETPs) that issue mutual funds that are available for purchase in the Summit Program. These payments are often referred to as “revenue sharing.” However, each of these revenue sharing arrangements with mutual fund companies (which also includes companies that offer ETPs) are solely related to FTS’ Institutional Brokerage business and do not apply to the mutual funds held in Summit accounts. Under these revenue sharing arrangements, the mutual fund company can pay FTS a fee based that is based off: 1. The amount of client sales; 2. Assets invested in the mutual company’s mutual funds; and/or 3. A fixed fee. The actual amounts that FTS receives can vary from one mutual fund company to another and can have a minimum dollar amount prior to FTS being eligible to receive a revenue sharing payment. In all cases, such revenue sharing payments will be paid to FTS from the mutual fund company’s own resources and not directly from client funds or assets. Such arrangements will have no impact on the fees being charged to clients by FTS and our IARs. FTS provides marketing support to the mutual fund company and allows the mutual fund company to access FTS’ IARs so that the mutual fund company can promote their mutual funds. This revenue share arrangement creates a conflict of interest by incentivizing FTS to have clients invest in mutual funds that provide revenue share instead of mutual funds that do not make revenue sharing payments to FTS. FTS does not directly share revenue sharing payments with our IARs. Since FTS’ IARs receive no direct portion of the revenue share that is received by FTS, FTS does not believe its IARs have a conflict of interest when selecting one mutual fund over another mutual fund as a result of these revenue sharing arrangements. Lastly, in order to mitigate this conflict of interest, currently FTS does not receive revenue share payments on any of the assets in mutual funds that are held in Summit accounts. Please visit the bottom of https://www.53.com/investments/mutual-funds.html for the list of the mutual fund companies that FTS has a revenue sharing arrangement with. 18) Conflicts Related to Receipt of Educational, Marketing, & Other Financial Support FTS and our IARs have a conflict of interest as a result of when Portfolio Managers, service providers, and products companies, such as mutual fund companies, unit investment trust sponsors, annuity companies, life insurance companies, ETP companies, or their affiliates, reimburse or cover the costs for FTS and/or our IARs for the following activities: marketing, business and client development, educational 07/08/2026 Summit Managed Account Firm Brochure Page 19 of 36  enhancement, and/or due diligence reviews incurred by FTS and/or an IAR related to the promotion or sale of the Portfolio Manager services or product company’s products (e.g., mutual fund, ETP). This compensation is also used to subsidize the cost of education programs, such as conferences we offer to our IARs, which include travel and travel-related expenses, meals, overnight lodging, speakers, and entertainment. Portfolio Managers, products companies, and service providers that participate in these events gain the opportunity to interact with our IARs and their supervisors, and it is anticipated that these interactions will result in additional sales of those products or services associated with those Portfolio Managers and product companies. Accordingly, a conflict of interest exists where we offer opportunities to Portfolio Managers, products companies, and service providers that are willing to cover expenses and/or pay us to cover expenses as compared to Portfolio Managers, products companies, and service providers that do not. IARs do not directly receive a portion of this compensation. However, IARs’ attendance and participation in these events can be expected to lead IARs to recommend and direct investments to the Portfolio Managers, products companies, and service providers that provide this compensation as compared to Portfolio Managers, products companies, and service providers that do not. Item 6 – Performance-Based Fees and Side-By-Side Management FTS does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. FTS and our IARs do not engage in side-by-side management. Item 7 – Types of Clients Summit is available to individuals, high net worth individuals, trusts, estates, foundations, charitable institutions, corporations, private pension plans, and other business entities or organizations with sufficient liquid assets to participate in Summit. Summit is not intended for government entities (federal, state, or municipal) or for public pension plans. Summit clients are required to promptly notify FTS in writing of any material changes to their information previously provided to FTS. Some examples include: Investment objective Investment time horizon • • Risk tolerance • Net worth • Annual income • • Address Failure by the client to provide FTS with current, accurate information could adversely affect FTS and our IARs’ ability to effectively manage the client’s assets within Summit. A Summit account requires a certain minimum dollar value of either cash or marketable securities that are acceptable to FTS before FTS approves an account. The Summit account minimum is $100,000. In addition, FTS and our IARs, or FIWA, at their discretion, can terminate a Summit account if the Summit account falls below the $100,000 account-opening minimum. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis and Investment Strategies FTS’ IARs utilize various sources of information, which can include but is not limited to, financial newspapers and magazines, inspection of corporate activities, research materials prepared by others, corporate rating services, annual reports, prospectuses, materials provided by FIWA, filings with the U.S. Securities and Exchange Commission, and other publicly available tools and information sources. An IAR of FTS will meet with a prospective client to interview and complete an investor profile. During this interview the IAR gathers information regarding the client’s risk tolerance, investment objectives, and 07/08/2026 Summit Managed Account Firm Brochure Page 20 of 36  financial information. With this data, the IAR assists the client in determining whether Summit is appropriate for them and recommends an investment style and an asset allocation model for the Summit account to the client. Each Summit account is invested in securities aligned with the client’s selected risk tolerance. However, FTS can invest a client’s account in a portfolio corresponding to a risk tolerance that is one level more conservative than the client’s selected risk tolerance. The client’s Statement of Investment Selection or Advisory Supplemental Form reflects the selected asset allocation model. As noted above, FTS and our IARs are responsible for the selection and monitoring of investments in the Summit account after the client has signed the Statement of Investment Selection or the Advisory Supplemental Form and funded the Summit account. Information about the risks associated with those investments can be found in the corresponding investment’s prospectus, if applicable. In addition to this Brochure, a copy of the IAR’s Investment Advisor Supplemental Brochure (ADV Part 2B) is provided to the client at or prior to the establishment of the Summit account. Clients can request another copy of this Brochure or their IAR’s ADV Part 2B at any time by contacting their IAR or contacting FTS at the phone number listed on the cover page of this Brochure. Diversification and asset allocation can help reduce the risk of a portfolio, but they do not remove all risk or chance of loss of the original amount invested or the gains earned in a Summit account. Periodically the Summit account is rebalanced to help provide consistency with the client’s ongoing investment objectives and the asset allocation. B. Material, Significant, or Unusual Risks Relating to Investment Strategies Different types of investments and investment strategies involve varying degrees of risk, and it should not be assumed that the future performance of any specific investment or investment strategy will be profitable. This includes the investments and investment strategies recommended or undertaken by FTS or our IARs. Investments are not obligations of, and are not guaranteed by, FTS, FTB or any of our other affiliates, and are not Federal Deposit Insurance Corporation (“FDIC”) or government insured. Investments are subject to risks, including possible loss of the principal amount invested. Losses can occur with any investment or strategy, including conservative investments or strategies. The more risk the client is willing to bear, the greater the potential for loss of the principal amount invested by the client or loss of unrealized gains on assets held in the Summit account. Additional information about the risks concerning a particular mutual fund or ETP can be found in the respective mutual fund or ETP’s prospectus. Clients of Summit should be prepared to bear the risk of loss associated with having a Summit account. Portfolio goals and objectives are not guaranteed and may not be achieved. Past performance does not guarantee future results. Summit accounts and the securities in the client’s Summit account can be subject to the following risks: 1) Risk of Asset Value Loss The investment strategy or strategies provided by FTS and our IARs, including the conservative models, involve the risk of loss including the loss of the original investment amount or loss of unrealized gains on assets. Clients should have a willingness to incur such losses in connection with investments in the Summit, especially if the client invests for a shorter period of time. By investing in Summit, clients can lose money by investing in stocks, bonds, mutual funds, ETPs, or other securities or by the investment strategy or strategies used by the IAR. Many factors affect each investment’s or Summit account’s performance. Nearly all investments and Summit accounts are subject to volatility in non-U.S. markets, through either direct investment exposure or indirect effects in U.S. markets from events occurring abroad, including adverse political, social, economic, or market occurrences. Additionally, investments or Summit accounts that pursue debt exposure are subject to risks, including, but not limited to, prepayment risk, default risk, and interest rate risk. In addition, funds, ETPs, and investment strategies that pursue strategies that concentrate in specific sectors or industries or are otherwise subject to particular segments of the market (e.g., healthcare, technology, real estate, financial, or international) can be significantly impacted by events affecting those sectors, industries, or markets. Mutual funds or ETPs that invest in other funds bear all the risks inherent in the underlying investments in which those funds invest. Strategies that pursue 07/08/2026 Summit Managed Account Firm Brochure Page 21 of 36  leveraged risk, including investment in derivatives — such as options, swaps (interest rate, total return, and credit default) and futures contracts — and forward-settling securities, magnify market exposure and losses. Mutual funds, ETPs, and Summit accounts are also subject to operational risks, which can include risk of loss or losses arising from failures in internal processes or systems, or people, such as routine processing errors or major systems failures, or from external events, such as exchange outages. 2) Interest Rate Risk The bond market is volatile, and bonds and other fixed income securities carry interest rate risk. Interest rate risk is generally expected to occur when the interest rate changes, but interest rate risk can also occur when market expectations of interest rate changes (or lack thereof) do not occur. Interest rates and bond prices generally have an inverse relationship; meaning that when interest rates increase the values of bonds decrease (and the opposite will generally occur when interest rates decrease). Generally, the longer the duration of a bond, the greater the impact on the valuation of the bond. For example, an interest rate increase will generally have a greater impact (an expected decrease in value) on a 20-year bond versus 5- year bond by the same issuer with same or similar terms. Fixed income securities also carry inflation risk and credit and default risks for both issuers and counterparties. Most bond funds do not have a maturity date, so holding the bond funds until maturity to avoid losses caused by price volatility is not feasible. Additionally, certain types of bonds can be less liquid than more actively traded investments, meaning bonds can be difficult to sell quickly or without accepting a lower price, which can result in a significant loss to you when sold. 3) Credit Risk Issuers of debt and other counterparties may be unable to make interest or principal payments when due or otherwise honor their debt obligations. Credit rating changes of the issuer can adversely affect the value of the debt instrument or security. Additionally, changes in the financial condition of an issuer or counterparty(ies) and/or changes in specific economic or political conditions that affect a particular type of security or issuer, can increase the risk of default by an issuer or counterparty, which can affect a security or instrument’s credit quality or value. Lower-quality debt securities involve greater risk of default or price changes due to changes in the credit quality of the issuer. 4) Cybersecurity Risk Companies, markets, investment companies, including ETPs and mutual fund companies, and services providers, like FTS, FIWA, and NFS, use significant amounts of technologies in their day-to-day functions. As a result, these entities and those individuals who use these services or have investments in companies are subject to numerous cybersecurity risks. Cybersecurity risks include, but are not limited to, compromised company, employee or client data, disruption of services, corruption or loss of data, inability to perform services (e.g., trading, valuation, issuance of reports, communications), and financial losses. 5) Artificial Intelligence (“AI”) Risk Technology advances in AI and machine learning technologies (e.g., ChatGPT, Gemini, Grok, etc.) create risks for users of these technologies, including FTS, our IARs, FIWA, and NFS. AI is a fast-evolving technology that has several risks associated with it, including but not limited to the following: • Confidential information Exposure: Accidental or intentional use of confidential or sensitive information into AI or machine learning technologies can result in the dataset being accessible by other AI technologies and/or users which could lead to unauthorized disclosure or misuse of client or firm data. • Bias and Factual Inaccuracies Risks: AI can be prone to algorithmic biases and present false or misleading information as factually accurate, known as “hallucinations”. AI hallucinations can be created by flawed data training, AI’s misinterpreting data or patterns, source of data is inaccurate, or the AI model will struggle to accurately understand real-world knowledge or factual information. 07/08/2026 Summit Managed Account Firm Brochure Page 22 of 36  • Model Risk: Models (e.g., portfolio management models, predicative models, risk assessment models, etc.) created, managed, or assisted by AI, can behave unpredictably if trained on biased, incomplete, or outdated data. This can lead to model issues such as poor investment decisions or misaligned risk assessments. • Regulatory Uncertainty: The legal and regulatory landscape governing AI is still developing and may go through rapid changes. Future changes in laws or regulations will impact on how AI can be used by financial institutions, potentially requiring changes to business practices or technology infrastructure, which could negatively impact FTS, our IARs, FIWA, and NFS current and future use of AI. 6) Derivatives Risk A derivative can be defined as a financial instrument or contract which derives its value from one or more underlying financial instruments such as an asset, index, or interest rate. A mutual fund or ETP’s use of derivatives can reduce the returns of your Summit account and/or increase the volatility Summit clients are exposed to. Derivatives are also subject to counterparty risk, which is the risk that the other party in the transaction will not fulfill its contractual obligation. Derivatives may give rise to a form of leverage, and when leverage is used in a mutual fund, ETP, or other security or investment strategy there is greater risk and often higher costs. C. Risks Associated with Particular Types of Securities 1) Investments in a Summit Account A Summit account will be invested in various securities, which will depend on the individual strategy(ies) determined by the IAR and the client. These securities will employ various investment strategies, and each investment strategy has a number of risks associated with it. Therefore, Summit accounts and the securities held within the Summit account are subject to these risks and clients can lose a substantial amount of their original investment in Summit. For more information regarding the risks associated with a mutual fund or ETP, please refer to the corresponding prospectus. 2) ETFs An ETF is a fund that trades on an exchange throughout the trading day, similar to stocks, and often seeks to track an index (e.g., S&P 500® Index), commodity or commodities (e.g., oil, natural gas, gold, precious metals, etc.), or a basket of assets based upon a theme, territory, or sector (e.g., healthcare, energy, international stock, consumer staples, dividend appreciation, emerging markets China, etc.). As a result, ETFs often do not have the objective to outperform what they are tracking. However, some ETFs are actively managed and do not seek to track a certain index or basket of assets. ETFs can also have unique risks depending on their structure and underlying investments. ETFs can trade at a premium (above) or discount (below) to their net asset value (“NAV”), and ETFs can also be affected by the market fluctuations of their underlying investments. If FTS or a client decides to terminate the Summit account during a down market or when ETFs are experiencing a large volume of redemptions, the value of the ETFs can be significantly below the NAV of the underlying assets held in the ETFs. ETFs can experience further below market valuations if the ETF has invested in illiquid or investments that have experienced less liquidity causing the ETF to take below desired valuations to cover redemptions from shareholders. Additionally, some ETFs have not experienced a down market, and there can be unknown risks associated with ETFs. 3) ETNs An ETN is an unsecured debt obligation of the issuer (usually an investment bank or another financial institution) that often seeks to track a market or strategy and provide returns linked to the performance of a specified index, minus applicable fees. ETNs trade on an exchange throughout the trading day similar to stocks and ETFs but they do not buy or hold assets to replicate or approximate the performance of the underlying index. In addition, ETNs generally do not seek to outperform what they are tracking. Because ETNs are debt instruments, they carry credit risk, meaning a client’s return depends on the financial stability and creditworthiness of the issuer. ETNs can also trade at a premium (above) or discount (below) their 07/08/2026 Summit Managed Account Firm Brochure Page 23 of 36  indicative value, particularly when market supply and demand fluctuate or if the issuer suspends new issuance. If FTS or a client decides to terminate the Summit account during periods of market stress, reduced liquidity, or concerns about the issuer’s financial health, the value of ETNs may be significantly impacted. Additionally, ETNs can include maturity dates as well as call provisions or early redemption features depending on the specific terms of the ETN, and some may have limited trading activity, which can increase volatility and reduce liquidity. As with ETFs, some ETNs track complex or less-tested strategies, and there may be unknown risks associated with ETNs. 4) ESG, SRI, Faith Based, and Similar Investments and Investment Strategies IARs that engage in Environmental, Social, and Governance (“ESG”), Socially Responsible Investing (“SRI”), Faith Based Investing, or similar investment strategy or strategies will generally choose to avoid investments and/or companies that might otherwise be considered appropriate investment options due to factors that can run contrary to the ESG, SRI, or Faith Based investment strategy. As a result, clients selecting an IAR or having an IAR invest in ESG, SRI, Faith Based, or similar investment strategy can result in lower returns than if the IAR had used a non-ESG, SRI, Faith Based, or similar investment strategy or investments. Furthermore, an IAR’s selection process to include and/or exclude investments can be based upon a number of factors, such as imposing a minimum revenue associated with the activity seeking to be avoided (such as Adult Entertainment). As a result, even if a client selects an ESG, SRI, Faith Based, or similar investment strategy with the IAR, the client could still be invested in investments or companies that the client is seeking to avoid. Additionally, clients selecting an investment strategy or focus on ESG, SRI, Faith Based, or other similar investment strategy with the IAR should refer to the mutual fund or ETN’s prospectus for more details on the ESG, SRI, or Faith Based investment strategy. FTS does not guarantee that a client’s specific ESG, SRI, or Faith Based goals or client’s interpretation of what the ESG, SRI, Faith Based or similar investment strategy will be represented by an IAR or the underlying investments selected. ESG, SRI, Faith Based, or similar investment strategies can be interpreted differently. For example, an IAR that has an investment strategy to invest in “clean energy” might consider companies involved in solar and nuclear energy as clean energy options. Whereas a client may not consider solar and nuclear energy sectors as “clean energy.” 5) Foreign Exposure Foreign securities, like domestic U.S. securities, are subject to market volatility risk, performance of underlying assets, regulatory risks, economic developments, and other factors that can significantly impact the valuation of a fund or security. In addition, foreign securities are subject to foreign interest rate(s), currency exchange rate, regulatory, geopolitical risks, and other risks, all of which can be greater in emerging markets. These risks are particularly significant for funds that focus on a single country, region, or emerging markets. Foreign markets will at times be more volatile than U.S. markets and can perform differently from the U.S. market. Emerging markets can be subject to greater social, economic, regulatory, and political uncertainties and can be extremely volatile. Foreign exchange rates can also be extremely volatile and can lead to significant losses. As an example, a fund’s underlying assets could have a positive performance; however, the fund’s value could decrease due to current currency exchange rate changes. 6) Legislative and Regulatory Risk Securities and investment strategies used in the Summit account can be adversely affected by new laws or changes to existing laws or regulations. Changes to laws, regulations, or government policies can impact the securities markets as a whole, specific industries, individual issuers of securities, and individual securities. These changes can affect the value, liquidity, or performance of your investments and could occur without prior notice. 7) Money Market Fund Clients could lose money by investing in a money market fund. Although a money market fund generally seeks to preserve the value of a client’s investment at $1.00 per share, FTS, our IARs, and the fund cannot guarantee it will preserve the value of $1.00. A client’s investment in a money market fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. FTS and our 07/08/2026 Summit Managed Account Firm Brochure Page 24 of 36  IARs, NFS and its affiliates, the money market fund’s sponsor, have no legal obligation to provide financial support to money market funds and client is not to expect that the money market fund’s sponsor will provide financial support to the fund at any time. 8) Municipal Bonds The municipal market is affected by adverse tax, legislative, or political changes, and by the financial condition of the issuers of municipal securities. Municipal funds normally seek to earn income and pay dividends that are expected to be exempt from federal income tax. If a fund investor is a resident in the state of issuance of the bonds held by the fund, interest dividends may also be exempt from state and local income taxes. Income that is exempt from regular federal income tax can be subject to state, local, or federal alternative minimum tax. Certain funds normally seek to invest only in municipal securities generating income exempt from both federal income taxes and the federal alternative minimum tax; however, outcomes cannot be guaranteed, and the funds sometimes generate income subject to these taxes. For federal tax purposes, a fund’s distribution of gains attributable to a fund’s sale of municipal or other bonds are generally taxable as either ordinary income or long-term capital gains. Redemptions, including exchanges, can result in a capital gain or loss for federal and/or state income tax purposes. Tax code changes could affect the municipal bond market. Tax laws are subject to change, and tax law changes or proposed changes can cause the prices of tax-exempt securities to decrease and/or affect the tax-exempt status of securities and securities that hold tax-exempt securities. 9) Stock Markets and Investments Stock markets are volatile and can decline significantly in a short amount of time in response to adverse issuer, political, regulatory, market, or economic developments. Different parts of the market can react differently to these developments. Value and growth stocks can perform differently from other types of stocks. Growth stocks can be more volatile. Value stocks can continue to be undervalued by the market for long periods of time. In addition, stock investments are subject to risk related to market capitalization as well as company-specific risk. Depending on the number of factors, such as, market events, the client’s risk tolerance, and the IAR’s investment strategy or strategies, an IAR may not make any changes to the investment strategies, or the investments used in a Summit account even when the stock markets incur significant losses. FTS and our IARs can invest in alternative mutual funds or ETPs, which can use investment strategies that differ from the buy-and-hold strategy typical in the fund industry. Compared to a traditional mutual fund, an alternative fund typically holds more non-traditional investments and can employ more complex trading strategies. Some examples of assets that can be held in alternative mutual funds include, but are not limited to, managed futures, arbitrage, commodities, leveraged loan, global real estate, master limited partnerships, and option contracts. Clients considering a strategy that utilizes alternative investments in a Summit account should be aware of their unique characteristics and risks. In addition to the risks listed above, some of these risks can include, but are not limited to: • Investment Structure: An alternative mutual fund made up of other mutual funds (often referred to as “fund of funds”) can offer greater diversification than a single-strategy or even multi-strategy alternative mutual fund or traditional mutual fund. At the same time, this greater diversification can lead to a flattening of return and potentially less transparency. There can also be an inability to re-allocate or adapt in a way that is beneficial to the overall performance of a particular fund of funds. • Leverage Risk: Using derivatives, such as commodity futures and options to increase the alternative mutual fund’s combined long and short exposure creates leverage, which can magnify the alternative mutual fund’s potential for gain or loss and, therefore, amplify the effects of market volatility on the alternative mutual fund’s share price. • Liquidity Risk: Liquidity risk exists when particular investments of an alternative mutual fund or ETP would be difficult to purchase or sell, possibly preventing the alternative mutual fund or ETP from 07/08/2026 Summit Managed Account Firm Brochure Page 25 of 36  selling such illiquid securities at an advantageous time or price, or possibly requiring the alternative mutual fund or ETP to dispose of other investments at unfavorable times or prices in order to satisfy the alternative mutual fund or ETP obligations. • Strategy Risk: In addition to the usual market and investment specific risks mutual funds have, alternative mutual funds can carry additional risks from the strategies they use. For example, market-neutral funds tend to have significant portfolio turnover risk that will generally result in higher costs. Similarly, a distressed bond fund is likely to have significant credit risk. 10) Tracking Error Tracking error risk generally applies to securities (such as an ETP) and investment strategies used by our IARs that attempt to track a market index (such as S&P 500® Index) and the deviation of actual performance the client realizes from the performance of the market index it attempts to track. Tracking error can result from numerous factors including but not limited to trading costs, management fees, cash holdings, market conditions - particularly sudden and extreme market changes, client-imposed restrictions, imperfect weighting between the securities and the market index, and changes to the composition of the market index. It is anticipated that tracking error risk will cause the performance of a client’s Summit account or the security or securities within a Summit account to be less or more than the market index. 11) Additional Risks For more risks specific to the underlying assets and the investment strategy used by an IAR, please refer to the mutual fund or ETP’s prospectus. Mutual fund and ETP’s prospectuses can be requested from FTS at any time through one of FTS’ IARs. Item 9 – Disciplinary Information FTS has no material civil or criminal actions or administrative proceedings to report. Below are regulatory events associated with FTS for the past 10 years, but these regulatory events are not limited to FTS’ registered investment advisor. Many of these regulatory events involve FTS’ broker-dealer and not the investment advisory business of FTS. Additional regulatory events involving FTS’ broker-dealer that date further back than 10 years and additional details regarding the below listed FINRA disciplinary actions are found at https://brokercheck.finra.org/firm/summary/628. FINRA – 05/08/2018 - Without admitting or denying the findings, FTS consented to the findings that FTS failed to fully comply with an undertaking from a previous Acceptance Waiver and Consent entered into with FINRA in 2009. In addition, FTS made material misstatements and omissions in approximately 77% of a sample set of 250 variable annuity exchanges randomly selected and reviewed by FINRA from among 1,431 variable annuity exchanges. Misstatements and omissions about the cost or benefits of the variable annuity exchange made the exchange appear more beneficial to the customer. FTS also failed to implement a supervisory structure reasonably designed to ensure that its registered representatives obtained and assessed accurate information about the customer’s existing and proposed variable annuities prior to affecting the exchanges. These activities did not involve FTS’ registered investment advisor, nor did it involve FTS’ Summit Program. SEC – 07/18/2023 - FTS settled allegations of wrongdoing by the SEC, in which the SEC alleged that 79 municipal bond underwriting offerings sold to broker-dealers and/or registered investment advisors failed to comply with municipal bond offering disclosure requirements under Rule 15c2-12 of the Securities Exchange Act of 1934 and found that FTS’ policies and procedures weren’t reasonably designed to determine if the broker dealers and/or registered investment advisors satisfied the exemption requirements under Rule 15c2- 12. FTS agreed to cease-and-desist from future violations of those provisions, be censured, and pay $442,465.59 in disgorgement plus prejudgment interest of $67,506.09 to the SEC and a $200,000 civil money penalty. Additional details regarding this Order are found at https://www.sec.gov/files/litigation/admin/2023/34-97937.pdf. These activities did not involve FTS’ registered investment advisor, nor did it involve FTS’ Summit. 07/08/2026 Summit Managed Account Firm Brochure Page 26 of 36  SEC – 09/29/2023 - FTS settled allegations of wrongdoing by the SEC, where from January 2019 to 2022, FTS employees sent and received Off-Channel Communications that related to the business of the broker-dealer and registered investment advisor. Due to the fact that these communications were not sent or received on FTS systems, FTS failed to surveil, maintain, or preserve these communications. As a result, FTS was required to cease-and-desist from further violation of SEC Rules related to retention of required books and records, pay a civil money penalty in the amount of $8,000,000, and take remedial measures including the hiring of an independent consultant. Additional details regarding this Order are found at https://www.sec.gov/files/litigation/admin/2023/34-98627.pdf. Item 10 – Other Financial Industry Activities and Affiliations A. Fifth Third Securities – Broker-Dealer & Municipal Advisor FTS is registered both as a broker-dealer with FINRA and as a registered investment adviser and municipal advisor with the SEC (registration does not imply a certain level of skill or training). Principal executive officers of the broker-dealer are also officers of the registered investment adviser. IARs of FTS also act as brokerage representatives of FTS, and they solicit other services and products separate from the investment advisory services provided through FTS (e.g., Compass, Passageway, Summit). When an IAR acts in the capacity of a brokerage representative, they receive compensation for these separate activities done under FTS’ broker-dealer. Clients are under no obligation to engage FTS and our IARs for these separate brokerage products and services. B. Fifth Third Bank, National Association (FTB) FTS is a wholly owned subsidiary of FTB. FTB is a federally chartered institution and is not a registered investment adviser under the U. S. Securities & Exchange Commission. It is anticipated that FTB will benefit from the compensation for services provided through Summit. In addition, FTS IARs can recommend or refer clients to FTB, where FTB provides investment advisory services. These services are separate from the advisory accounts and services offered by FTS. If a client opens an investment advisory account with FTB based on a recommendation or referral from FTS or an FTS IAR, FTS and our IAR(s) receive ongoing compensation from FTB. The processes, procedures, and documentation required to open and maintain an account with FTB also differ from those of FTS and may be less burdensome than FTS’ requirements. These compensation arrangements, along with the differences in processes and requirements, create conflicts of interest for both FTS and our IARs. To help mitigate these conflicts of interest, FTB performs supervisory reviews of recommendations and referrals made by FTS and our IARs to validate that such recommendations are based on the client’s individual needs and best interest, rather than on the compensation received by FTS and our IARs. C. Fifth Third Insurance Agency, Inc. (FTIA) FTIA is a licensed insurance agency, which is a wholly owned subsidiary of FTB. FTS’ IARs act as insurance agents for FTIA. FTS and its IARs offer insurance products and services to advisory clients outside of Summit accounts. Clients are under no obligation to engage FTIA or its insurance agents for these separate services and products for which a customary commission is received. These insurance products are separate from Summit and are not considered managed assets within Summit. D. Frankin Street Advisors, Inc. (Franklin Street Advisors) Franklin Street Advisors is a registered investment advisor that is a wholly owned subsidiary of FTB and is an affiliated entity of FTS. Franklin Street Advisors is not a Program Manager currently available in the Summit Program; therefore, FTS does not consider the affiliated entity, Franklin Street Advisors, a conflict of interest to Summit clients or prospective clients. FTS operates independently from Franklin Street Advisors, although the two entities share certain resources, such as technology applications and other support services provided through Fifth Third Bank. E. Fifth Third Wealth Advisors, LLC (FTWA) FTWA is a wholly owned, indirect subsidiary of FTB and an adviser registered with the U.S. Securities and 07/08/2026 Summit Managed Account Firm Brochure Page 27 of 36  Exchange Commission. FTWA is not a Program Manager currently available in the Summit Program; therefore, FTS does not consider the affiliated entity, FTWA, a conflict of interest to Summit clients or prospective clients. FTS operates independently from FTWA, although the two entities share certain resources, such as technology applications and other support services provided through Fifth Third Bank. F. Comerica Securities, Inc. (Comerica Securities) Comerica Securities is a wholly owned subsidiary of FTB and is a broker-dealer and member FINRA/SIPC. Comerica Securities is not a Program Manager available in the Summit Program and currently does not provide investment advisory services to retail customers; therefore, FTS does not consider the affiliated entity, Comerica Securities, a conflict of interest to Summit clients or prospective clients. The two entities share certain resources, such as technology applications and other support services provided through Fifth Third Bank. Item 11 – Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading A. Code of Ethics FTS has adopted a Code of Ethics expressing the firm's commitment to ethical conduct. FTS' Code of Ethics is based upon the principle that FTS and its employees owe a fiduciary duty to clients to conduct their affairs, including their personal securities transactions, in such a manner as to avoid (i) serving their own personal interests ahead of clients, (ii) taking inappropriate advantage of their position with the firm and (iii) any actual or potential conflicts of interest or any abuse of their position of trust and responsibility. The Code of Ethics is designed to help maintain the high ethical standards long maintained by FTS continue to be applied. The purpose of the Code of Ethics is to preclude activities which lead to or give the appearance of conflicts of interest, insider trading and other forms of prohibited or unethical business conduct. FTS’ fiduciary duty means that FTS has an affirmative duty of utmost good faith to act solely in the best interest of its clients. FTS and its employees are subject to the following specific fiduciary obligations when dealing with investment advisory clients: • The duty to have a reasonable, independent basis for the investment advice provided; • The duty to help confirm that investment advice is suitable to meeting the client’s individual investment objectives, needs and circumstances; and • A duty to be loyal to clients. To implement the Code of Ethics, all FTS access persons are required to acknowledge their receipt of the FTS’ Code of Ethics. FTS’ IARs are subject to specific personal securities transactions and holdings reporting requirements. FTS’ Code of Ethics further includes the FTS policy prohibiting the use of material non-public information. FTS requires that all access persons must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. Any individual not in observance of the above may be subject to termination or other disciplinary actions. Advisory clients or prospective advisory clients can receive the full version of FTS’ Code of Ethics by making a written request to: Fifth Third Securities, Inc. Attn: Compliance Department 38 Fountain Square Plaza MD: 1090XB Cincinnati, OH 45263 B. Participation or Interest in Client Transactions As discussed in Item 5A – Investment Advisory Fees and Compensation, fixed income trades can result in a markup or markdown charged in addition to the investment advisory fee you pay for your FTS account, and it varies based on several factors including, but not limited to, the type of security being bought or sold, maturity date, and size of the transaction. 07/08/2026 Summit Managed Account Firm Brochure Page 28 of 36  FTS helps address this conflict by having a separate group of securities registered principals that review activities in Summit, and these registered principals do not directly receive compensation from the recommendations made by IARs. C. Personal Trading IARs are prohibited from buying or selling securities (or related securities such as warrants, options, or futures) either prior to or subsequent to submitting a trade for a Summit client with the intent to benefit from a price fluctuation generated from the Summit client’s trade. Nevertheless, FTS’ IARs can invest in the same securities (or related securities such as warrants, options, or futures) that they recommend to Summit clients. Our IARs can also recommend securities to Summit clients at or about the same time as our IARs buy or sell the same securities in their personal accounts. This creates a potential conflict of interest, including the risk that the IAR’s personal trading could influence, or appear to influence, investment recommendations, or that the IAR’s personal trading could receive more favorable timing or pricing than trades for Summit clients. To help address these conflicts, IARs are required to adhere to FTS’s Code of Ethics that emphasizes the IAR’s fiduciary duty to avoid serving their own personal interests ahead of our clients. IARs are also subject to specific personal securities transactions and holdings reporting requirements. IARs are prohibited from purchasing initial public offerings in their own personal accounts under FTS’ Code of Ethics, and IARs must receive pre-clearance before investing in private securities offerings (e.g., Regulation D offerings). D. Conflicts Related to Receipt of Gifts and Business Entertainment FTS has additional policies and procedures to help address other potential material conflicts of interest that arise from our IARs giving and receiving gifts and gratuities and business entertainment. IARs can receive business entertainment from product or service providers. Examples of business entertainment include, but are not limited to, an occasional meal or a ticket to an event (e.g., concert, game, local event). This creates a conflict of interest for the IAR where the IAR recommends the product associated with the company who has provided the business entertainment. To help mitigate this conflict, FTS generally limits the amount of business entertainment that can be received by its IAR per product or service company when the business entertainment is not associated with training, an FTS meeting, or a meeting with an FTS client. This limit does not apply to business entertainment of de minimis value as long as the value of the business entertainment received is below $40. Additionally, IARs can receive gifts from product companies, asset managers, or vendors. This creates a conflict of interest for the IAR where the IAR recommends the product or service associated with the company who has provided the gift. To help mitigate this conflict, FTS and regulatory rules prohibit the receipt of gifts over a certain limit per company and per calendar year. IARs are required to report to FTS when they receive a gift that was provided by a product or service company with the exception of promotional items of small dollar value (e.g., water bottle with the company logo on the bottle, pens, notebooks, t-shirt). Item 12 – Brokerage Practices A. Broker-Dealer Selection for Client Transactions In Summit, clients establish their accounts through NFS, the clearing broker-dealer and custodian for Summit accounts. NFS performs the necessary execution and custodial services on behalf of FTS. Clients do not have the ability to request other clearing broker-dealers for their accounts. Although FTS has found the services of NFS to be consistent with its obligation to seek best execution and that the fees (including but not limited to commissions and/or transaction fees) charged are reasonable in relation to the value of the brokerage and research services provided, a client may nonetheless pay a fee for services that is higher than another qualified broker-dealer might charge to effect the same transaction. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range 07/08/2026 Summit Managed Account Firm Brochure Page 29 of 36  of a clearing broker-dealer’s services, including the value of research provided, execution capability, commission rates and the benefit to all clients. 1) Research and Other Soft Dollar Benefits FTS does not enter into agreements that involve soft dollar benefits. However, as part of our agreements with NFS, FTS does receive benefit in the form of credits and discounts for using NFS as our clearing broker-dealer and custodian. The receipt of these benefits is not dependent on the amount or volume of client transactions placed through NFS or commissions earned by NFS for placement of trades for FTS (i.e., soft dollar benefits). Conflicts of interest due to our agreements with NFS are outlined below. a) NFS Credits & Discounts NFS provides FTS with credits in the form of receipt of payment to FTS and the offset or reduction of fees and expenses owed by FTS to NFS when FTS meets certain criteria established by NFS. These credits include singular or infrequent credits (e.g., credit as part of contract renewal or update) and recurring credits (e.g., monthly, annual intervals). One of these credits is calculated based on net flows to NFS, defined as incoming cash and securities transfers less outgoing transfers. Accordingly, FTS has conflicts of interest in both promoting transfers of cash and securities to NFS and retaining those assets with NFS. This credit excludes cash and securities associated with the Deconversion Credit referenced below. FTS’ receipt of these NFS credits represents a conflict of interest. To help mitigate the conflict of interest these credits create, FTS and NFS have limited the criteria that have to be met by FTS to receive these credits. For example, the receipt of these credits are not dependent on the amount or volume of transactions placed through NFS, the amount of charges/fees assessed by NFS to FTS, commissions earned by NFS for placement of trades, the number of clients or accounts FTS has with NFS (with the exception of the Deconversion Credit), and does not prevent FTS to place a security transaction or transactions through another firm if FTS believes it is in the client’s best interest. In addition, in connection with Fifth Third Bancorp’s acquisition of Comerica Incorporated and its subsidiaries, including Comerica Bank, N.A., NFS will provide FTS with: (1) a one-time credit to offset costs associated with the conversion of accounts and assets from Ameriprise Financial Services, LLC (“Ameriprise”) to NFS (the “Deconversion Credit”), (2) an increase to an existing annual credit provided by NFS to FTS, and (3) discounted fees from NFS’s affiliated entity, Fidelity Institutional Wealth Adviser LLC, for investment advisory accounts which includes Summit accounts. The Deconversion Credit is contingent on the volume of assets and accounts transferred. If the transferred assets and accounts fall below a specified threshold, NFS will not provide the Deconversion Credit. Additionally, if a specified percentage or more of the assets and accounts transferred to NFS in connection with this conversion are subsequently moved away from NFS within a defined period after the conversion, FTS is to negotiate with NFS to determine whether FTS will reimburse a portion of the Deconversion Credit. As a result, FTS has conflicts of interest related both to encouraging the transfer of accounts and assets from Ameriprise to NFS and to retaining those accounts and assets after the transfer. To help mitigate these conflicts, the Deconversion Credit is not tied to the transfer of specific asset types and does not depend on future transactions occurring at NFS. b) Conflicts Related to Interest on Cash Holdings NFS shares credit interest compensation with FTS on cash balance holdings held in Summit accounts. To help mitigate this conflict of interest, FTS requires clients to select a core account investment vehicle (a/k/a sweep option) for available cash balances instead of allowing the Summit account to remain in cash. Even when a client selects a core account investment vehicle, there are situations when a Summit account will still end up holding a cash balance. As a result, FTS will receive credit interest from this cash balance holding. Additionally, we do not directly share with IARs the credit interest income received from cash holdings in a Summit account, and lastly, the interest earned on cash holdings in a Summit account that FTS receives from NFS is reimbursed directly to the client’s Summit account. These reimbursements for cash holdings occur in 07/08/2026 Summit Managed Account Firm Brochure Page 30 of 36  the same quarter or the following quarter that FTS receives the interest from NFS. Furthermore, FTS Clients can select an available core account investment vehicle or change the core account investment vehicle at any time for their Summit Account by contacting their IAR. Additional information regarding the available investment options for your core account investment vehicle can be found at 53.com/ftsdisclosure under “Core Account Investment Vehicle Disclosure Summary”. c) Conflicts Related to Clearing Firm (NFS) (1) No Cost Transactions FTS pays NFS clearance and execution fees for trades placed in Summit accounts. These clearance and execution fees are in part based upon the type of security involved in the transaction (e.g., listed equity, over-the-counter equities, municipal bonds, mutual funds, etc.). However, NFS makes transactions in certain mutual funds and ETPs available to FTS at no cost if the mutual fund or ETPs is part of NFS’ NTF Mutual Funds Program, NTF Managed Account Program, and iNTF Managed Account Program. The availability of no cost transactions creates a conflict of interest for FTS by providing the availability to have transactions in certain mutual funds and ETPs at no cost while transactions in other mutual funds and ETPs not part of NFS’ NTF Mutual Funds Program, NTF Managed Account Program, and iNTF Managed Account Program are assessed a charge or fee. To help mitigate this conflict of interest, FTS does not distribute to IARs the list of mutual funds and ETPs on NFS’ NTF Mutual Funds Program, NTF Managed Account Program, and iNTF Managed Account Program. Furthermore, FTS has contracted with FIWA to perform initial and ongoing due diligence on some or all the mutual funds and ETPs available in the Summit Program, which includes all of the mutual funds and ETPs that are available on NFS’ NTF Mutual Funds Program, NTF Managed Account Program, and iNTF Managed Account Program. FTS conducts additional due diligence on the mutual funds and ETPs after FIWA has approved or continues to approve the mutual funds and ETPs. (2) NFS Credits & Discounts NFS provides FTS with credits in the form of receipt of payment to FTS and the offset or reduction of fees and expenses owed by FTS to NFS when FTS meets certain criteria established by NFS. These credits include singular or infrequent credits (e.g., credit as part of contract renewal or update) and recurring credits at (e.g., monthly, or annual intervals). One of these credits is calculated based on net flows to NFS, defined as incoming cash and securities transfers less outgoing transfers. Accordingly, FTS has conflicts of interest in both promoting transfers of cash and securities to NFS and retaining those assets with NFS. This credit excludes cash and securities associated with the Deconversion Credit referenced below. FTS’ receipt of these NFS credits represents a conflict of interest. To help mitigate the conflict of interest these credits create, FTS and NFS have limited the criteria that have to be met by FTS to receive these credits. For example, the receipt of these credits are not dependent on the amount of assets FTS has with NFS, the amount or volume of transactions placed through NFS, the amount of charges/fees assessed by NFS to FTS, any commissions earned by NFS for placement of trades, the number of clients or accounts FTS has with NFS (with the exception of the Deconversion Credit), and does not prevent FTS to place a security transaction or transactions through another firm if FTS believes it is in the client’s best interest. In addition, in connection with Fifth Third Bancorp’s acquisition of Comerica Incorporated and its subsidiaries, including Comerica Bank, N.A., NFS will provide FTS with: (1) a one-time credit to offset costs associated with the conversion of accounts and assets from Ameriprise Financial Services, LLC (“Ameriprise”) to NFS (the “Deconversion Credit”), (2) an increase to an existing annual credit provided by NFS to FTS, and (3) discounted fees from NFS’s affiliated entity, Fidelity Institutional Wealth Adviser LLC, for investment advisory accounts. The Deconversion Credit is contingent on the volume of assets and accounts transferred. If the transferred assets and accounts fall below a specified threshold, NFS will not provide the Deconversion Credit. Additionally, if a specified percentage or more of the assets and accounts transferred to NFS in connection with this conversion are subsequently moved away from NFS within a defined period after the conversion, FTS is to negotiate with NFS to determine whether FTS will reimburse a portion of the Deconversion Credit. 07/08/2026 Summit Managed Account Firm Brochure Page 31 of 36  As a result, FTS has conflicts of interest related both to encouraging the transfer of accounts and assets from Ameriprise to NFS and to retaining those accounts and assets after the transfer. To help mitigate these conflicts, the Deconversion Credit is not tied to the transfer of specific asset types and does not depend on future transactions occurring at NFS. 2) Trade Errors If FTS, our IARs, or FIWA makes an error when submitting a trade order on a client’s behalf, it is the policy of FTS that the trade error be corrected as soon as possible and in such a manner the client is not disadvantaged and bears no loss as a result of the error. Upon the identification of a trade error, FTS will work with NFS and/or FIWA to take the appropriate steps necessary to rectify the error. If correcting a trade error results in a loss or a gain within the client’s account, FTS or FIWA will retain any gain or absorb any loss. B. Order Aggregation IARs can pool securities trades for the same security for multiple client accounts to create large blocks of trades. This is done to help achieve best price execution for the total pool of accounts and/or to help avoid conflicts of interest of favoring one client over another. Once the trades have been executed, the securities or proceeds are allocated back to the pool of client accounts at the average price for the block trade as a whole. IARs must adhere to FTS’ allocation policies. For more information on block trading please see FIWA’s ADV Part 2A Brochure. A current copy can be requested from your IAR or can be obtained directly from the SEC’s website (https://adviserinfo.sec.gov/firm/brochure/301896) and selecting “Fidelity Managed Account Xchange” under Brochure Name. Item 13 – Review of Accounts A. Frequency and Nature of Review of Client Accounts or Financial Plans FTS’ IARs periodically review client Summit accounts. Reviews by IARs can include the client’s current asset allocation and the managed securities in the Summit account. In addition, IARs will generally attempt to meet with Summit clients each calendar year and review their financial and investment goals, risk tolerance, and other information relevant to maintaining an appropriate investment strategy for the client, as well as review the investment management of the Summit account. These reviews by IARs sometimes result in rebalancing a Summit account back to or a close approximate of the asset allocation selected by the client. These reviews with Summit clients can be conducted in-person, telephonically, or by a videoconferencing system (e.g., Microsoft Teams). Generally, if FTS is unable to conduct a review with a Summit client for two consecutive calendar years, FTS will commence with termination of the advisory relationship with the Summit client in the third year unless a review with the client is able to occur. However, FTS understands that in certain client situations meeting with an FTS IAR may not be practical and in those circumstances (e.g., military service member deployed overseas), FTS can choose not to terminate the advisory relationship with the Summit client. B. Factors Prompting Review of Client Accounts Other Than a Periodic Review FTS and our IARs can perform reviews beyond the periodic reviews mentioned above. These additional reviews can be prompted by a client’s request, FTS’ internal monitoring and reviews, statutory or regulatory requests or rule changes, market developments, potential issues identified with respect to the Summit account (e.g., suspected fraud or money laundering), among other factors. C. Content and Frequency of Account Reports to Clients On a quarterly basis, FIWA sends Summit clients a statement containing a description of the activity that occurred in the client’s account(s) during the previous quarter including, but not limited to, the following: • Securities holdings • Account value • Transactions occurred in the account, including contributions and withdrawals • Investment advisory fees charged for the period 07/08/2026 Summit Managed Account Firm Brochure Page 32 of 36  This quarterly statement includes a statement to the effect that a Summit client is to contact FTS if there have been any changes in financial situation or investment objectives, if the Summit client wishes to impose reasonable investment restrictions on the management of the Summit account, or if the Summit client wishes to reasonably modify existing investment restrictions. FTS does not independently verify the accuracy of the performance information provided by FIWA on client quarterly performance reports. In addition, clients receive either monthly statements from NFS if securities transactions (e.g., purchases, sales, or transfers) occur in the Summit account or quarterly statements from NFS if no transactions occur in the Summit account. FTS strongly recommends clients compare the holdings and transactions listed on NFS statements against the quarterly performance reports provided by FIWA. The client should promptly alert their IAR or FTS if the client identifies any discrepancies between these statements. FIWA performance statements reflect a trade-date basis, and NFS statements reflect a settlement-date basis. This means transactions that occur at the end of a quarter that have not settled will appear on the FIWA statement but will not appear on the NFS statement. When FTS or a client terminates the Investment Management Agreement and the corresponding Summit account, the client will not receive a quarterly performance report for the quarter in which the Summit account was terminated. Item 14 – Client Referrals and Other Compensation FTS and our parent company, FTB, recognize and provide rewards to our Financial Professionals which include Financial Professionals who are IARs. A. FTS Education Summit Each year, FTS holds an educational meeting to provide enhanced training for our top Financial Professionals, including IARs. FTS provides travel, food, entertainment, lodging accommodations, and other expenses for our Financial Professionals who are invited to the FTS Education Summit. FTS generally invites the Financial Professionals who have produced the most revenue based upon the specific role of the Financial Professional. Criteria for qualifying for an invitation to the FTS Education Summit can change from year-to-year, but it is anticipated that the criteria will generally involve the overall performance of the Financial Professional. B. FTB President’s Circle Each year, FTB holds the President’s Circle meeting for top-performing FTB employees based upon role, including Financial Professionals who are IARs. Invitation to the FTB President’s Circle is generally based on the overall revenue to FTB for a period of time. The revenue counted towards being invited to the FTB’ President’s Circle includes revenue associated with FTS’ transactions and accounts. FTS generally has no final determination for the criteria of the FTB’s President’s Circle, but FTS does have input as to the general structure to help ensure that the criteria complies with FTS’ standards and regulatory rules. IARs who are not invited cannot attend the FTS Education Summit or FTS President’s Circle. These factors create a conflict of interest for IARs if they would like to be invited to these events. To help mitigate this conflict, FTS employs a separate group of principals who generally review the recommendations of IARs that result in securities transactions or opening investment advisory accounts. Additionally, criteria for an invitation to these events is not based solely on the revenue of a single product, product or service type, and the time period in which the overall revenue is based will be for a longer period of time (generally between 9-12 months). C. Area and Regional Meetings IARs can also receive recognition in area and/or regional meetings. Examples of recognition can include verbal recognition, trophies, plaques, or other physical awards. D. Compensation to Non-Supervised Persons for Client Referrals FTS currently does compensate individuals who are securities registered with FTS for qualified client referrals 07/08/2026 Summit Managed Account Firm Brochure Page 33 of 36  to FTS. To qualify for the referral fee the following conditions must be met: 1) the client is not an existing client of FTS at the time of the referral, 2) the client agrees to and has an appointment with a Registered Representative of FTS, and 3) the client has a minimum of $50,000 in investable assets. If these three conditions are met, individuals who are securities registered with FTS would receive a $25 referral fee. A referral fee is not contingent upon the client opening an account (Investment Advisory or Brokerage), purchasing any security or investment, or FTS receiving any type of compensation from the client or their investable assets. FTS pays on-going compensation to IARs who are made available to some Summit clients to assist with their Summit account when their primary IAR is unavailable. Assistance provided by these IARs will generally be around the administration of the accounts, such as Summit account balance inquiries, specific information requests about the client’s Summit account holdings (e.g., current value of a security, date(s) when a specific security was purchased or sold, prospectus request, etc.), and information about the IARs, as applicable. Assistance with Summit clients would not include making investment decisions for the Summit account, recommendations to change to other investment advisory programs of FTS, or asset allocation changes to an existing Summit account without the involvement of the primary IAR. These IARs that receive the nominal fee are registered as IARs with FTS and applicable clients will receive a copy of the IAR’s Investment Advisory Supplemental Brochure (Form ADV 2B) in addition to their primary IAR’s Investment Advisory Supplemental Brochure. Item 15 – Custody NFS is the qualified custodian for FTS. Summit clients receive either monthly statements from NFS if securities transactions (e.g., purchases, sales, or transfers) occur in the Summit account or quarterly statements from NFS if no transactions occur in the Summit account. Clients are encouraged to compare the holdings and transactions listed on NFS statements against the quarterly performance reports provided by FIWA (See 13.C. – Content and Frequency of Account Reports to Clients). The client should promptly alert their IAR or FTS if the client identifies any discrepancies between these statements. FIWA performance statements reflect a trade-date basis, and NFS statements reflect a settlement-date basis. This means transactions that occur at the end of a quarter that have not settled will appear on the FIWA statement but will not appear on the NFS statement. Item 16 – Investment Discretion By signing the IMA, Summit clients grant FTS discretionary authority to manage Summit account assets. Such discretionary authority allows FTS to make all investment decisions with respect to the client’s Summit account(s) when FTS deems appropriate and without prior consultation with the client, to buy, sell, exchange, convert and otherwise trade in any equity, mutual fund, ETP, fixed income security, or publicly traded REIT approved by FTS for use in Summit accounts. In addition, this discretionary authority allows FTS to invest a client’s accounts/assets in a lower risk tolerance up to one level than the client has selected (see Item 4B – Summit Investment Management Program). Summit clients have the opportunity to place reasonable investment restrictions on the types of investments that will be managed on the client's behalf within Summit accounts (see Item 4.C. – Availability of Customized Services for Individual Clients). Item 17 – Voting Client Securities FTS and our IARs are prohibited from accepting voting authorizations or instructions from Summit clients and exercising or voting on any security-related issues for assets held in Summit accounts. However, IARs can provide Summit clients with general information about proxy voting such as the meaning of the vote, deadlines, and potential implications. Responsibility for proxy voting is governed by the terms outlined in the IMA. Summit clients receive their proxies or other solicitations directly from NFS. Please contact your IAR directly or contact us at 888-889- 1025 with questions about a particular solicitation. 07/08/2026 Summit Managed Account Firm Brochure Page 34 of 36  Item 18 – Financial Information A. Balance Sheet FTS is not required to provide a balance sheet with this Brochure because we do not solicit prepayment of more than $1,200 in fees per client, six months or more in advance. B. Financial Conditions Likely to Impair Ability to Meet Contractual Commitments to Clients FTS is not aware of any financial impairment that will preclude us from meeting our contractual commitments to our advisory clients. C. Bankruptcy Filings FTS has not been the subject of a bankruptcy petition in the last ten years. (Remainder of the Page Intentionally Left Blank) 07/08/2026 Summit Managed Account Firm Brochure Page 35 of 36  Investment Advisory Account Service Fee Schedule*,1 Effective Date July 8, 2026 Fee Description Fee Frequency Aged Legal Items Fee $25.00 Per item Varies Per applicable occurrence American/Global Depositary Receipt Fee2 Bounced or Return Check Fee3 $50.00 Per item Country/State Taxes4 Varies Per applicable transaction Debit Interest Charge NFBLR5 plus 3% Accrues daily, charged monthly Foreign Security Movement Fee $75.00 Per security Foreign Tax Fee6 Varies Per applicable occurrence Options Regulatory Fee7 Varies Per options transaction Overnight Mailing Fee $10.00 Per delivery Physical Reorganization Fee $25.00 Per item Precious Metals Fee Varies8 Per security SEC Section 31 Fee9 Varies Per applicable transaction Stop Payment on Check Fee3 $30.00 Per item Trade Settlement Extension Fee3 $30.00 Per extension Transfer Agent – Register/Ship Fee10 $25.00 Per certificate Outgoing Wire Transfer Fee $15.00 Per wire Important Disclosures * This Investment Advisory Account Service Fee Schedule discloses only account-level service fees and does not include investment advisory fees. For information on the investment advisory fees, refer to your Statement of Investment Selection or Advisory Supplemental Brochure. To learn more about fees and charges for Fifth Third Securities investment advisory programs (e.g., Compass, Passageway, Summit), review the corresponding Form ADV 2A brochure at 53.com/ftsdisclosure. 1 All Fees are subject to change and can vary by program and arrangement (e.g., Investment Advisory, Standard, Preferred, Private Bank, Online). Certain fees (e.g., regulatory, state and foreign government fees, etc.) are outside of the control of National Financial Services, LLC and Fifth Third Securities and can be changed or added at any time without prior notice. 2 American Depositary Receipts (ADRs) and Global Depositary Receipts (GDRs) may have administrative, or management type, fees associated with them which are passed through to shareholders. Refer to the ADR or GDR’s prospectus for information on pass through fees. 3 Fee is comprised of the combined fees assessed and paid to National Financial Services, LLC and Fifth Third Securities. 4 Fee represents charge assessed by some foreign governments on purchases and sells of securities of companies incorporated in thei r countries. The fee corresponds to the amount of tax, as set forth under applicable foreign tax laws. It is generally a percentage or scheduled amount based on the total purchase or sale amount of the securiti es subject to tax. The fee is passed on from the foreign government to the client. When applicable, the fee will appear on the trade confirmation. 5 The National Financial Base Lending Rate (NFBLR) is set at the discretion of National Financial Services, LLC after considering commercially recognized interest rates, industry conditions regarding the extension of margin credit and general credit conditions. 6 Fee represents charge assessed by some foreign governments on income generated from securities of companies incorporated in their countries. The fee corresponds to the amount of tax, as set forth under applicable foreign tax laws. It is generally a percentage or scheduled amount based on the income generated from the securiti es subject to tax. The fee is passed on from the foreign government to the client. When applicable, the fee will appear on the monthly or quarterly account statement. 7 Fee represents charge assessed by the Options Clearing Corporation (OCC) on all options transactions that are passed on to you and will be displayed on the trade confirmation as Activity Assessment Fee. 8 Fee varies based on several factors regarding the precious metal including, but not limited to, package weight, value, delivery location, and insurance required to ship. 9 Fee represents charge assessed by the SEC (Section 31 Fee) that is passed on to you and will be displayed on the trade confirmation as Activity Assessment Fee. The fee is calculated on the investment amount (principal) of applicable transactions. More information on the Section 31 Fee can be found on the SEC’s website. 10 This fee generally appears in your account as DRS Registration. Fifth Third Bank, N.A. provides access to investments and investment services through various subsidiaries, including Fifth T hird Securities. Fifth Third Securities is the trade name used by Fifth Third Securities, Inc., member FINRA/SIPC, a registered broker-dealer and a registered investment advisor registered with the U.S. Securities and Exchange Commission (SEC). Registration does not imply a certain level of skill or training. Securities, Investments, Investment Advisory Services, and Insurance: Are Not FDIC Insured Offer No Bank Guarantee Are Not Insured By Any Federal Government Agency May Lose Value Are Not A Deposit 07/08/2026 Summit Managed Account Firm Brochure Page 36 of 36