First Command Advisory Services

DESCRIPTION OF SERVICES FORM ADV PART 2A BROCHURE First Command Advisory Services, Inc. 1 FirstComm Plaza, Fort Worth, Texas 76109-4999 800.443.2104 Overseas, Call 817.731.8621 www.firstcommand.com clientservices@firstcommand.com This brochure is dated October 15, 2025. This brochure provides information about the qualifications and business practices of First Command Advisory Services, Inc. If you have any questions about the contents of this brochure, please contact us at 800.443.2104 (or, if overseas, 817.731.8621). 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 First Command Advisory Services, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. First Command Advisory Services, Inc. is an SEC-registered investment adviser. Registration as an investment adviser with the SEC does not imply a certain level of skill or training.  ITEM 2 - SUMMARY OF MATERIAL CHANGES TO THE ADV PART 2A BROCHURE 1. Throughout Brochure. This Brochure announces the addition of two new wrap fee advisory programs introduced under the Asset Management Solutions Advisory Program umbrella: First Command Premier Income and First Command Elite. These new advisory programs provide clients with a broader selection of investment strategies pursuant to which clients’ assets are managed. Throughout this Brochure, there are updates to the descriptions of these new Advisory Programs, including their Advisory Fees and account minimums. 2. Item 12. First Command Brokerage Services, Inc. (“FCBS”) has renegotiated a contract with Pershing, LLC, the custodian and clearing firm for advisory program accounts. The contract includes terms favorable to FCBS. These updates also include details about certain incentives that impact FCAS’s conflicts of interest. These updates include waiver of all transaction fees on the Pershing platform and substantial financial incentives for FCBS to keep accounts with Pershing and move additional accounts to the Pershing platform. 3. Item 15. The Custody section has been updated to align with SEC guidance, to clarify that FCAS and its Affiliated Companies, First Command Bank (“FCB”) and FCBS, have legal custody over clients’ accounts. 4. Item 17. Our third-party voting proxy, Glass Lewis, updated its policy guidelines on how it votes proxies. We have updated the link to their Corporate Governance Focused Thematic Policy Guidelines. 5. Throughout Brochure. As part of ongoing program improvements, several program name changes have been made. Asset Management Solutions now refers to the overall suite of FCAS’s advisory programs, and each program under the Asset Management Solutions has received a new name to reflect updated branding and organizational structure. For example, FIP is now known as “First Command Foundations,” and SIP is renamed to “First Command Select.” These changes are administrative in nature and do not affect the underlying investment process or the client experience. 6. Additional editorial and non-material changes were also made throughout the brochure. These are the material changes since the last annual update of this Brochure from August 26, 2024. You may request a current copy of this Brochure at any time by contacting your Financial Advisor, calling FCAS’s Home Office at 800.443.2104 (overseas, call 817.731.8621) or visiting www.firstcommand.com. 1  ITEM 3 - TABLE OF CONTENTS ITEM 2 - SUMMARY OF MATERIAL CHANGES TO THE ADV PART 2A BROCHURE .................... 1 ITEM 3 - TABLE OF CONTENTS ......................................................................................................... 2 ITEM 4 - OUR ADVISORY BUSINESS ................................................................................................ 3 ITEM 5 - FEES AND COMPENSATION ............................................................................................. 14 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 ITEM 9 - DISCIPLINARY INFORMATION .......................................................................................... 24 ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .................................. 24 ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENTS’ TRANSACTIONS & PERSONAL TRADING ...................................................................................................... 25 ITEM 12 - BROKERAGE PRACTICES ............................................................................................... 26 ITEM 13 - REVIEW OF ACCOUNTS .................................................................................................. 28 ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION .................................................... 29 ITEM 15 - CUSTODY ......................................................................................................................... 29 ITEM 16 - INVESTMENT DISCRETION ............................................................................................. 29 ITEM 17 - VOTING CLIENT SECURITIES ......................................................................................... 30 ITEM 18 - FINANCIAL INFORMATION .............................................................................................. 31 2  FORM ADV PART 2A: FIRM BROCHURE ITEM 4 - OUR ADVISORY BUSINESS WHO WE ARE First Command Advisory Services, Inc. (“FCAS”, “we”, “us” or “our”) and its affiliated entities have been serving American families since 1958. FCAS is registered as an investment adviser with the U.S. Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended (“Advisers Act”). Registration as an investment adviser with the SEC does not imply a certain level of skill or training. FCAS will work with both third parties (hereinafter, “Non-Affiliated Companies”) and FCAS’s Affiliated Companies (each, an “Affiliated Company”) to provide the services for each Advisory Program. FCAS and the Affiliated Companies referenced herein are wholly owned subsidiaries of First Command Financial Services, Inc. (“FCFS”). FCFS is 100 percent owned by the First Command Employee Stock Ownership Plan. The applicable FCAS Affiliated Companies include: • First Command Brokerage Services, Inc. (“FCBS”), an SEC registered broker-dealer (member SIPC, FINRA); • First Command Insurance Services, Inc. (“FCIS”), an insurance general agent; and • First Command Bank (“FCB”), a federal savings association (member FDIC). All references to “client”, “you” and/or “your” in this brochure refer to prospective and existing clients of FCAS. References to “we,” “us” or “our” refer to FCAS. OUR INVESTMENT ADVISORY SERVICES In our capacity as an investment adviser, we offer financial planning services, asset management services, and other investment advisory services to individuals and entities. We embrace time-tested financial principles, advocating a disciplined, long-term approach to saving and investing, supported by strategies to manage financial risk. Through our commitment to providing face-to-face financial coaching at every stage of our clients’ professional and personal lives, we have established lasting relationships with hundreds of thousands of client families. We are committed to helping our clients plan confidently for the future and accompanying them on their financial journeys. We believe in offering our clients personal face-to-face service, whenever possible, through our investment adviser representatives (“First Command Financial Advisor” or “Financial Advisor”). These services and fees are described in further detail below and in the ADV Part 2A, Appendix 1, Wrap Fee Program Brochure (“Wrap Fee Brochure”) for the applicable Advisory Program. Further fees related to brokerage services and custodial fees are detailed in the FCBS Fee Schedule. Financial Planning Services FCAS offers complimentary financial planning services to active-duty service members and to others at FCAS’s discretion. Financial Advisors can also provide complimentary financial planning services to clients enrolled in an Advisory Program, at the Financial Advisor’s discretion. Clients who qualify for complimentary financial planning services are encouraged to request such services from Client’s Financial Advisor. 3  For individuals who request financial planning services who do not qualify to receive such services on a complimentary basis or have more complex financial planning needs, FCAS, through its Financial Advisors, also offers personalized financial planning services for a fee through a program called Tailored Professional Services (“TPS” or “TPS Program”). Clients interested in enrolling in the TPS Program are encouraged to speak with your Financial Advisor. The following services are included as part of financial planning services, whether complimentary or through the TPS Program: • A written financial plan with recommendations and strategies for cash management (banking), wealth accumulation and management (investing), and risk management (insurance) during your initial term of service. • An updated written financial plan for a material change to your circumstances you report to your Financial Advisor. • Reasonable personal or telephone access to the Advisor for continued financial advice. • Access to First Command’s web features. • Periodic financial reviews or “progress meetings” with your Financial Advisor within the Service Period. • When appropriate, and with your consent, bringing together other professionals independent of FCAS to augment the TPS Program. Such outside professionals may include a CPA/accountant, tax analyst, estate planner, attorney, real estate specialist and/or financial product specialist. Please note that FCAS and its Affiliated Companies do not provide legal or tax advice and the TPS fee does not cover fees that may be charged and billed separately by other professionals. In order to provide you with the financial planning services, whether complimentary or through the TPS Program, our Financial Advisors will gather detailed information from you to determine your existing financial condition, attitudes, goals, risk tolerance, and planning horizon. We rely on you to provide us with your complete financial situation, goals and needs, as well as any updates to your situation. Any financial plan and/or other financial planning recommendations prepared for you will address your current financial circumstances and goals, and will be based on the information you provide on questionnaires, documents, and during interviews and meetings with your Financial Advisor. We will work collaboratively with you and encourage you to be an active participant in all discussions related to the financial planning services we provide you. In addition to providing you with financial planning services, you may also receive recommendations to establish relationships and/or investment accounts through FCAS and/or an Affiliated Company for specific products and services that are separate from the financial planning services provided to you. Financial planning services, whether complimentary or through the TPS Program, do not include implementation of any recommendations or monitoring account(s) incorporated in a financial plan that is created for you. These services solely include the provision of a general financial plan and not the implementation of securities, other investments, insurance products or investment strategies. Any recommendations for banking products and services will be provided by FCB. FCAS may recommend you obtain certain types of insurance products and services. No part of the Advisory Fee charged to you is for recommendations or other advice related to insurance. You will pay commissions when you purchase insurance products through FCIS. FCAS may make recommendations to you for transactions in brokerage accounts or for brokerage products through FCBS. FCBS’s product offerings include mutual funds, exchange traded funds, variable annuities, variable life insurance, and Section 529 Plans. If you establish a brokerage account or 4  purchase brokerage products through FCBS, you will pay commissions when you make a new investment in a brokerage product or when you trade in a brokerage account. FCAS may recommend you obtain investment advisory services through an FCAS Advisory Program. Should you enroll in a FCAS offered Advisory Program, you will pay investment advisory fees for the investment advice provided by FCAS (“Advisory Fee”). Your Financial Advisor may recommend an investment advisory relationship, a brokerage relationship, or a combination of two relationships to you. Your Financial Advisor will work with you and make recommendations to you based on your specific financial situation, factoring in information your Financial Advisor has collected from you through a questionnaire and through discussions with you including, but not limited to, your overall financial situation, your personal investment objectives and goals, and your risk tolerance. Other factors your Financial Advisor will consider include your desired investment time horizon, your liquidity needs, investment experience, diversification, your personal circumstances, account restrictions, your risk tolerance, and your desire for professional management. These factors are important in our recommendations made to you due to the respective fee structures between a brokerage account and an advisory account. Brokerage accounts incur fees when trades are placed, meaning the more trades placed, the greater the account fees. Advisory accounts, on the other hand, do not incur fees as a result of trades being placed. Instead, advisory accounts charge a flat annual fee, assessed monthly, which is based on a percentage of the account’s value. Further, FCAS’s wrap fee advisory programs charge a singular fee for managing assets in the account, as explained in greater detail within this brochure and the Wrap Fee Brochure for the applicable advisory program. While investors might find either a brokerage or advisory account to be a good fit for their needs, each account type provides different benefits and considerations. Advisory accounts may be advisable for accounts that place trades as appropriate or hold multiple positions that need to be rebalanced. Further, Advisory accounts are advice-based and are part of an ongoing, fiduciary relationship with a Financial Advisor. Advisory accounts are generally recommended for investors who want to receive investment advice and monitoring of their account on an ongoing basis and prefer to have planning conversations with a Financial Advisor. On the other hand, brokerage accounts, may be advisable for investors who manage their investments themselves or don’t feel they need consultation or recommendations on their investments on an ongoing basis. For example, an investor who would prefer to buy and hold mutual funds with no intention of occasional rebalancing might find brokerage accounts to be more suitable as the investor pays fees primarily generated through the investor’s trading activity and is not paying to receive ongoing investment advice and monitoring of their account. However, if an investor desires to trade specific investments frequently inside their portfolio, brokerage fees for that trading activity can negatively impact the investor’s return. There are circumstances where your Financial Advisor and FCAS have a financial incentive to recommend an investment advisory relationship, as opposed to a brokerage relationship, which creates a conflict of interest for your Financial Advisor and FCAS. For example, notwithstanding the benefits an investor receives under an advisory relationship (including, but not limited to, the benefit of having a fiduciary relationship with a Financial Advisor and FCAS, ongoing investment advice and periodic rebalancing), a longstanding advisory relationship is more likely to result in more compensation being generated for FCAS and the Financial Advisor over the duration of the relationship than if the same investor instead selected a brokerage relationship with FCBS (and the Financial Advisor in the capacity of a registered representative of FCBS). This creates an additional incentive for FCAS and the Financial Advisor to recommend that an investor enter into an investment advisory relationship with it as opposed to a brokerage relationship with its Affiliated Company, FCBS. 5  Of course, there is no way to predict the future with any certainty or to guarantee that your Financial Advisor and FCAS would receive more compensation from such a client than the compensation that would be received by FCBS if such a client were to enter into a brokerage relationship with FCBS. In this respect, there are many variables that impact whether an advisory relationship would result in more compensation than a brokerage relationship. In addition, the impact of these variables on compensation can change over time as markets change and the investor’s financial characteristics and goals change. These conflicts of interest are mitigated because your Financial Advisor can only recommend products or services (including investment advisory and brokerage relationships) that your Financial Advisor believes are appropriate for you and in your best interest. In addition, FCAS has created and implemented a compliance and supervisory program to mitigate such conflicts through the oversight of client accounts and investment advisory activities. Importantly, recommendations are subject to review by professionals at FCAS ensure they are in line with the best interests of the client and are made in line with the Code of Ethics detailed in Section H below. When you obtain financial planning services through FCAS, you determine whether to implement any of the recommendations provided to you and you are under no obligation to purchase any product or service through FCAS and/or its Affiliated Companies. Your Financial Advisor must be appropriately licensed to offer the recommendations provided in connection with the financial planning services. Risk is inherent in investing; therefore, we do not guarantee future financial results as a result of implementing any of the recommendations we make to you. In recommending proprietary products and services of its Affiliated Companies, FCAS is not considering other firms, which may offer additional products or services that may have lower costs. You may elect to implement any of the recommendations provided to you in whole or in part through FCAS and/or any of its Affiliated Companies. If you elect to implement any of the recommendations provided to you, then you are responsible for all fees and expenses incurred in connection with the implementation of a financial plan (such as Advisory Fees and/or commissions and expenses related with brokerage or insurance products). You will receive appropriate disclosures documenting an agreement describing the nature and extent of the services provided by FCAS or its Affiliated Companies and the applicable fees charged for those services. The fees charged by FCAS or its Affiliated Companies such as Advisory Fees charged by FCAS in connection with the implementation of a financial plan are in addition to the fees incurred by you for the TPS Program and in connection with the formulation of a financial plan (if applicable). The purchase of products and services offered through FCAS and/or its Affiliated Companies result in reasonable and customary compensation in the form of Advisory Fees or commissions (depending on the product or service) which are shared between the applicable First Command entity and your Financial Advisor. As noted, if you purchase investment advisory services or securities or insurance products provided, issued, sponsored, advised, underwritten, distributed by, or otherwise obtain additional services offered by us or an Affiliated Company, we and/or the Affiliated Company will receive additional revenue. This creates a conflict of interest for your Financial Advisor when acting as a registered representative, investment adviser representative and/or insurance agent to recommend products and services based on the compensation received by us and/or our Affiliated Companies, rather than solely based on your needs. To help mitigate this conflict of interest, the recommendations made by our Financial Advisors when acting as a registered representative, investment adviser representative and/or insurance agent are reviewed to ensure the recommendations are appropriate and consistent with the interests of our clients. In addition, the compensation paid to the Financial Advisors when acting as registered representatives, investment adviser representatives and/or insurance agents is periodically reviewed to 6  ensure compliance with applicable law and to prevent compensation incentives from causing inappropriate recommendations to be made. FCAS’s Asset Management Solutions Advisory Programs FCAS is the sponsor and investment adviser of Asset Management Solutions Advisory Programs, which consists of several advisory programs listed below (each a “Program” or “Advisory Program” and collectively the “Advisory Programs”). Through the Advisory Programs, you can access a wide variety of investment strategies. Some of the Advisory Programs allow for the inclusion of mutual funds, exchange-traded funds (ETFs), selections of third-party managed investment portfolios through third- party managed accounts, stocks, bonds, and alternative/complex products. Our services are provided to you through First Command Financial Advisors as described in this Brochure. As a “wrap fee program,” your selected Advisory Program provides investment advisory services, brokerage, and non- IRA custody services for a single, inclusive fee (i.e., wrap fee). The specific Advisory Program you select may cost you more or less than purchasing such services separately. Factors that bear upon the cost of a particular Advisory Program in relation to the cost of the same services purchased separately include, but are not limited to, the type and size of the account and the number and range of supplementary advisory and client-related services provided to the account. We are the sponsor and investment adviser for the Advisory Programs as described in this Brochure. Your Financial Advisor will work with you to gather information about your financial situation, goals, and objectives, including information on your investment time horizon (this is the length of time before you intend to draw down or liquidate your investments), risk tolerance (certain investments are riskier than others), and other relevant factors. Based on this information, your Financial Advisor (and Wealth Portfolio Manager, depending on the Advisory Program) will then propose an overall investment strategy that includes asset allocation and investment portfolio recommendations with your account to be managed in one or more Advisory Programs in accordance with the customized investment strategy as further detailed in this Brochure. Should your risk profile change, it is your responsibility to contact your Financial Advisor to update your risk profile and decide whether you wish to make a change to your investment strategy. Your Financial Advisor (or Wealth Portfolio Manager, as applicable) will periodically meet with you to discuss any changes to your financial situation, goals, and objectives to ensure that the investment strategy continues to meet your investment needs. To enroll in an Advisory Program, you will be required to complete our new account paperwork establishing an account and agree to our Investment Management Agreement (“IMA”), which contains additional terms and conditions governing your account and your relationship with us. If you are moving your account from one Advisory Program to another, you may be required to complete paperwork indicating your election, which may include signing the most current IMA. This Brochure provides you with a general overview of our responsibilities to you and conflicts of interest as it applies to the Advisory Programs. You can obtain more specific information about the investment strategies, how investment strategies are carried out, options to customize your investments, the Investment Management Team (“IMT”), the role of Wealth Portfolio Manager (“WPM”), investment returns, and other information through discussion with your Financial Advisor. We encourage you to review this Brochure carefully and to talk to your Financial Advisor to make certain you fully understand our investment process and the features available to you as a participant in one or more of the Advisory Programs. Additional information about each Advisory Program, including the types of portfolio management services, wrap fee charges, discretionary authorities, and additional program costs, are provided in our ADV 2A Appendix 1 “Wrap Fee Program Brochure” (“Wrap Fee Brochure”). For a more detailed description of each Advisory Program, contact your Financial Advisor. 7  DESCRIPTIONS OF ASSET MANAGEMENT SOLUTIONS ADVISORY PROGRAMS First Command Foundations First Command Foundations Advisory Program (“Foundations”) enables FCAS’s IMT to provide you with investment portfolio options (“Model Portfolios”) composed of ETFs subject to certain limitations discussed below and in the Wrap Fee Brochure. The IMT determines which ETFs to include in the Model Portfolios offered to Foundations clients and it will periodically adjust and rebalance Model Portfolio investments to remain consistent with each Model Portfolio’s investment strategies. FCAS does not monitor Foundations accounts on an individual basis, and it does not monitor any other types of non-advisory accounts, including, but not limited to, brokerage accounts. Each Model Portfolio in Foundations is designed to align with a client’s particular risk profile, which is used by the IMT to set the initial asset allocation. This practice attempts to limit risk to clients by investing among a range of different ETF asset classes in Model Portfolios. Any modifications the IMT makes to the Model Portfolios are effected through the sale or purchase of securities in your account, which may have tax ramifications for you. The Model Portfolios utilized in Foundations consist exclusively of passively managed ETFs and are optimized using only stocks, bonds, and cash to provide a more streamlined, core model focused on minimizing internal expenses and slightly improved tax efficiency. The IMT is responsible for managing your Foundations account in accordance with the Model Portfolio(s) recommended to you by your Financial Advisor. IMT management provides due diligence and oversight, including ongoing account monitoring and rebalancing. You remain the owner of all securities held in your account and have all ownership rights associated with these securities. Model Portfolios may be added or discontinued over time in FCAS’s discretion. First Command Select First Command Select Advisory Program (“Select”) enables the IMT to provide you with Model Portfolios composed of active or passive mutual funds and ETFs, subject to certain limitations discussed below and in the Wrap Fee Brochure. The IMT determines which mutual funds and/or ETFs to include in the Model Portfolios available to Select clients and it will periodically adjust and rebalance Model Portfolio investments to remain consistent with each Model Portfolio’s investment strategies. FCAS does not monitor Select accounts on an individual basis, and it does not monitor any other types of non-advisory accounts, including, but not limited to, brokerage accounts. Each Model Portfolio in Select is designed to align with a client’s particular risk profile, which is used by the IMT to set the initial asset allocation. This practice attempts to limit risk to clients by investing among a range of different mutual fund and ETF asset classes in Model Portfolios. Any modifications the IMT makes to the Model Portfolios are effected through the sale or purchase of securities in your account, which may have tax ramifications for you. For some Model Portfolios in Select, municipal bond fund options are available. While both Foundations and Select accounts receive the same level of IMT due diligence and oversight, including ongoing account monitoring and rebalancing, Select’s Model Portfolios invest in a combination of both passively and actively managed ETFs and mutual funds in order to provide exposure to broader diversification of stocks, bonds, and cash plus the inclusion of real assets (real estate, natural resources, etc.). This broader asset class scope also allows the IMT to optimize the Model Portfolio(s) with regards to various sector and factor exposures and increase the IMT’s capacity to make tactical adjustments to the applicable Model Portfolio when the IMT deems prudent. Model Portfolios may be added or discontinued over time in FCAS’s discretion. 8  First Command Premier Income The First Command Premier Income Advisory Program (“Premier Income”) is an investment advisory program that manages client’s assets in accordance with a single fixed income model in a separately managed account (“SMA”). The fixed income investment style represented in the model is managed by an investment manager from a third-party investment advisor who specializes in fixed income strategies. These investment advisers and their strategies are selected for inclusion in the Premier Income Advisory Program by the IMT. Clients enrolled in this Program have their account assets invested in individual securities (e.g., bonds). Your Financial Advisor will engage with a WPM, who will recommend and direct the allocation of assets in your Premier Income account to a third-party investment advisor’s fixed income model in a manner consistent with your investment objectives. Some fixed income models allow for client-specific preferences to be submitted by the WPM (e.g., state specific municipal bond purchases). The wrap fee FCAS charges for Premier Income does not include the third-party investment adviser’s management fee or Envestnet’s portfolio administrative fee, if applicable, which is passed through to the client. These third-party fees vary from one third party investment adviser to another. Speak to your Financial Advisor for more information about the options available to you. First Command Elite The First Command Elite Advisory Program (“Elite”) is an investment advisory program known as a unified managed account (or UMA). Clients’ assets are invested in, or via, different types of investment vehicles, such as ETFs, mutual funds, third-party managed portfolios, IMT Model Portfolios, and individual stocks and bonds, within a single, unified account. Elite clients are assigned to a FCAS WPM who works directly with the client, the client’s Financial Advisor, and third-party investment managers (as applicable) to manage the client’s assets across multiple “sleeves” (some of which are securities and some of which are portfolios managed by investment advisers) available within the UMA. The availability of “sleeves” within the UMA allows multiple investment managers, who may or may not be affiliated with FCAS, to each manage a portion of the account’s assets on a discretionary basis. Envestnet provides portfolio analysis, investment manager due diligence for some investments, ongoing monitoring, and centralized trading capabilities for your Elite account. In addition, some third-party investment managers have entered into an agreement with Envestnet under which they provide, manage, and maintain portfolio models that are implemented by Envestnet within your Elite account on a discretionary basis. Third-party investment managers have additional management fees that are not included in the Elite Wrap Fee; accordingly, if a client has assets allocated to a sleeve within Elite that is managed by a third-party investment manager, the fees charged to the client will include the third-party investment manager’s fees in addition to the wrap fee charged by FCAS for an Elite account. Your WPM makes recommendations for the allocation of assets in your Elite account in a manner consistent with your investment objectives. The WPM directs the implementation of these recommendations and will direct the selection and termination of investment manager(s) at the account level on a discretionary basis. Clients with Elite accounts can choose overlay services, provided by Envestnet, for an additional cost that is passed through to the client. There are two types of overlay services Envestnet provides. The first overlay service is a tax overlay. Tax overlay is intended to integrate tax considerations into portfolio management and provide continuous services such as tax-loss harvesting, tax-efficient rebalancing, and year-round tax management to maximize a client’s after-tax returns. The methodologies and 9  assumptions used by FCAS or its Financial Advisors may not be appropriate in all client situations. Clients can also choose the values overlay. Values overlay allows clients to align their investment strategy with their personal beliefs, ethics, or social values. The values overlay is a very qualitative process. The values overlay provides a snapshot of what a client’s account would look like without the selected values restriction. Then, it would try to replicate the performance of the account had those constraints not been in place by selecting alternative securities that are expected to perform similarly to like accounts that do not have such value-based constraints. Clients with Elite accounts can also request the WPM to avoid a certain security or group of securities. There is no additional cost to the client for this level of customization. However, unlike the values overlay described above, if an Elite client requests to avoid a certain security or group of securities without choosing the values overlay, there is no provided optimization services associated with the avoidance of certain securities or groups of securities. Further, FCAS does not separately provide optimization services to an Elite account when the client has requested avoidance of a certain security or group of securities without electing to utilize a values overlay. Services Provided under the Advisory Programs The following services are included as part of all Asset Management Solutions Advisory Programs: • Asset management; • Account statements that will include all investment positions, market values and transactions; • Annual tax reports for use in preparing federal and state tax returns; • Online quarterly portfolio performance reports; • Quarterly economic and market summaries; and • One-time or periodic third-party distributions upon your written request. A signature guarantee may be required. CHOOSING MUTUAL FUNDS AND ETFS TO HOLD IN THE ADVISORY PROGRAMS Choosing ETFs to Hold in Foundations. The IMT, on a fully discretionary basis, will choose ETFs for Foundations Model Portfolios from certain lists of funds that are available on Pershing’s platform. The IMT will always choose ETFs for inclusion in a Foundations Model Portfolio consistent with what serves our clients’ best interests. When the IMT conducts a search for a new ETF for inclusion in these Model Portfolios, it will narrow down the applicable investment universe to a short list of ETFs that are equally suitable and recommendable. The IMT, on a fully discretionary basis, will choose ETFs for Foundations Model Portfolios available on Pershing’s platform. The IMT will always choose ETFs for inclusion in the Model Portfolios consistent with what serves our clients’ best interests. Choosing Mutual Funds and ETFs to Hold in Select. The IMT, on a fully discretionary basis, will choose mutual funds and ETFs for Select Model Portfolios from certain lists of funds that are available on Pershing’s platform. The IMT will always choose mutual funds and ETFs for inclusion in a Select Model Portfolio consistent with what serves our clients’ best interests. When the IMT conducts a search for a new mutual fund or ETF for inclusion in these Model Portfolios, it will narrow down the applicable investment universe to a short list of mutual funds or ETFs that are equally suitable and recommendable, which includes mutual funds from the Primary Fund Families. The IMT, on a fully discretionary basis, will choose mutual funds and ETFs for Select Model Portfolios that are available on Pershing’s platform. The IMT will always choose mutual funds and ETFs for inclusion in the Model Portfolios consistent with what serves our clients’ best interests. 10  Choosing Third-Party Investment Managers in Premier Income and Elite. The IMT, on a fully discretionary basis, will evaluate and select third-party investment managers for inclusion in Premier Income and Elite Advisory Programs. The IMT selects a portfolio managed by third-party investment manager (also known as an SMA manager) based on an available slate of available third-party managed accounts already prescreened by Envestnet’s Portfolio Management Consultants (PMC). The IMT chooses each investment option based on its own due diligence, and aims to select the option based on what they deem as the most appropriate for inclusion of the Premier Income Program. Considerations include cost, performance, management team, and investment philosophy. The IMT may also rely solely on due diligence provided by PMC for ongoing due diligence on a third- party managed account’s performance. When a client chooses to open a Premier Income account, the WPM will invest in a third-party managed account that will meet the client’s best interests and investment strategy. If the client opens an Elite account, the WPM may recommend and direct investment in a third-party managed account in line with the client’s best interests and investment strategy. The third-party managed accounts selected must be approved by the IMT. Depending on the Advisory Program, your WPM has discretion to select one or more a third-party managed accounts from the IMT-approved list and to add and remove third-party investment managers from the account. Choosing Investments in Elite. The IMT, on a fully discretionary basis, will evaluate and select available program investments, including third-party investment managers, for inclusion in Elite. The IMT chooses each investment option based on its own due diligence with considerations that includes each option’s cost, performance, management team, and investment philosophy. The IMT may also rely solely on due diligence provided by Envestnet’s Portfolio Management Consultants (PMC) for the selection of and ongoing due diligence on any investment. When a client chooses to open an Elite account, a WPM is assigned to work with a client and their Financial Advisor to provide a customized portfolio recommendation. The portfolio recommendation will be based upon a client's financial situation, objectives, risk tolerance, time horizon, financial information, values, liquidity needs, and other factors. The WPM then directs the implementation of these recommendations and will direct the selection and termination of investment manager(s) on a discretionary basis. PROPRIETARY HOME OFFICE MODEL SELECTION OF MUTUAL FUNDS AND ETFS The disclosures below apply to mutual funds and ETFs managed by the IMT whether as a Model Portfolio in a Foundations or Select account or as a sleeve of the Elite Advisory Program (together, “Proprietary Home Office Model”). For additional information concerning third-party investment managers that invest in mutual funds and ETFs, please refer to the disclosures of these third-party investment managers, such as their Form ADV brochures, for more information on their practices. For Proprietary Home Office Models, the IMT gives preference to mutual funds and ETFs from one of the Primary Fund Families. This creates a conflict of interest because these Primary Fund Families give FCBS money and benefits in exchange for consideration and meetings to discuss investments into their funds. This conflict is mitigated because FCAS does not use the benefits conferred to FCBS by the Primary Fund Families as a factor in the IMT’s selection of funds. If a mutual fund or ETF that is not from one of the Primary Fund Families is more suitable and recommendable, the IMT will select that mutual fund or exchange traded fund instead. If a Primary Fund Family fund or ETF is equally recommendable with that of a non-Primary Fund family, the IMT will give preference to the Primary Fund Family fund. In addition, certain mutual funds and ETFs may impose short-term redemption fees for redemptions of funds that occur prior to the specified period as outlined in the prospectus. This fee, if applicable, is withheld by the fund company upon liquidation of the fund position and is separate from other fees associated with either the fund or the applicable Advisory Program. 11  The IMT will not consider revenue sharing, cost reimbursements, or any other type of compensation when determining which mutual funds or ETFs to purchase. The IMT is not provided with this information and does not consider it a factor in its analysis. The IMT does not choose funds that have surcharge fees associated with the funds, which may lead the IMT to select a share class that does not have the lowest expense ratio. FCAS does not receive any revenue from using mutual funds or ETFs available through Pershing’s platform. Under FCBS’s contract with Pershing, Pershing provides FCAS access to all mutual funds and ETFs offered on Pershing’s platform and does not charge FCAS or its Affiliates with transaction fees associated with the selected funds. Because FCAS does not have to pay transaction fees to Pershing in connection with the purchase and sale of mutual funds and ETFs for clients, it incurs lower costs to administer its Advisory Programs. This creates a conflict of interest because FCAS has fewer expenses due to the waiver of transaction fees and, as a result, earns more revenue. Clients could pay lower internal operating expenses on the mutual funds and ETFs that are purchased for their accounts than they would if FCBS’s contract with Pershing did not waive those transaction fees. This conflict of interest is mitigated because the waiver of transaction fees affords FCAS the flexibility to select among all available share classes in selecting funds without regard to transaction fees. These selections are further subject to due diligence as described in this Brochure. Some securities on Pershing’s platform will charge FCAS surcharge fees for the selected security and those fees will be passed on to the client. FCAS strives utilize the lowest cost share class available without a surcharge, there may be other less costly share classes offered by a fund that are not available to FCAS on the Pershing platform or are subject to other conditions or restrictions that would make utilizing such share class unreasonable, costly, or prohibitive. FCAS will not select securities that are unavailable on the Pershing platform unless at the client’s direction, if permitted under the applicable advisory program. FCAS participates in regular due diligence meetings with representatives of the Primary Fund Families that allows Financial Advisors to receive the most up-to-date information about the investment products offered. This close business relationship allows FCAS to directly work with the fund managers and administrators to address client concerns and needs. FCAS also meets with fund managers to address more general questions about a fund’s performance over time, and this information inures to the benefit of FCAS clients generally. Financial Advisors generally have a greater degree of familiarity with investment products from the Primary Fund Family partners (as of the date of this Brochure): Invesco, MFS, Fidelity Advisor, Victory Pioneer, Franklin Templeton, and Blackrock. The Primary Fund Family partners also pay FCBS revenue sharing for mutual fund assets held in brokerage accounts. They do not, however, pay any revenue sharing for mutual fund assets held in AMS accounts. Some Primary Fund Families will also sponsor or offer reimbursement for costs related to training, education and other events for our Advisors and clients and/or pay marketing support services fees to FCBS. All mutual funds held in the AMS program are sold by FCBS under a prospectus where the various share classes and internal fees are outlined. FCAS strongly encourages you to review the fund prospectus. PROPRIETARY HOME OFFICE MODEL MUTUAL FUND SHARE CLASSES SELECTION The IMT, in selecting mutual fund share classes in its Proprietary Home Office Models, strives to choose the share class that serves our clients’ best interests. The appropriate share class will be chosen from among eligible share classes, after considering the underlying expense ratio and redemption fees of the share class. FCAS will generally select the share class that does not charge 12  surcharge fees and has historically experienced the lowest expense ratio from among the share classes that FCAS is eligible to purchase in its Proprietary Home Office Models. Typically, the share class chosen will be an institutional or similar share class. In certain instances, a lower cost share class may be available, but FCAS may be ineligible to purchase such share class due to the requirements of the mutual fund or the mutual fund’s distribution guidelines or because a lower cost share class would charge surcharge fees, and this would cause an increase in expenses that would be passed along to the you, affecting the profitability of your investment. You may be eligible to purchase such lower cost share classes outside of the Asset Management Solutions Advisory Programs. All accounts (or sleeves in the Elite Advisory Program) managed in accordance with a Proprietary Home Office Model will use the same share class. The IMT will select the most appropriate share class that all clients utilizing a Proprietary Home Office Models are eligible to purchase instead of selecting the share class based on individual accounts. As such, there may be a share class for a particular mutual fund that experiences lower expenses than the share class selected for such fund to be held in accounts (or sleeves for Elite) utilizing the Proprietary Home Office Models. For similar reasons, you may be eligible to purchase certain share classes for a particular mutual fund outside of the applicable Asset Management Solutions Advisory Program that may experience lower expenses than the share class used for such fund in the applicable Program. Investment Management Platform FCAS has an agreement with Envestnet Asset Management, Inc. (“Envestnet”) whereby Envestnet (by and through its affiliates) will provide FCAS with its Investment Management Platform Services. Envestnet offers certain services through an integrated third-party service and technology provider, which provides various administrative, investment advisory, investment management, model portfolio management, overlay management, tax overlay services, investment and manager due diligence, research, reporting, trade implementation, compliance monitoring, operational support, and/or other services. Envestnet is not a tax advisor, nor does it provide any tax advice, and clients should consult their tax consultant prior to electing the tax overlay service offered by Envestnet. For a complete description of Envestnet’s services, please refer to Envestnet’s Form ADV Part 2A and Form Part 2A Appendix 1, which is available at https://www.investpmc.com/ADVPart2A, or you can request these documents from FCAS or your Financial Advisor at any time and free of charge. The fees charged by Envestnet for its Investment Management Platform Services are based in part on the total aggregate asset value all client assets serviced by Envestnet. These fees are based on a tiered schedule where if certain breakpoints are met for the total aggregate assets, the applicable fees for the Investment Management Platform Services (expressed in basis points) are reduced. This cost structure is a conflict of interest because it incentivizes FCAS to recommend client assets be held in an Asset Management Solutions program because it will reduce FCAS’s costs for Envestnet’s Investment Management Platform Services in connection with maintaining the AMS program. It is also a conflict of interest because we have an incentive to recommend that you increase your investment in your account, as that allows FCAS to pay lower fees for Envestnet’s Investment Management Platform Services. This conflict is mitigated by the Advisory Fee Schedule which reduces the fee percentage charged to the client based on the client’s assets within the selected Asset Management Solutions Advisory Program(s). Envestnet’s operational cost is more expensive for FCAS than certain other investment platform service providers. The Advisory Fees cover FCAS’s operating costs incurred by using Envestnet instead of another investment platform service provider. We have a conflict because our revenue from the Advisory Fees is higher than the operating costs FCAS incurs from Envestnet. This conflict is mitigated by the significant capabilities Envestnet provides to FCAS and its clients, relative to other platform 13  services providers, including but not limited to the ability to generate custom reports, improved customer service, and the opportunity to develop and offer additional advisory programs in the future. Assets Under Management As of September 30, 2025, First Command Advisory Services, Inc. manages $24.3 billion on a discretionary basis. Investment Management Agreement Required In order to obtain financial planning services without also opening an account in the Advisory Program, you will need to sign a separate agreement specifically for the TPS Program. To obtain investment advisory services from FCAS, you will be required to enter into an agreement for those services (commonly referred to as the “Investment Management Agreement” or “IMA”). The IMA is designed to clearly define the roles and responsibilities between FCAS and you. FCAS may update its service offerings and Advisory Program(s) from time-to-time. FCAS may amend the IMA if we give you written notice of such amendment and you do not object to the amendment within thirty (30) days after we send such notice to you. We will send such notice by U.S. mail to your last known address of record, or electronically deliver the notice to you if you have agreed to receive documents and information under the IMA electronically. After FCAS sends notice of an amendment to you, you will have thirty (30) days from delivery of the amendment to respond in writing that you either consent to or do not consent to the amendment. The notice of the amendment will contain instructions on how to respond. If you do not respond by the end of the thirty (30) day period or continue to receive our investment advisory services after the thirty (30) day period, you will be deemed to have consented to the amendment. While you may consent to or not consent to any amendment We seek to make to the IMA, if you choose not to consent to any such amendment, we will terminate the IMA in accordance with its terms. Existing investment advisory clients who choose to take advantage of a new Advisory Program in the future may be required to sign a new IMA. ITEM 5 - FEES AND COMPENSATION FINANCIAL PLANNING FEES As provided in this Brochure, FCAS offers complimentary financial planning services to active-duty service members and to others at FCAS’s discretion. Financial Advisors can also provide complimentary financial planning services to clients enrolled in an Advisory Program, at the Financial Advisor’s discretion. For individuals who request financial planning services who do not qualify to receive such services on a complimentary basis or have more complex financial planning needs, FCAS, through its Financial Advisors, also offers personalized financial planning services for a fee through a program called Tailored Professional Services (“TPS” or “TPS Program”). Fees charged by FCAS for TPS services generally range from $750 to $3,000. The TPS fee is based on the client’s income and investable assets, the complexity of the client’s situations, and the experience and credentials of the assigned Financial Advisor. These fees are set by your Financial Advisor and are subject for negotiation with your Financial Advisor. FCAS and your Financial Advisor will each receive a portion of the TPS fee. The amount of this compensation will be more than your Financial Advisor would receive if they chose not to charge a TPS 14  fee. Your Financial Advisor therefore may have a financial incentive to charge you for financial planning services through TPS than those provided to others on a complimentary basis or at a lower rate. ADVISORY PROGRAMS FEES If you desire to participate in one of our Advisory Programs, your Financial Advisor will provide you with a copy of our Wrap Fee Brochure, which, in addition to this brochure, further explains, in detail, the fees and related compensation for the Asset Management Solutions Advisory Programs. Wrap Fee A wrap fee program generally involves an investment account where you are charged a single, bundled, or “wrap” fee for investment advice, brokerage services, administrative expenses, and other fees and expenses. FCAS’s Asset Management Solutions Advisory Programs charge you a wrap fee for the day-to-day asset management, costs for execution of securities transactions and oversight of each of your Advisory Program accounts. The wrap fee for an Advisory Program is also referred to as an Advisory Fee. The Advisory Fee is based on a percentage of the value of your account, rather than upon transactions in your account. Additionally, the annual Advisory Fee for the Advisory Programs is not negotiable, except for clients who contribute more than $5 million with respect to an Elite account. We reserve the right, in our sole discretion, to discount advisory fees for clients. Advisory Fees are assessed monthly in advance based on the previous month’s ending balance of assets under management in your account. Advisory Fees will be deducted from your account assets when due. In the event any deposits and withdrawals (netted) equal or exceed $10,000 (in market value on an absolute basis) on any business day in an account, an interim, prorated Advisory Fee will be charged or refunded (as applicable) to the account. This is commonly referred to as flow or interim billing and is only applicable on an account-by-account basis (not aggregated with other related accounts). Each interim prorated Advisory Fee is assessed within 2-5 business days of the receipt/payment of the deposits/withdrawals (netted) and is based on the number of days remaining in the current billing period. FCAS’s advisory program services may be terminated via notice at any time by either the client or FCAS and, following the receipt of a notice of termination, the client will be issued a prorated refund of paid Advisory Fees, based upon the number of days from the termination date through the end of the then-current fee period. A refund, if any, is paid the month following the termination date. Advisory Management Services (AMS) Annual Advisory Fee Schedule The annual AMS Advisory Fee charged for FIP and SIP are the same and are calculated as shown in the below AMS Fee Schedule: The Advisory Fees are provided below for each program. 15  Foundations Wrap Fee Schedule Select Wrap Fee Schedule Value of Account Assets Annual Management Fee Value of Account Assets Annual Management Fee $0 - $250,000 1.30% $0 - $250,000 1.30% $250,001 - $500,000 1.15% $250,001 - $500,000 1.15% $500,001 - $1 million 1.00% $500,001 - $1 million 1.00% $1 million - $2 million 0.75% $1 million - $2 million 0.75% over $2 million 0.50% over $2 million 0.50% Premier Income Wrap Fee Schedule Value of Account Assets Annual Management Fee Over $500,000 0.50%* *First Command fee only. Third-party investment manager fees and platform fees apply. Elite Wrap Fee Schedule Elite Transitional Wrap Fee Schedule** Value of Account Assets Annual Management Fee Value of Account Assets Annual Management Fee 0 - $500,000 1.30% 0 - $500,000 1.30% $500,001 - $1 million 1.20% $500,001 - $1 million 1.10% $1 million - $2 million 1.10% $1 million - $2 million 0.95% $2 million - $3 million 1.00% $2 million - $3 million 0.85% $3 million - $5 million 0.90% $3 million - $5 million 0.70% over $5 million 0.60%* over $5 million 0.50% * Elite clients with this balance may negotiate their annual management fee. **This Fee is only available to FCB Investment Management Account clients who transition to Elite before September 30, 2026. This fee is temporary and covers the first twelve (12) months of an FCB Investment Managed Account client’s transfer to an Elite account (transition period). Fees revert to the regular Elite Wrap Fee Schedule after the transition period. 16  We will aggregate assets you have in Foundations, Select, and Elite Advisory Program accounts for purposes of qualifying for a lower Advisory Fee. Assets may be aggregated regardless of whether you participate only in Foundations, only in Select, only in Elite, or any combination of these three Programs. If you participate in any combination of Foundations, Select, and Elite, the Advisory Fee will be calculated using a blended fee structure. We will: (1) first calculate the Advisory Fee that would result if all assets were held in each Program; (2) determine the percentage of assets held in each Program relative to total qualifying assets within the Program; and (3) apply the percentage realized for each Program in step ‘(2)’ to the Advisory Fee determined for that Program in step ‘(1)’ to arrive at the total blended Advisory Fee. Assets in Premier Income will not be aggregated with assets in any other Asset Management Solutions Advisory Programs for purposes of lowering the fee schedule. The Premier Income Advisory Fee is composed of: the annual advisory fee charged by FCAS and the management fee charged by the particular third-party investment manager your WPM selected, which includes the management fee charged by the third-party investment manager and the Envestnet portfolio administrative fee (also known as Envestnet’s “gateway fee”). Your Financial Advisor will provide you with the third-party investment manager selected for your account and their fees. Envestnet’s portfolio administration fee only applies to third-party investment managers; it is not applied to First Command proprietary portfolio models. The third-party investment manager is responsible for ensuring you are provided with their firm’s fee brochure and disclosures OTHER FEES, EXPENSES AND COSTS OUTSIDE THE AMS ADVISORY FEE Fees for Certain Requested Services and Specific Account Actions All securities and brokerage transactions in Asset Management Solutions Advisory Programs are effected by FCBS as an introducing broker-dealer. As described above, you will not pay a separate fee for transaction costs or expenses incurred in your account (i.e., commissions, ticket charges, etc.), but you will pay additional fees as detailed below. FCBS incurs certain fees pursuant to its clearing relationship with Pershing LLC (“Pershing”) related to processing requested services and facilitating specific administrative actions for your account. Pershing is the firm that is responsible for custodianship of assets and clearance and settlement of all trades within Asset Management Solutions Advisory Programs. These fees are passed along to you after being adjusted to include FCBS’s compensation for assisting with the service or action. FCBS execution costs and additional services requests will incur additional fees pursuant to the FCBS Fee Schedule. If you have not received a copy of the FCBS Fee Schedule, contact your Financial Advisor or FCAS at the contact information provided on the cover page of this Brochure. FCBS, at its discretion, marks up the various fees detailed in the FCBS Fee Schedule that are assessed by Pershing and paid by clients. FCBS decides how much and which fees will be marked up. Not all brokerage firms mark up these or other fees. The mark-up on these fees generates additional revenue for FCBS. Markups on these types of fees are a conflict of interest because FCBS earns additional revenue from these fees. Certain fees, for example, are avoidable if clients elect e-Delivery of certain account-related documents. The actual fees and charges that clients will incur are dependent upon the type of account and the nature and quantity of the transactions that occur, the services provided, or the positions held in the account. FCBS shares its IRA Custodial fees with FCB and Pershing in consideration for the services provided by these entities to support FCB as the IRA custodian and Pershing’s clearing role and tax reporting to the Internal Revenue Service. This conflict of interest is mitigated as neither FCAS or your Financial Advisor receives any portion of the IRA custodial fees. 17  Overlay Services. Specific to Elite accounts, FCAS will pass through the cost of overlay features and any fees charged by third-party investment managers directly to your account. Such fees are not marked up by FCAS or its Affiliated Companies and neither FCAS nor your Financial Advisor receive any portion of these fees. Compensation to Your Financial Advisor FCAS and your Financial Advisor will each receive a portion of the Advisory Fee. Other fees you may incur as discussed in this Brochure related to your AMS account, i.e., fees included in the FCBS Fee Schedule, are not shared with your Financial Advisor, and, as such, your Financial Advisor does not consider such fees when deciding what to recommend to you. Financial Advisors receive a portion of the Advisory Fee for consultation and other services to you with respect to the AMS program. The amount of this compensation may be more than your Financial Advisor would receive if the client participated in other FCAS programs or paid separately for investment advice, brokerage, and other services. Your Financial Advisor therefore may have a financial incentive to recommend the wrap fee program over other programs or services. The amount paid to your Financial Advisor will generally be less than if you had purchased the same investments outside the program and paid a sales charge or brokerage fee. However, for assets remaining in the program for the long term, your Financial Advisor’s compensation may be more than if you had purchased the funds outside the program. Fees and Compensation Related to Brokerage, Insurance, and Banking Products Your Financial Advisor is also a registered representative of FCAS’s affiliated broker-dealer, FCBS, and a licensed insurance agent with FCIS. Financial Advisors are also compensated for the sale of FCBS brokerage products (including fees from the sale of mutual funds and/or ETFs), FCIS insurance products, and, in limited circumstances, FCB banking products. Your payments to FCBS, FCIS, Financial Advisors and/or FCIS insurance agents by and through our Affiliated Companies creates conflicts of interest. The types of payments described in this disclosure brochure are common in the broker-dealer, investment adviser, insurance, and banking industries. Because your Financial Advisor serves in multiple capacities, your Financial Advisor has an incentive to recommend investment products or services that create the greatest compensation for your Financial Advisor. FCAS mitigates this conflict of interest in several ways. In addition to disclosing these conflicts of interest, FCAS has created and implemented compliance and supervisory policies and procedures to mitigate such conflicts through the oversight of client accounts and investment advisory activities. FCAS mitigates these conflicts of interest, in part, by endeavoring to act in each client’s best interest and through the adoption and implementation of a Code of Ethics (as detailed below) and other policies and procedures. To determine whether your Financial Advisor earns compensation in multiple capacities, review your Financial Advisor’s Form ADV 2B Brochure Supplement or contact FCAS corporate headquarters in Fort Worth, Texas (“Home Office”) using the information on the cover page of this Part 2A Disclosure Brochure. The information provided in this Brochure regarding other compensation is not intended to be exhaustive of all of the other compensation arrangements. Rather, it is a general description of the other compensation arrangements that FCAS believes are material to its clients and potential clients in making an informed decision whether to engage FCAS and its Financial Advisors to provide investment advisory products and services. By entering into a written agreement with FCAS, you (the client) consent to FCAS’, its Affiliated Companies’ and/or its Financial Advisors’ retaining their respective portion of other compensation (directly or indirectly) in connection with FCAS’ investment advisory 18  19 products and services you receive from and through FCAS. FCAS encourages you to discuss this with your Financial Advisor or to contact FCAS with any client-specific questions. You generally will pay commissions, fees, and other costs if you purchase one or more products and services offered by FCBS, FCIS, and FCB. These fees and charges are in addition to and separate from any financial planning and/or investment advisory fees for the Advisory Program discussed above. The payment of Advisory Fees discussed above for either the TPS Program or any Advisory Program are not offset by commissions, fees, and other costs incurred as a result of your purchase of products and/or services through FCBS, FCIS and/or FCB. FCBS’S REGULATION BEST INTEREST DISCLOSURE As previously described above, FCAS’s affiliated broker-dealer, FCBS, provides brokerage, custody, and execution services through its clearing arrangement with Pershing, a non-affiliated firm. FCBS receives direct and indirect compensation from Pershing, in part, based on FCAS’s advisory clients and assets held in custody with Pershing. FCBS has negotiated a long-term contract with Pershing, that contains an early termination penalty and is otherwise financially incentivized to use Pershing as its custodian and to move more advisory client accounts on to the Pershing platform and for those accounts to stay with Pershing. FCBS does not directly share this financial compensation with FCAS. For more complete details on these conflicts of interest and others, refer to Item 10 of this Brochure, the FCBS Regulation Best Interest (Reg BI) Disclosure document, and the FCBS Fee Schedule. FCBS’s Regulation Best Interest Disclosure Document (“Reg BI Disclosure Document”) includes information related to (1) material facts relating to the scope and terms of your relationship with FCBS including the capacity in which it acts as a broker-dealer when providing services to you; (2) the material fees and costs that will apply to your transactions, holdings and accounts held through FCBS; and (3) the conflicts of interest associated with FCBS recommending that you establish an investment account, transact in securities or select an investment strategy. FCBS employs a range of policies, procedures, supervision systems and other measures to help mitigate its conflicts of interest. You will receive FCBS’s Reg BI Disclosure Document prior to or at the time you receive a recommendation from a FCAS Financial Advisor for FCBS services. You may also obtain a copy of FCBS’s Reg BI Disclosure Document by contacting your Financial Advisor, calling FCAS’s Home Office at 800.443.2104 (overseas, call 817.731.8621), or visiting https://cdn.firstcommand.com/assets/web-documents/regulation-best-interest-disclosure.pdf. ITEM 6 - PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge performance-based fees. We also do not offer side-by-side management. ITEM 7 - TYPES OF CLIENTS First Command investment advisory services are open to individuals, corporate entities, charitable organizations and other institutions, and trusts only. We do not do business with pension plans or investment companies. The account minimums for the Advisory Programs are provided below:  Financial Advisor with whom you have worked shall be liable for performance or non-performance of Program Name Additional Program Costs any investment advice or recommended investment made in good faith and in accord with our duty of Minimum Account Size Maximum Annual Program Fee care. $20,000 1.30% First Command Foundations Methods of Analysis and Investment Strategies for Foundations and Select Advisory Programs Your Financial Advisor is responsible for the client relationship in the Foundations and Select Advisory $50,000 1.30% First Command Select Programs and provides recommendations to you subject to FCAS’s supervision and compliance requirements. $500,000 0.50% Third-party investment manager fees First Command Premier Income FCAS’s IMT performs due diligence on investment products purchased for or recommended to our Foundations and Select Advisory Program clients and manages the day-to-day decisions for the $1,000,000 1.30% transactions occurring in client accounts for the Foundations and Select Advisory Programs. The IMT is First Command Elite Third-party investment manager fee(s); overlay services (optional) responsible for creating and maintaining Model Portfolios in the Foundations and Select Advisory Programs. The IMT follows a disciplined approach in researching current and potential investments, with decisions based on: • Philosophy. We are biased toward mutual funds and ETFs managed by managers who select investments based on fundamental analysis of underlying business characteristics, comprehensive review of financial statements, and prudent consideration of risks including security valuation. • Process. We seek alignment of the process with the stated philosophy and evidence of its consistency and successful execution over time. • People. The character of the individuals who will manage the funds we select is of the utmost If the minimum initial investment amount is not met within 90 days of account opening or account assets are reduced due to client withdrawals to less than the account minimum, we reserve the right to terminate your IMA, liquidate your account, and send the proceeds to you. We will provide you with prior notice indicating the specific action we will take if the minimum asset amount is not met in a timely manner or account assets are reduced due to client withdrawals to less than the account minimum. Liquidating your account or converting your account from one Advisory Program to another Advisory Program may result in a taxable event and/or a higher wrap fee. The minimum initial investment amount may be changed from time to time or waived at FCAS’s sole discretion. Subsequent investments shall not be less than $100. The notice we send to you will state the specific action we will take if the account assets are not restored to meet the account minimum in a timely manner. importance. We must maintain high confidence in the experience, integrity, and dedication of those who have primary responsibility for investment decisions and be comfortable with the teams which support them and the firm cultures in which they operate. • Price. We must believe that the cost of a product is reasonable in the context of the value it can deliver for clients and in comparison, to similar alternatives. The IMT uses a variety of quantitative and qualitative techniques as part of its analysis, including many principles which have collectively become known as Modern Portfolio Theory. Modern Portfolio Theory is a theory of investment which attempts to maximize portfolio expected return for a given amount of In the event an account is deemed ineligible for the applicable Advisory Program, such as no longer meeting a Program’s minimum requirements or not funding an account (account minimum requirements) within 90 days of opening an account, FCAS has the sole authority to move the Program account to a retail, brokerage account with FCBS. Upon this move, FCAS’s Advisory Program services will be discontinued and the related Advisory Fee will be terminated in accordance with FCAS’s policies (e.g. never charged or refunded). FCAS and your Financial Advisor will no longer be obligated to provide ongoing advice, and any trading will be done at your request (non-discretionary) subject to retail commissions on a trade-by-trade basis. portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully choosing the proportions of various assets. You are eligible to obtain financial planning services, including through the TPS Program, without establishing or maintaining an investment account through FCBS. Methods of Analysis and Investment Strategies for Premier Income and Elite Advisory Programs Your Financial Advisor is responsible for the client relationship and will recommend the Premier Income or Elite Advisory Program to you subject to FCAS’s supervision and compliance requirements. ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Upon your Financial Advisor’s recommendation to you to open a Premier Income or Elite account, a WPM is assigned to work with you, your Financial Advisor, and the IMT (as applicable). For Premier METHODS OF ANALYSIS AND INVESTMENT STRATEGIES; GENERALLY Income accounts, the WPM’s role is to select a third-party investment manager and complete the manager-required documents, including any changes to the third-party investment manager selection. For Elite accounts, your WPM is responsible for providing and directing customized strategies. The WPM will select investments for you in accordance with the Advisory Program’s requirements and the customized investment strategy. For example, in a Premier Income account, the WPM will select a third-party investment manager that aligns with your investment strategy. In an Elite account, the WPM will select and manage your assets across multiple sleeves selected by the WPM and available within FCAS, through its Financial Advisors, IMT, and WPMs use a variety of quantitative and qualitative techniques as part of its analysis to minimize risk. Of course, while risk can be managed, it cannot be avoided. Investing in securities involves risk of loss that clients should be prepared to bear. We do not guarantee the performance of any investments or guarantee that our investment advice or strategies or that of any Financial Advisor will be successful or that your investment objectives will be met. Investment advice or financial planning recommendations provided by us (including the IMT and WPMs) or any Financial Advisor, are largely a matter of professional judgment, and neither us nor any 20 21  Financial Advisor with whom you have worked shall be liable for performance or non-performance of any investment advice or recommended investment made in good faith and in accord with our duty of care. Methods of Analysis and Investment Strategies for Foundations and Select Advisory Programs Your Financial Advisor is responsible for the client relationship in the Foundations and Select Advisory Programs and provides recommendations to you subject to FCAS’s supervision and compliance requirements. FCAS’s IMT performs due diligence on investment products purchased for or recommended to our Foundations and Select Advisory Program clients and manages the day-to-day decisions for the transactions occurring in client accounts for the Foundations and Select Advisory Programs. The IMT is responsible for creating and maintaining Model Portfolios in the Foundations and Select Advisory Programs. The IMT follows a disciplined approach in researching current and potential investments, with decisions based on: • Philosophy. We are biased toward mutual funds and ETFs managed by managers who select investments based on fundamental analysis of underlying business characteristics, comprehensive review of financial statements, and prudent consideration of risks including security valuation. • Process. We seek alignment of the process with the stated philosophy and evidence of its consistency and successful execution over time. • People. The character of the individuals who will manage the funds we select is of the utmost importance. We must maintain high confidence in the experience, integrity, and dedication of those who have primary responsibility for investment decisions and be comfortable with the teams which support them and the firm cultures in which they operate. • Price. We must believe that the cost of a product is reasonable in the context of the value it can deliver for clients and in comparison, to similar alternatives. The IMT uses a variety of quantitative and qualitative techniques as part of its analysis, including many principles which have collectively become known as Modern Portfolio Theory. Modern Portfolio Theory is a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully choosing the proportions of various assets. Methods of Analysis and Investment Strategies for Premier Income and Elite Advisory Programs Your Financial Advisor is responsible for the client relationship and will recommend the Premier Income or Elite Advisory Program to you subject to FCAS’s supervision and compliance requirements. Upon your Financial Advisor’s recommendation to you to open a Premier Income or Elite account, a WPM is assigned to work with you, your Financial Advisor, and the IMT (as applicable). For Premier Income accounts, the WPM’s role is to select a third-party investment manager and complete the manager-required documents, including any changes to the third-party investment manager selection. For Elite accounts, your WPM is responsible for providing and directing customized strategies. The WPM will select investments for you in accordance with the Advisory Program’s requirements and the customized investment strategy. For example, in a Premier Income account, the WPM will select a third-party investment manager that aligns with your investment strategy. In an Elite account, the WPM will select and manage your assets across multiple sleeves selected by the WPM and available within 21  the Elite Account. The availability of sleeves within the Elite account allows multiple investment managers, who may or may not be affiliated with FCAS, to each manage a portion of the account’s assets on a discretionary basis. FCAS’s WPMs have discretion over the selection of third-party investment managers at the Premier Income and Elite Advisory Program client account level. The WPMs recommend and select an investment strategy based on your financial situation, objectives, risk tolerance, time horizon, financial information, values, liquidity needs, and other factors. All third-party investment managers selected by the WPM must already be approved by the IMT for inclusion in the applicable advisory program. The IMT approves and monitors third-party investments managers at the Advisory Program level as further described in this Brochure and following the principles of Modern Portfolio Theory as provided above. RISK OF LOSS Investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of, nor predictable by FCAS. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war or regional/global pandemic) that affect investments in general or in specific industries or companies. The investment decisions made, and the actions taken in managing client assets will be subject to various market, liquidity, currency, economic, political and other risks. Investing in securities involves a risk of loss that clients should be prepared to bear. The investment performance and the success of any investment strategy or particular investment can never be predicted or guaranteed, and the value of a client’s investments will fluctuate due to market conditions and other factors. Investments may lose value and past performance is never a guarantee of future results. The information contained in this Brochure cannot disclose every potential risk associated with an investment strategy, nor all of the risks applicable to a particular manager, security or investment. Risks vary by client according to their investment objectives, guidelines, liquidity needs or risk tolerances and not every strategy or portfolio will be exposed to each of the risks described in this Brochure and the applicable Advisory Program. This list is not intended to be exhaustive of all of the risks associated with investing in strategies or securities that are utilized or recommended by FCAS. Rather, it is a general description of the nature and risks of the investment advisory services provided by FCAS and the related investments. This summary is qualified in its entirety by reference to the prospectuses and offering documents that apply to the funds and/or strategies that FCAS recommends and/or in which a client invests. Clients should carefully read any applicable prospectuses and/or offering documents and should consider consulting with their legal and/or tax professionals before engaging in any particular investment strategy or transacting in any specific investment. Past performance is no guarantee of future results. The sources of information used by FCAS include materials prepared by organizations such as Morningstar, Inc., financial periodicals, annual reports, prospectuses, independent research subscription services, and the other documents created by the product issuers. While we use the methods and tools noted above as part of our due diligence, each recommendation to a client is primarily built upon the client’s goals, needs, objectives, and attitudes towards risk. The recommendations generally have a long-term focus. The actual risks associated with the investments will vary depending on the particular investment chosen, but the most important risk—like with all securities— remains the potential for loss of principal and income. Other material risks include: (1) the possibility of costs even in case of negative returns; (2) lack of control (e.g., we buy mutual funds and ETFs and the fund manager or portfolio manager controls the buying and selling as well as the timing of the trades for these funds); and (3) price uncertainty (e.g., the price at which you purchase or redeem mutual fund 22  shares will typically depend on the fund’s NAV, which may not be calculated until many hours after you’ve placed your order). Stock market volatility, interest rate changes, inflation risk, interest rate risk, credit risk, political and country risk, management and company risk, etc. should also be taken into account. Other Risks Applicable to all Programs Wash Sales. Under the wash sale rules, if a client sells a security for a loss and the client repurchases the same (or substantially identical) security either 30 days before or 30 days after the date of the sale, the loss is disallowed. The wash sale rules apply to transactions not only in that account but also to transactions in all other accounts held by the client, the client’s spouse, and certain entities controlled by them as related parties. Further, FCAS cannot monitor all assets held outside of clients’ account(s) with FCAS and therefore FCAS strategy will not necessarily consider trading activity in all other security accounts held with third parties. It is the client’s responsibility to comply with the wash sale rules with respect to such accounts. Incorrect assumptions about tax attributes and transactions outside of the FCAS strategy may lead to inefficient tax management. Operational Risk. Portfolios are exposed to operational risk introduced through human intervention or the failure of automated processes. Operational risks include, but are not limited to, reconciliation errors, trading the wrong security, trading a security for an unintended portfolio or purchasing a security that a portfolio was intended to sell, or vice versa. Cybersecurity and Information Security. A portfolio is susceptible to operational and informational security risks due to the increased use of the internet. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyberattacks include, but are not limited to, infection by computer viruses or other malicious software code, gaining unauthorized access to systems, networks, or devices through “hacking” or other means for the purpose of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cybersecurity failures or breaches of third-party service providers may cause disruptions at third-party service providers and impact business operations, potentially resulting in financial losses; the inability to transact business; violations of applicable privacy and other laws, regulatory fines, or penalties; reputational damage; unanticipated expenses or other compensation costs; and/or additional compliance costs. FCAS has an established business continuity and disaster recovery plan and related cybersecurity procedures designed to prevent or reduce the impact of such risks; there are inherent limitations in such plans and systems due in part to the evolving nature of technology and cyberattack tactics. Additionally, FCAS employs reasonable security standards and safeguards to protect clients’ personal information and prevent fraud. If you suspect fraudulent activity in your FCAS account(s), you should immediately contact your Advisor or call 800.443.2104. Technology and Third-Party Vendors. FCAS relies on third-party vendors and technology providers in order to provide many of its services. Additionally, some of the technology used is provided by third- party vendors and is, therefore, beyond FCAS’s direct control. FCAS seeks to ensure adequate backups of hardware, software, telecommunications, internet-based platforms, and other electronic systems, through its vendor due diligence procedures, but there is no guarantee that any or all third- party service provider risks will be mitigated. In addition, natural disasters, power interruptions and other events may cause system failures, which will require the use of backup systems. Backup systems may not operate as well as the primary systems and may fail to properly operate, especially when used for an extended period. To reduce the impact a system failure may have, FCAS evaluates its backup and disaster recovery systems and performs periodic testing of its backup systems operations. Despite FCAS’s reasonable efforts, hardware, telecommunications, or other electronic systems malfunctions may be unavoidable and result in consequences such as the inability to execute client transactions or monitor client accounts. 23  Concentration. Strategies that are concentrated in only a few securities, sectors or industries, regions or countries or asset classes could expose a portfolio to greater risk and may cause greater portfolio volatility. Other Risks Applicable to Elite Tax Overlay Strategy. A tax overlay strategy relies on various techniques, assumptions, and calculation methodologies and cannot be guaranteed to reduce or minimize a client’s overall tax liabilities, or as to the tax results that may be generated by a given transaction (or transactions). A tax-managed strategy may cause a client portfolio to hold a security in order to achieve more favorable tax treatment or to sell a security in order to create tax losses. Factors that could impact the value of tax-managed investing techniques include, but are not limited to market conditions, the tax characteristics of securities used to fund an account, client-imposed investment restrictions, client tax rate, asset allocation, investment approach, investment universe, and any tax law or firm policy changes. The pre-tax performance of a tax-managed account may be lower than the performance of similar advisory accounts portfolios not employing a tax overlay strategy. Under current IRS regulations wash sales, which occur when securities are sold at a loss and then re-purchased within 30 days, and any tax loss sought through the sale of a security may be disallowed by the IRS. Tax- managed investing does not equate to comprehensive tax advice, is limited in scope, and not designed to eliminate taxes in an account. ITEM 9 - DISCIPLINARY INFORMATION FCAS has not been subject to any material legal or disciplinary events. ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS FCAS’s and its Financial Advisors’ relationship to its Affiliated Companies create conflicts of interest and, in many cases, incentivizes your Financial Advisor to recommend an Affiliated Company’s products and/or services versus other, similar, non-affiliated providers. Additionally, many of our Financial Advisors serve in multiple capacities and may be incentivized to recommend products or services that create the greatest compensation for the Financial Advisor. FCBS is a broker-dealer. It recommends and effects securities transactions for you, including buying and selling securities that can be either held in accounts at Pershing, its clearing firm, or held in accounts directly with the issuer of the securities purchased such as mutual fund companies. FCBS is a member of the Financial Industry Regulatory Authority (“FINRA”). FCBS is authorized to conduct business in all 50 states, the District of Columbia, Puerto Rico, and Guam. It is also a member of the Securities Investor Protection Corporation (“SIPC”) and the Municipal Securities Rulemaking Board (“MSRB”). FCIS is an insurance general agency that provides insurance products and services including but not limited to life insurance, long term care insurance, disability income insurance, liability insurance, and annuities. FCB is a federally chartered savings and loan bank (member FDIC). Personal banking products and services provided by FCB include checking and savings accounts, money market accounts, certificates of deposit, automobile loans, mortgage loans, secured and unsecured personal loans, debt consolidation loans, credit and debit cards, online banking services, and trust services. Commercial 24  banking products and services offered by FCB include commercial checking accounts, money market savings accounts, commercial loans, business credit and debit cards and online banking services. Financial Advisors are affiliated with FCAS, are registered representatives affiliated with FCBS; and also are insurance agents affiliated with FCIS. Financial Advisors will also receive support fees from FCB in recognition of their efforts to promote your banking relationship with FCB. FCAS seeks to address these conflicts of interest by monitoring and enforcing a Code of Ethics, along with other compliance and supervisory policies and procedures, and through the establishment of the investment oversight committee (“IOC” or “Committee”). Furthermore, FCAS seeks to disclose material conflicts of interest to its clients and prospective through this Brochure and other documents. ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENTS’ TRANSACTIONS & PERSONAL TRADING FCFS and all of its subsidiaries, including FCAS, have adopted a rigorous Code of Ethics that sets forth the high ethical standards of business conduct required of FCFS and its subsidiaries’ employees and Financial Advisors. FCAS takes great pride in our integrity and our commitment to serving clients’ needs. The Code of Ethics sets forth the standards of conduct expected of all FCAS personnel. The Code is based on the principle that all employees and supervised persons of FCAS have a fiduciary duty to place the interests of clients ahead of their own and of FCAS. It is a means of memorializing our vision of appropriate and professional conduct in servicing our clients. Each of FCAS’s employees and representatives have been furnished with a copy of this Code and has acknowledged and accepted its terms. The Code espouses policies to safeguard your confidential information, engage in fair dealing, and avoid conflicts of interest in decision-making. We do not tolerate violations to our Code of Ethics by taking allegations of a violation to this policy seriously and holding each employee and representative responsible for maintaining the standards set by the Code of Ethics. We comply with all applicable laws and regulations that govern our business. You may review the FCFS Code of Ethics at any time. It is available on the website at https://cdn.firstcommand.com/assets/web- documents/code-of-ethics.pdf. You may also obtain a paper copy of the Code of Ethics by calling us at 800.443.2104 or writing to us at the following address: First Command Advisory Services Attn. Chief Compliance Officer 1 FirstComm Plaza Fort Worth, TX 76109-4999 FCAS, Financial Advisors, and its Affiliated Companies recommend or effect transactions in securities in which an FCAS or Affiliate director, officer, employee, or another Financial Advisor may also invest directly or indirectly. This poses a conflict of interest to the extent that transactions in such securities on behalf of FCAS clients may advantage such related persons. FCAS and its Affiliated Companies do not buy from, sell to, or otherwise enter into transactions for securities with clients or client accounts. 25  ITEM 12 - BROKERAGE PRACTICES FCAS uses its affiliate FCBS for all brokerage transactions and services. FCBS is an introducing broker- dealer. As an introducing broker-dealer, it recommends and effects securities transactions for you, including buying and selling securities that can be either held in accounts at Pershing, its clearing firm, or held in accounts directly with the issuer of the securities purchased such as mutual fund companies. Pershing is not affiliated with any First Command Affiliated Companies. Pershing or the issuer of the securities purchased, as applicable, will be responsible for maintaining policies and procedures for aggregating the purchase or sales of securities for client accounts. Aggregation will generally not have an effect on the price you pay or receive when purchasing or selling mutual funds and ETFs. Pursuant to the terms and conditions set forth in the IMA, if you select FCAS as your investment adviser to manage your cash, securities and other assets which will be custodied (or maintained) at a designated third-party custodian selected by FCAS, i.e., Pershing and managed in a FCAS Advisory Program, client understands and agrees that it must use FCBS for any brokerage-related service. Not all investment advisers require their clients to use a specific broker-dealer. Requiring clients to use a particular broker-dealer may result in being unable to achieve the most favorable execution of client transactions, which could cost clients more money. In the case of mutual funds, it is important to note that the price at which you purchase or redeem shares will depend on the fund’s NAV, which the fund may not calculate until many hours after you've placed your order. In general, mutual funds must calculate their NAV at least once every stock market trading day, typically after the major U.S. exchanges close. As such, requiring you to use a particular broker-dealer will generally not have an effect on the price you pay or receive when purchasing or selling mutual funds. There is a conflict of interest when offering investment advisory services that require our Affiliated Company to provide brokerage services for which it is compensated. FCAS maintains policies, procedures, supervision systems and other measures to help mitigate its conflict of interest. FCAS does not receive additional compensation, is not subject to quotas, and does not qualify for bonuses or awards based on the purchase or referral of proprietary products. A client’s assets under AMS will be maintained in client’s name by a qualified custodian selected by FCAS, which is Pershing. Accounts are required to be established and held through FCAS’ affiliated broker-dealer, Pershing, a non-affiliated firm, member Financial Industry Regulatory Authority (FINRA) and Securities Investor Protection Corporation (SIPC). FCBS provides brokerage, custody and execution services through its clearing arrangement with Pershing. Services provided by Pershing include, but are not limited to: (i) maintaining custody of client’s assets; (ii) trading client’s assets; (iii) providing client with monthly or quarterly account statements, (iv) providing client with certain tax reporting documents, (v) delivering prospectuses, proxy materials and other similar documents, (vi) managing credit interest and dividend payments in the account, (vii) crediting principal on called or matured securities in the account, and (viii) other custodial functions. FCAS’s and FCBS’s affiliation creates conflicts of interest and, in many cases, incentivizes FCAS and its Financial Advisors to recommend an affiliate’s products and/or services versus other, similar, non- affiliated providers. Additionally, many of FCAS’s Financial Advisors serve in multiple capacities and may be incentivized to recommend products or services that create the greatest compensation for the Financial Advisor. For additional information about FCBS’s order execution and routing practices, contact the First Command Home Office using the information on the cover page of this brochure. 26  FCAS selected FCBS primarily due to its Affiliated Company status and FCBS’s relationship with Pershing. As part of this relationship, FCAS, through its affiliation with FCBS, receives substantial economic and non-economic benefits from Pershing, including but not limited to accessibility to dedicated service personnel, electronic and institutional trading, third party research and technology, technical and operational support, advisory fee processing, and electronic communications and reporting to clients. FCBS receives substantial financial incentives and access to other products, services, and fee reductions from Pershing as part of its overall relationship with Pershing; however, some of these benefits may be based on the amount of brokerage and advisory assets held by Pershing. For example, FCBS receives quarterly financial incentives from Pershing based on the number of funded brokerage and advisory accounts custodied at Pershing and the total assets under management from these accounts. Further, FCBS receives additional financial incentives from Pershing for FCBS reaching specific threshold targets for moving and consolidating assets in client accounts custodied by Pershing. FCAS’s and FCBS’s affiliation creates a conflict of interest and, in many cases, incentivizes FCAS and its Advisors to recommend FCBS and Pershing brokerage products and clearing services versus other, similar, non-affiliated providers. Further, First Command Financial Advisors serve in multiple capacities and may be incentivized to recommend products or services that create the greatest compensation for the Financial Advisor. As further detailed in this Brochure, as part of FCBS’s overall relationship with Pershing, FCAS receives research and other products or services (other than custody of securities, trade execution, clearance and settlement of transactions) from Pershing. Some of these benefits may be based on the amount of advisory assets held by the custodian. Additionally, FCBS receives asset-based pricing on custodial charges in lieu of ticket or transactional charges. The receipt of these benefits creates a conflict of interest because FCAS has an incentive to base advice in part on the benefit to FCAS and not solely on the nature, cost or quality of custody or brokerage services provided by FCBS and Pershing. In addition to disclosing these conflicts of interest, FCAS has created and implemented a compliance and supervisory program to mitigate such conflicts through the oversight of client accounts and investment advisory activities. FCBS and Pershing have negotiated a long-term contractual arrangement that provides FCBS substantial financial incentives and access to other products, services, and fee reductions from Pershing as part of its overall relationship with Pershing. The contract FCBS has with Pershing spells out the costs and commitments as well as the fees FCBS receives from Pershing for certain activities. As part of their negotiated contract, if FCBS chooses to leave Pershing before the contract expires and move to another custodian, FCBS is required to pay a substantial sum of money back to Pershing (which reduces over time), as well as a per-account fee for certain retirement accounts that transfer away from Pershing. The terms of this negotiated contract, including the payments disclosed herein, incentivize FCBS to remain with Pershing. FCBS’s selection of Pershing was not based solely on these payments but instead was based on intensive search and due diligence of other possible custodians that FCBS felt met the requirements and needs of FCBS and its customers. Nevertheless, these financial and other incentives create conflicts of interest. The compensation and incentives FCBS receives through Pershing are not directly shared with our IMT, WPM, or Financial Advisors. The various types of compensation and incentives FCBS receives from Pershing are described below: Quarterly financial incentives. FCBS receives quarterly financial incentives from Pershing based on the number of funded brokerage and advisory accounts custodied at Pershing and the total assets under management from these accounts. Further, FCBS receives additional financial incentives from Pershing for FCBS reaching specific threshold targets for moving and consolidating assets in client 27  accounts custodied by Pershing. Additionally, FCBS receives asset-based pricing on custodial charges in lieu of ticket or transactional charges. Account Credits. Pershing financially compensates FCBS based on the number of accounts and their average account size on the Pershing platform. This creates a conflict of interest because Pershing provides a substantial financial incentive to FCBS to consolidate assets onto the Pershing platform in order for FCBS to receive additional monetary compensation from Pershing. Asset Credits. Pershing paid FCBS a one-time, substantial asset consolidation support payment upon long-term renewal of Pershing custodial services to FCBS. FCBS is also able to receive additional asset consolidation support payments on an ongoing basis upon receiving certain conversion thresholds. Further, Pershing provides monetary compensation to FCBS for net new assets introduced to the Pershing platform each quarter. Eligible accounts for transfer include Direct to Fund accounts and IRA accounts held directly with a mutual fund sponsor. On an aggregate basis, the amount of the credits amount to significant amounts of money considering the number of accounts that can transfer to Pershing. This creates a conflict of interest as the transfer credit may be more than FCBS and FCAS’ costs and expenses. In most cases. clients will also incur additional costs by transferring their accounts held directly with a mutual fund sponsor to Pershing. These costs will likely exceed a client’s direct mutual fund costs and will benefit FCAS or its affiliates. Although, the transfer credit is not shared with clients or Advisors, it is a material conflict of interest when an account held directly with a mutual fund sponsor transfers to Pershing. This also concerns circumstances where a direct retirement plan is transferred to an individual retirement account held through Pershing. FCBS, at its sole discretion, adds a markup to various brokerage and custodial fees that are paid by clients. The markup generates additional revenue for FCBS. The actual fees and charges that clients will incur are dependent upon the type of account, the nature of the transaction, the quantity of the transaction, the services provided, or the positions held in the account. Not all brokerage firms mark up these or other fees. FCAS is obligated to seek best execution for all trades, regardless of program; however, 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 services. While FCAS reviews the accuracy, timeliness and execution of trades processed through Pershing, FCAS cannot guarantee that a client will receive the most favorable execution of trades, which in turn may cost clients more money. Periodically, FCAS reviews the custodial services provided by other qualified custodians in comparison to those provided by FCBS and Pershing. Please refer to FCBS’s Regulation Best Interest Disclosure (also known as the “Reg BI”) for more information regarding FCBS’s practices and conflicts of interest. For more information or to request a copy of the Regulation Best Interest Disclosure, contact your Financial Advisor. ITEM 13 - REVIEW OF ACCOUNTS If you are a client in one of our Advisory Programs, FCAS will manage and periodically rebalance your account’s assets consistent with the asset allocation for your chosen model portfolio (for Foundations and Select) or in accordance with your investment strategy developed by your WPM in your Elite account. For Premier Income, the third-party investment manager will rebalance your separately managed account in accordance with the single fixed income model chosen. We recommend that all clients meet with their Financial Advisor (and/or WPM as applicable) at least once per year to review their account(s). During reviews, your personal financial information will be updated. You may require more frequent reviews depending on your particular situation or if a periodic 28  review raises questions about your portfolio. A revised recommendation will be made, if appropriate. You are responsible for updating their profile to ensure all information supplied by Client is up-to-date and complete. Account statements will be provided to you in writing or electronically on at least a quarterly basis by Pershing. These statements will contain balances as well as transaction history for your account during the indicated period. You should review your account statements and confirmations closely to ensure there are no unauthorized transactions in your account. You should notify us in writing within 30 days of receipt of your account statement or confirmation if you have any questions or concerns regarding the information contained therein. Note: It is your responsibility to promptly notify your Financial Advisor or FCAS of any changes to your profile (i.e. investment objective, risk tolerance, investable time horizon, financial situation, liquidity considerations, contact information, etc.). ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION FCAS does not receive any additional compensation for our advisory services other than as described in this ADV Part 2A and the Wrap Fee Brochure, as applicable. We also do not pay fees to other parties for client referrals. ITEM 15 - CUSTODY As noted above, Pershing serves as the custodian of advisory clients’ funds and securities and clears and settles all trades for the Advisory Program. Accordingly, FCAS does not have physical custody of your assets. However, pursuant to a triparty agreement with Pershing, FCBS and FCB perform certain functions to administer the account with respect to which FCAS provides investment advisory services, as described above in Section I. Brokerage Practices. Further, FCAS has the authority to deduct, or instruct the custodian to deduct, advisory fees directly from client accounts. FCAS is therefore considered to have legal custody of your funds or securities because of this authority and because it is an Affiliated Company of FCBS and FCB. For example, if you maintain an advisory account with FCAS, you may authorize FCBS to perform certain Automated Clearing House (ACH) functions such as direct deposits, distributions, and asset movements which FCBS personnel will facilitate on your behalf through Pershing’s systems. In addition, FCB provides limited, tax-related reporting services for individual retirement accounts. FCBS is only permitted to have physical possession of your funds or securities for a very limited time period; Pershing, in its role as a full-service broker-dealer, is responsible for maintaining your funds and securities upon receipt from FCBS, FCB, and other third parties. Pershing will send you statements on at least a quarterly basis. In addition, FCAS will provide clients with quarterly performance monitoring reports for clients’ accounts which may be accessed electronically through FCAS’s Client Portal (i.e., “Command Center”). Clients will receive all documents electronically unless you opt-in to receive paper documents. Importantly, clients will incur fees and costs for electing to receive paper statement via regular mail. You should carefully review all statements received, ensure that they are accurate, and notify us immediately if there are any discrepancies. ITEM 16 - INVESTMENT DISCRETION To participate in an Advisory Program, you must grant us full discretionary authority to manage your invested assets by agreeing to our IMA at account opening. We cannot accept any non-discretionary or 29  consult-type arrangements. Neither you nor FCAS may transact in your selected Advisory Program account other than as described in the IMA. The IMA allows you to impose certain restrictions. These restrictions must be requested in writing and are as follows: • You may direct at any time that you wish to terminate the rebalancing of your account assets. This can be effective up to thirty (30) days. • You may direct that the payment of lump sum withdrawals be from assets other than the cash equivalent position within your account (If you select this restriction, you should also consider suspending rebalancing of your account assets to avoid possible unintended tax consequences.) • You may direct that the payment of a specific lump sum withdrawal be made from a particular investment in the account assets rather than from the cash equivalent position within your account. (If you select this restriction, you should also consider suspending rebalancing of your account assets to avoid possible unintended tax consequences.) • For Foundations and Select Only: You may direct that a particular sum be held in a cash equivalent position for a specified period of time that may not exceed 90 days. You should consult with your Financial Advisor prior to requesting these restrictions. Other than by choosing your risk profile and Model Portfolio, if applicable, and as described in the IMA, you may not place other restrictions on the management of your account, including imposing restrictions on investing in certain securities or types of securities. Notwithstanding the above, if you are enrolled in the Elite program, you may work with your Financial Advisor and WPM to customize your portfolio, within certain constraints as described further below, to adjust the allocation to stocks, bonds, and cash. In addition, you may elect to use overlay management at an additional cost to exclude a stock or group of stocks from your investment portfolio. Asset Management Solutions Advisory Programs exclusively provides discretionary investment management services to manage the assets in your account(s). Granting discretionary authority means you authorize FCAS to make the investment decisions on your behalf to buy, sell or trade investments, select investment products, engage or terminate Investment Managers, perform portfolio re-balancing, and determine portfolio asset allocations as described further in this Brochure. Our discretionary authority is limited to managing your assets and does not enable FCAS or the Investment Managers to make any deposits or withdrawals of assets for your account, unless expressly authorized by you. ITEM 17 - VOTING CLIENT SECURITIES FCAS maintains a Proxy Voting Policy which reflects our duty as a fiduciary to vote proxies in your best interest under the Advisory Programs. FCAS currently subscribes to advisory and other proxy voting services provided by an independent proxy voting service provider, Glass, Lewis & Co. (“Glass Lewis”). FCAS has delegated proxy voting for Advisory Program clients to Glass Lewis. FCAS has addressed conflict of interest issues by hiring Glass Lewis to vote proxies on its behalf. Glass Lewis then votes proxies in accordance with its Corporate Governance Focused Thematic Policy Guidelines, which can be found at https://www.glasslewis.com/wp- content/uploads/2023/11/2024-US-Benchmark-Policy-Guidelines-Glass-Lewis.pdf/. In the event of a material conflict of interest that is not otherwise addressed through our Proxy Voting Policy and relationship with Glass Lewis, we will notify you. 30  We maintain relevant and appropriate proxy records in accordance with our Proxy Voting Policy. If you would like to receive a copy of our Proxy Voting Policy or specific voting records for proxies related to your holdings, please write to: First Command Advisory Services Chief Investment Officer Attn: Proxy Voting Policy 1 FirstComm Plaza Fort Worth, TX 76109-4999 A client may direct a vote in a particular solicitation by writing to the above address. FCAS will then work with you in accordance with our Proxy Voting Policy. ITEM 18 - FINANCIAL INFORMATION FCAS is financially able to meet all of its obligations. We have not been the subject of a bankruptcy petition and do not anticipate any issues that would limit our ability to meet our contractual obligations to our clients or business partners. 31  First Command Advisory Services, Inc. 1 FirstComm Plaza, Fort Worth, Texas 76109-4999 1-800-443-2104 • Overseas, Call 817-731-8621 www.firstcommand.com clientservices@firstcommand.com 10225 

WRAP FEE PROGRAM BROCHURE FORM ADV PART 2A, APPENDIX 1 BROCHURE First Command Advisory Services, Inc. 1 FirstComm Plaza, Fort Worth, Texas 76109-4999 1-800-443-2104Overseas, Call 817-731-8621www.firstcommand.comclientservices@firstcommand.comThis Wrap Fee Program Brochure is dated October 15, 2025. This Wrap Fee Program Brochure provides information about the qualifications and business practices of First Command Advisory Services, Inc. If you have any questions about the contents of this brochure, please contact us at 800.443.2104 (or, if overseas, 817.731.8621). 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 First Command Advisory Services, Inc. is also available on the SEC’s website at www.adviserinfo.sec.gov. First Command Advisory Services, Inc. is an SEC-registered investment adviser. Registration as an investment adviser with the SEC does not imply a certain level of skill or training.  ITEM 2 - SUMMARY OF MATERIAL CHANGES TO THE WRAP FEE PROGRAM BROCHURE 1. Throughout Brochure. This Brochure announces the addition of two new wrap fee advisory programs introduced under the Asset Management Solutions Advisory Program umbrella: First Command Premier Income and First Command Elite. These new advisory programs provide clients with a broader selection of investment strategies pursuant to which clients’ assets are managed. Throughout this Brochure, there are updates to the descriptions of these new Advisory Programs, including their Advisory Fees and account minimums. 2. Item 6. Our third-party voting proxy, Glass Lewis, updated its policy guidelines on how it votes proxies. We have updated the link to their Corporate Governance Focused Thematic Policy Guidelines. 3. Item 9. First Command Brokerage Services, Inc. (“FCBS”) has renegotiated a contract with Pershing, LLC, the custodian and clearing firm for advisory program accounts. The contract includes terms favorable to FCBS. These updates also include details about certain incentives that impact FCAS’s conflicts of interest. These updates include waiver of all transaction fees on the Pershing platform and substantial financial incentives for FCBS to keep accounts with Pershing and move additional accounts to the Pershing platform. 4. Item 9. The Custody section has been updated to align with SEC guidance, to clarify that FCAS and its Affiliated Companies, First Command Bank (“FCB”) and FCBS, have legal custody over clients’ accounts. 5. Throughout Brochure. As part of ongoing program improvements, several program name changes have been made. Asset Management Solutions now refers to the overall suite of FCAS’s advisory programs, and each program under the Asset Management Solutions has received a new name to reflect updated branding and organizational structure. For example, FIP is now known as “First Command Foundations,” and SIP is renamed to “First Command Select.” These changes are administrative in nature and do not affect the underlying investment process or the client experience. 6. Additional editorial and non-material changes were also made throughout the brochure. These are the material changes since the last annual update of this Brochure from August 26, 2024. You may request a current copy of this Wrap Fee Program Brochure at any time by contacting your Financial Advisor, calling FCAS’s Home Office at 800.443.2104 (overseas, call 817.731.8621) or visiting www.firstcommand.com. 1  ITEM 3 - TABLE OF CONTENTS ITEM 2 - SUMMARY OF MATERIAL CHANGES TO THE WRAP FEE PROGRAM BROCHURE ....... 1 ITEM 3 - TABLE OF CONTENTS .......................................................................................................... 2 ITEM 4 - SERVICES, FEES AND COMPENSATION ............................................................................ 3 ITEM 5 - ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ................................................... 18 ITEM 6 - PORTFOLIO MANAGER SELECTION AND EVALUATION ................................................ 19 ITEM 7 - CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS .................................. 25 ITEM 8 - CLIENT CONTACT WITH PORTFOLIO MANAGERS ......................................................... 25 ITEM 9 - ADDITIONAL INFORMATION .............................................................................................. 25 2  FORM ADV PART 2A, APPENDIX 1 “WRAP FEE PROGRAM BROCHURE” ITEM 4 - SERVICES, FEES AND COMPENSATION INTRODUCTION First Command Advisory Services, Inc. (“FCAS”, “we”, “us” or “our”) and its affiliated entities have been serving American families since 1958. FCAS is registered as an investment adviser with the U.S. Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended (“Advisers Act”). Registration as an investment adviser with the SEC does not imply a certain level of skill or training. FCAS will work with both third parties (hereinafter, “Non-Affiliated Companies”) and FCAS’s affiliated companies (each, an “Affiliated Company”) to provide the services for each Advisory Program. FCAS and the Affiliated Companies are wholly owned subsidiaries of First Command Financial Services, Inc. (“FCFS”). FCFS is 100 percent owned by the First Command Employee Stock Ownership Plan. The applicable FCAS Affiliated Companies include: • First Command Brokerage Services, Inc. (“FCBS”), an SEC registered broker-dealer (member SIPC, FINRA); • First Command Insurance Services, Inc. (“FCIS”), an insurance general agent; and • First Command Bank (“FCB”), a federally chartered savings and loan bank (member FDIC). All references to “client”, “you” and/or “your” in this brochure refer to prospective and existing clients of FCAS. References to “we,” “us” or “our” refer to FCAS and/or its investment adviser representatives (hereinafter, “First Command Financial Advisor” or “Financial Advisor”). As of September 30, 2025, First Command Advisory Services, Inc. manages $24.3 billion on a discretionary basis. OVERVIEW OF THE ASSET MANAGEMENT SOLUTIONS ADVISORY PROGRAMS FCAS is the sponsor and investment adviser of Asset Management Solutions Advisory Programs, which consists of several advisory programs listed below (each a “Program” or “Advisory Program” and collectively the “Advisory Programs”). Through the Advisory Programs, you can access a wide variety of investment strategies. Some of the Advisory Programs allow for the inclusion of mutual funds, exchange-traded funds (ETFs), selections of third-party managed investment portfolios through third- party managed accounts, stocks, bonds, and alternative/complex products. Our services are provided to you through First Command Financial Advisors as described in this Brochure. As a “wrap fee program,” your selected Advisory Program provides investment advisory services, brokerage, and non- IRA custody services for a single, inclusive fee (i.e., wrap fee). The specific Advisory Program you select may cost you more or less than purchasing such services separately. Factors that bear upon the cost of a particular Advisory Program in relation to the cost of the same services purchased separately include, but are not limited to, the type and size of the account and the number and range of supplementary advisory and client-related services provided to the account. We are the sponsor and investment adviser for the Advisory Programs as described in this Brochure. Your Financial Advisor will work with you to gather information about your financial situation, goals, and objectives, including information on your investment time horizon (this is the length of time before you 3  intend to draw down or liquidate your investments), risk tolerance (certain investments are riskier than others), and other relevant factors. Based on this information, your Financial Advisor (and Wealth Portfolio Manager, depending on the Advisory Program) will then propose an overall investment strategy that includes asset allocation and investment portfolio recommendations with your account to be managed in one or more Advisory Programs in accordance with the customized investment strategy as further detailed in this Brochure. Should your risk profile change, it is your responsibility to contact your Financial Advisor to update your risk profile and decide whether you wish to make a change to your investment strategy. Your Financial Advisor (or Wealth Portfolio Manager, as applicable) will periodically meet with you to discuss any changes to your financial situation, goals, and objectives to ensure that the investment strategy continues to meet your investment needs. To enroll in an Advisory Program, you will be required to complete our new account paperwork establishing an account and agree to our Investment Management Agreement (“IMA”), which contains additional terms and conditions governing your account and your relationship with us. If you are moving your account from one Advisory Program to another, you may be required to complete paperwork indicating your election, which may include signing the most current IMA. This Brochure provides you with a general overview of our responsibilities to you and conflicts of interest as it applies to the Advisory Programs. You can obtain more specific information about the investment strategies, how investment strategies are carried out, options to customize your investments, the Investment Management Team (“IMT”), the role of Wealth Portfolio Manager (“WPM”), investment returns, and other information through discussion with your Financial Advisor. We encourage you to review this Brochure carefully and to talk to your Financial Advisor to make certain you fully understand our investment process and the features available to you as a participant in one or more of the Advisory Programs. Additional information about each Advisory Program, including the types of portfolio management services, wrap fee charges, discretionary authorities, and additional program costs, are provided below. For a more detailed description of each Program, contact your Financial Advisor. Asset Management Solutions Advisory Programs First Command Foundations First Command Foundations Advisory Program (“Foundations”) enables FCAS’s IMT to provide you with investment portfolio options (“Model Portfolios”) composed of ETFs subject to certain limitations discussed below. The IMT determines which ETFs to include in the Model Portfolios offered to Foundations clients and it will periodically adjust and rebalance Model Portfolio investments to remain consistent with each Model Portfolio’s investment strategies. FCAS does not monitor Foundations accounts on an individual basis, and it does not monitor any other types of non-advisory accounts, including, but not limited to, brokerage accounts. Each Model Portfolio in Foundations is designed to align with a client’s particular risk profile, which is used by the IMT to set the initial asset allocation. This practice attempts to limit risk to clients by investing among a range of different ETF asset classes in Model Portfolios. Any modifications the IMT makes to the Model Portfolios are effected through the sale or purchase of securities in your account, which may have tax ramifications for you. The Model Portfolios utilized in Foundations consist exclusively of passively managed ETFs and are optimized using only stocks, bonds, and cash to provide a more streamlined, core model focused on minimizing internal expenses and slightly improved tax efficiency. The IMT is responsible for managing your Foundations account in accordance with the Model Portfolio(s) recommended to you by your Financial Advisor. IMT management provides due diligence and oversight, including ongoing account 4  monitoring and rebalancing. You remain the owner of all securities held in your account and have all ownership rights associated with these securities. Model Portfolios may be added or discontinued over time in FCAS’s discretion. First Command Select First Command Select Advisory Program (“Select”) enables the IMT to provide you with Model Portfolios composed of active or passive mutual funds and ETFs, subject to certain limitations discussed below. The IMT determines which mutual funds and/or ETFs to include in the Model Portfolios available to Select clients and it will periodically adjust and rebalance Model Portfolio investments to remain consistent with each Model Portfolio’s investment strategies. FCAS does not monitor Select accounts on an individual basis, and it does not monitor any other types of non-advisory accounts, including, but not limited to, brokerage accounts. Each Model Portfolio in Select is designed to align with a client’s particular risk profile, which is used by the IMT to set the initial asset allocation. This practice attempts to limit risk to clients by investing among a range of different mutual fund and ETF asset classes in Model Portfolios. Any modifications the IMT makes to the Model Portfolios are effected through the sale or purchase of securities in your account, which may have tax ramifications for you. For some Model Portfolios in Select, municipal bond fund options are available. While both Foundations and Select accounts receive the same level of IMT due diligence and oversight, including ongoing account monitoring and rebalancing, Select’s Model Portfolios invest in a combination of both passively and actively managed ETFs and mutual funds in order to provide exposure to broader diversification of stocks, bonds, and cash plus the inclusion of real assets (real estate, natural resources, etc.). This broader asset class scope also allows the IMT to optimize the Model Portfolio(s) with regards to various sector and factor exposures and increase the IMT’s capacity to make tactical adjustments to the applicable Model Portfolio when the IMT deems prudent. Model Portfolios may be added or discontinued over time in FCAS’s discretion. First Command Premier Income The First Command Premier Income Advisory Program (“Premier Income”) is an investment advisory program that manages client’s assets in accordance with a single fixed income model in a separately managed account (“SMA”). The fixed income investment style represented in the model is managed by an investment manager from a third-party investment advisor who specializes in fixed income strategies. These investment advisers and their strategies are selected for inclusion in the Premier Income Advisory Program by the IMT. Clients enrolled in this Program have their account assets invested in individual securities (e.g., bonds). Your Financial Advisor will engage with a WPM, who will recommend and direct the allocation of assets in your Premier Income account to a third-party investment advisor’s fixed income model in a manner consistent with your investment objectives. Some fixed income models allow for client-specific preferences to be submitted by the WPM (e.g., state specific municipal bond purchases). The wrap fee FCAS charges for Premier Income does not include the third-party investment adviser’s management fee or Envestnet’s portfolio administrative fee, if applicable, which is passed through to the client. These third-party fees vary from one third party investment adviser to another. Speak to your Financial Advisor for more information about the options available to you. 5  First Command Elite The First Command Elite Advisory Program (“Elite”) is an investment advisory program known as a unified managed account (or UMA). Clients’ assets are invested in, or via, different types of investment vehicles, such as ETFs, mutual funds, third-party managed portfolios, IMT Model Portfolios, and individual stocks and bonds, within a single, unified account. Elite clients are assigned to a FCAS WPM who works directly with the client, the client’s Financial Advisor, and third-party investment managers (as applicable) to manage the client’s assets across multiple “sleeves” (some of which are securities and some of which are portfolios managed by investment advisers) available within the UMA. The availability of “sleeves” within the UMA allows multiple investment managers, who may or may not be affiliated with FCAS, to each manage a portion of the account’s assets on a discretionary basis. Envestnet provides portfolio analysis, investment manager due diligence for some investments, ongoing monitoring, and centralized trading capabilities for your Elite account. In addition, some third-party investment managers have entered into an agreement with Envestnet under which they provide, manage, and maintain portfolio models that are implemented by Envestnet within your Elite account on a discretionary basis. Third-party investment managers have additional management fees that are not included in the Elite Wrap Fee; accordingly, if a client has assets allocated to a sleeve within Elite that is managed by a third-party investment manager, the fees charged to the client will include the third-party investment manager’s fees in addition to the wrap fee charged by FCAS for an Elite account. Your WPM makes recommendations for the allocation of assets in your Elite account in a manner consistent with your investment objectives. The WPM directs the implementation of these recommendations and will direct the selection and termination of investment manager(s) at the account level on a discretionary basis. Clients with Elite accounts can choose overlay services, provided by Envestnet, for an additional cost that is passed through to the client. There are two types of overlay services Envestnet provides. The first overlay service is a tax overlay. Tax overlay is intended to integrate tax considerations into portfolio management and provide continuous services such as tax-loss harvesting, tax-efficient rebalancing, and year-round tax management to maximize a client’s after-tax returns. The methodologies and assumptions used by FCAS or its Financial Advisors may not be appropriate in all client situations. Clients can also choose the values overlay. Values overlay allows clients to align their investment strategy with their personal beliefs, ethics, or social values. The values overlay is a very qualitative process. The values overlay provides a snapshot of what a client’s account would look like without the selected values restriction. Then, it would try to replicate the performance of the account had those constraints not been in place by selecting alternative securities that are expected to perform similarly to like accounts that do not have such value-based constraints. Clients with Elite accounts can also request the WPM to avoid a certain security or group of securities. There is no additional cost to the client for this level of customization. However, unlike the values overlay described above, if an Elite client requests to avoid a certain security or group of securities without choosing the values overlay, there is no provided optimization services associated with the avoidance of certain securities or groups of securities. Further, FCAS does not separately provide optimization services to an Elite account when the client has requested avoidance of a certain security or group of securities without electing to utilize a values overlay. Discretion and Restrictions To participate in an Advisory Program, you must grant us full discretionary authority to manage your invested assets by agreeing to our IMA at account opening. We cannot accept any non-discretionary or consult-type arrangements. Neither you nor FCAS may transact in your selected Advisory Program 6  account other than as described in the IMA. The IMA allows you to impose certain restrictions. These restrictions must be requested in writing and are as follows: • You may direct at any time that you wish to terminate the rebalancing of your account assets. This can be effective up to thirty (30) days. • You may direct that the payment of lump sum withdrawals be from assets other than the cash equivalent position within your account (If you select this restriction, you should also consider suspending rebalancing of your account assets to avoid possible unintended tax consequences.) • You may direct that the payment of a specific lump sum withdrawal be made from a particular investment in the account assets rather than from the cash equivalent position within your account. (If you select this restriction, you should also consider suspending rebalancing of your account assets to avoid possible unintended tax consequences.) • For Foundations and Select Only: You may direct that a particular sum be held in a cash equivalent position for a specified period of time that may not exceed 90 days. You should consult with your Financial Advisor prior to requesting these restrictions. Other than by choosing your risk profile and Model Portfolio, if applicable, and as described in the IMA, you may not place other restrictions on the management of your account, including imposing restrictions on investing in certain securities or types of securities. Notwithstanding the above, if you are enrolled in the Elite program, you may work with your Financial Advisor and WPM to customize your portfolio, within certain constraints as described further below, to adjust the allocation to stocks, bonds, and cash. In addition, you may elect to use overlay management at an additional cost to exclude a stock or group of stocks from your investment portfolio. Services Provided The following services are included as part of all Asset Management Solutions Advisory Programs: • Asset management; • Account statements that will include all investment positions, market values and transactions; • Annual tax reports for use in preparing federal and state tax returns; • Online quarterly portfolio performance reports; • Quarterly economic and market summaries; and • One-time or periodic third-party distributions upon your written request. A signature guarantee may be required. FEES AND COMPENSATION The following fees and compensation are applicable to all Asset Management Solutions Advisory Programs: Wrap Fees A wrap fee program generally involves an investment account where you are charged a single, bundled, or “wrap” fee for investment advice, brokerage services, administrative expenses, and other fees and expenses. FCAS charges you a wrap fee for the day-to-day asset management, costs for execution of securities transactions, and oversight of your Advisory Program account(s). The wrap fee for one of the Asset Management Solutions Advisory Programs is also referred to as an Advisory Fee. The Advisory Fee is based on a percentage of the value of your account, rather than upon transactions in your account. 7  Advisory Fees are assessed monthly in advance based on the previous month’s ending balance of assets under management in your account. Advisory Fees will be deducted from your account assets when due. The Advisory Fees are provided below for each program. Foundations Wrap Fee Schedule Select Wrap Fee Schedule Value of Account Assets Annual Management Fee Value of Account Assets Annual Management Fee $0 - $250,000 1.30% $0 - $250,000 1.30% $250,001 - $500,000 1.15% $250,001 - $500,000 1.15% $500,001 - $1 million 1.00% $500,001 - $1 million 1.00% $1 million - $2 million 0.75% $1 million - $2 million 0.75% over $2 million 0.50% over $2 million 0.50% Premier Income Wrap Fee Schedule Value of Account Assets Annual Management Fee Over $500,000 0.50%* *First Command fee only. Third-party investment manager fees and platform fees apply. Elite Wrap Fee Schedule Elite Transitional Wrap Fee Schedule** Value of Account Assets Annual Management Fee Value of Account Assets Annual Management Fee 0-$500,000 1.30% 0 - $500,000 1.30% $500,001 - $1 million 1.20% $500,001 - $1 million 1.10% $1 million - $2 million 1.10% $1 million - $2 million 0.95% $2 million - $3 million 1.00% $2 million - $3 million 0.85% $3 million - $5 million 0.90% $3 million - $5 million 0.70% over $5 million 0.60%* over $5 million 0.50% * Elite clients with this balance may negotiate their annual management fee. **This Fee is only available to FCB Investment Management Account clients who transition to Elite before September 30, 2026. This fee is temporary and covers the first twelve (12) months of an FCB Investment Managed Account client’s transfer to an Elite account (transition period). Fees revert to the regular Elite Wrap Fee Schedule after the transition period. 8  We will aggregate assets you have in Foundations, Select, and Elite Advisory Program accounts for purposes of qualifying for a lower Advisory Fee. Assets may be aggregated regardless of whether you participate only in Foundations, only in Select, only in Elite, or any combination of these three Programs. If you participate in any combination of Foundations, Select, and Elite, the Advisory Fee will be calculated using a blended fee structure. We will: (1) first calculate the Advisory Fee that would result if all assets were held in each Program; (2) determine the percentage of assets held in each Program relative to total qualifying assets within the Program; and (3) apply the percentage realized for each Program in step ‘(2)’ to the Advisory Fee determined for that Program in step ‘(1)’ to arrive at the total blended Advisory Fee. Assets in Premier Income will not be aggregated with assets in any other Asset Management Solutions Advisory Programs for purposes of lowering the fee schedule. The Premier Income Advisory Fee is composed of: the annual advisory fee charged by FCAS and the management fee charged by the particular third-party investment manager your WPM selected, which includes the management fee charged by the third-party investment manager and the Envestnet portfolio administrative fee (also known as Envestnet’s “gateway fee”). Your Financial Advisor will provide you with the third-party investment manager selected for your account and their fees. Envestnet’s portfolio administration fee only applies to third-party investment managers; it is not applied to First Command proprietary portfolio models. The third-party investment manager is responsible for ensuring you are provided with their firm’s fee brochure and disclosures. Additionally, the annual Advisory Fee for the Asset Management Solution Advisory Programs is not negotiable, except for clients who contribute more than $5 million with respect to an Elite account. We reserve the right, in our sole discretion, to discount advisory fees for clients. In the event any deposits and withdrawals (netted) equal or exceed $10,000 (in market value on an absolute basis) on any business day in an account, an interim, prorated Advisory Fee will be charged or refunded (as applicable) to the account. This is commonly referred to as flow or interim billing and is only applicable on an account-by-account basis (not aggregated with other related accounts). Each interim prorated Advisory Fee is assessed within 2-5 business days of the receipt/payment of the deposits/withdrawals (netted) and is based on the number of days remaining in the current billing period. FCAS advisory services may be terminated via notice at any time by either the client or FCAS and, following the receipt of a notice of termination, the client will be issued a prorated refund of paid Advisory Fees, based upon the number of days from the termination date through the end of the then- current fee period. A refund, if any, is paid 2-5 business days after the termination date. OTHER FEES, EXPENSES AND COSTS OUTSIDE THE ADVISORY FEE Fees for Certain Requested Services and Specific Account Actions All securities and brokerage transactions in Asset Management Solutions Advisory Programs are effected by FCBS as an introducing broker-dealer. As described above, you will not pay a separate fee for transaction costs or expenses incurred in your account (i.e., commissions, ticket charges, etc.), but you will pay additional fees as detailed below. FCBS incurs certain fees pursuant to its clearing relationship with Pershing LLC (“Pershing”) related to processing requested services and facilitating specific administrative actions for your account. Pershing is the firm that is responsible for custodianship of assets and clearance and settlement of all trades within Asset Management Solutions Advisory Programs. These fees are passed along to you after being 9  adjusted to include FCBS’s compensation for assisting with the service or action. FCBS execution costs and additional services requests will incur additional fees pursuant to the FCBS Fee Schedule. If you have not received a copy of the FCBS Fee Schedule, contact your Financial Advisor or FCAS at the contact information provided on the cover page of this Brochure. FCBS, at its discretion, marks up the various fees detailed in the FCBS Fee Schedule that are assessed by Pershing and paid by clients. FCBS decides how much and which fees will be marked up. Not all brokerage firms mark up these or other fees. The mark-up on these fees generates additional revenue for FCBS. Markups on these types of fees are a conflict of interest because FCBS earns additional revenue from these fees. Certain fees, for example, are avoidable if clients elect e-Delivery of certain account-related documents. The actual fees and charges that clients will incur are dependent upon the type of account and the nature and quantity of the transactions that occur, the services provided, or the positions held in the account. FCBS shares its IRA Custodial fees with FCB and Pershing in consideration for the services provided by these entities to support FCB as the IRA custodian and Pershing’s clearing role and tax reporting to the Internal Revenue Service. This conflict of interest is mitigated as neither FCAS or your Financial Advisor receives any portion of the IRA custodial fees. Overlay Services. Specific to Elite accounts, FCAS will pass through the cost of overlay features and any fees charged by third-party investment managers directly to your account. Such fees are not marked up by FCAS or its Affiliated Companies and neither FCAS nor your Financial Advisor receive any portion of these fees. INDIRECT COSTS OF MUTUAL FUNDS AND EFTS Mutual Fund Related Costs. FCAS will not receive any compensation from a mutual fund company related to the purchase and holding of mutual funds in the selected Advisory Program. However, you should be aware of the following fees, costs, expenses, and cost reimbursements, and their impact on your investment rate of return: Internal Expenses of the Mutual Funds. Assets invested by FCAS in mutual funds under the Advisory Programs will be subject to the internal expenses of the underlying mutual funds. These expenses are assessed by the mutual fund companies and disclosed in fund prospectuses and other offering documents. You may request copies of fund prospectuses and other offering documents from FCAS or your Financial Advisor, or by visiting the fund’s website at any time at no cost. These expenses generally include, but are not limited to, fund operating expenses, management fees, service fees, and/or redemption fees (including short-term trading redemption fees). The internal expenses of the underlying mutual funds will typically range from 0.3% to 1.5% of your assets annually and are in addition to the Advisory Fee and other fees discussed above. The internal expenses of the underlying mutual funds have a negative impact on your investment rate of return. Sales Charges and 12b-1 Fees. 12b-1 fees are named after the SEC rule that allows funds to pay marketing expenses out of the fund's assets. 12b-1 fees are separate from a fund's management fee, which covers operating costs. The 12b-1 fee is considered an operational expense and, as such, is included in a fund's expense ratio. It is generally between 0.25% and 0.75% (the maximum allowed) of a fund's net assets. The assets selected by FCAS under the Advisor Programs do not incur sales charges or 12b-1 fees. Institutional class shares will be used in Model Portfolios and client accounts whenever available. Mutual fund assets that are transferred in kind into the applicable Advisory Program may have a 12b-1 fee. These funds are generally sold within a few business days, and the proceeds are invested in the chosen, applicable Asset Management Solutions Advisory Program 10  strategy securities, none of which contain 12b-1 fees. There are occasions when FCAS receives de minimus residual 12b-1 fees associated with the assets transferred in kind into Asset Management Solutions Advisory Programs. ETF Related Costs and Expenses. FCAS will not receive any compensation related to the purchase and holding of ETFs in the Advisory Programs. However, you should be aware of the following fees, costs, and expenses and their impact on your investment rate or return: Internal Expenses of ETFs. Assets invested under the Advisory Programs will be subject to the internal expenses of the underlying ETFs, if any. These expenses are assessed by the ETFs and disclosed in their offering documents. You may request copies of these offering documents from FCAS or your Financial Advisor, or by visiting the ETF’s website at any time at no cost. These expenses generally include, but are not limited to, the ETF sponsor fee, the trustee fee, ETF custodian’s fee, stock exchange listing fees, SEC registration fees, printing and mailing costs, audit fees, legal fees, licensing fees, marketing expenses and other operating expenses. ETF’s internal expenses have a negative impact on your investment rate of return. Bid-Ask Spread. You will also incur costs associated with FCBS trading ETFs through its clearing firm, Pershing, based on the “bid/ask” spread. The “ask” (or “offer”) is the market price at which an ETF can be bought, and the "bid" is the market price at which the same ETF can be sold. Many complicated factors drive bid/ask spreads, including the extent of market maker competition, market maker inventory management costs, size of the trade, and the liquidity of the ETF itself. The bid/ask spread of the ETF has a negative impact on your investment rate of return. Other Costs and Expenses. FCAS will not charge any commissions for trades or receive payments for order flow or directing of trades from the issuer of an ETF or Pershing related to the purchase or holding of ETFs in Advisory Program accounts. FCBS does not receive commissions for trades on ETFs within Advisory Program accounts. Revenue Sharing. For mutual funds or ETFs held within the Advisory Programs, FCBS and FCAS do not receive revenue sharing from the mutual funds, ETFs, or Pershing. SPONSORSHIP, MARKETING SUPPORT, AND EXPENSE REIMBURSEMENT Distributors of mutual funds or ETFs held within the Advisory Programs will occasionally sponsor FCBS. FCBS receives sponsorship from the “Primary Fund Families.” The Primary Fund Families are large national mutual fund families, with established risk management departments, that offer numerous funds to address the spectrum of client investment horizons and risk profiles. Each have exhibited stability over time and careful attention to designing mutual fund products that support a long-term investment strategy. Distributors of mutual funds or ETFs, including those from one or more of the Primary Fund Families, will occasionally sponsor or offer reimbursement for costs to FCBS related to: • their participation in training and/or education sessions that are provided for our Financial Advisors at companywide or regional meetings; • educational and/or marketing events for prospective and existing clients; • reasonable expenses associated with conducting due diligence review of their companies and their products; or • our attendance at their training and educational conferences, including travel and other related expenses (“sponsorship payments”). 11  Additionally, MFS Fund Distributors, Inc. pays FCBS an annual flat fee of $650,000 in consideration for FCBS performing marketing related services on behalf of MFS Fund Distributors, Inc. (“marketing support service fees”). Similar arrangements may be established with the distributors of other mutual funds or ETFs in the future. Sponsorship payments and marketing support service fees are not dependent on any particular sales target or calculated based on the value of products from the distributor. Sponsorship payments are applied to the expenses of the applicable event. Marketing support service fees are not shared with FCAS, the IMT, your WPM, or your Financial Advisor. IMT and WPM personnel are not incentivized to consider such payments in determining which securities to select and make available for the applicable Asset Management Solutions Advisory Program. Similarly, your Financial Advisor does not have an incentive to consider such payments when deciding whether to recommend an account to you in the Asset Management Solutions Advisory Programs or which specific Asset Management Solutions Model Portfolio to recommend (where applicable). Sponsorship payments and marketing support service fees are paid by the distributors from their own assets and resources (not the assets of the funds or ETFs). There is no additional cost to you as a shareholder or to the funds or ETFs. Therefore, these payments will not impact the rate or return of your investments in Asset Management Solutions Advisory Programs. We recognize that sponsorship payments, expense reimbursement and marketing support service fees are a conflict of interest as such payments create an incentive for us to recommend certain mutual funds, ETFs, and third-party managed accounts for inclusion in your Asset Management Solutions Advisory Program account(s) from distributors and third-party investment managers that make such payments over other distributors that do not. This conflict is disclosed to you in this Brochure. To address this conflict, we maintain policies and procedures to ensure that sponsorship payments, expense reimbursements, and marketing support service fees are not a factor in deciding which mutual funds, ETFs, and third-party managed accounts to select for the applicable investment strategy for your account. Those responsible for marketing support, expense reimbursement, and sponsorship are segregated from the IMT and the WPMs. We recognize our fiduciary duty and base our decisions regarding which investment strategies are recommended and utilized for your applicable Asset Management Solutions Advisory Program account(s) solely on what serves our clients’ best interests. OVERALL COST You have the option to purchase investment advisory and brokerage services similar to those provided by an advisory program from other investment advisers. These bundled set of services may be available at lower or higher overall costs from other wrap fee program sponsors. In addition, you may also be able to purchase many of the securities and investment advisory strategies and portfolios available within an Asset Management Solutions Program without participating in a wrap fee program. It may cost more or less to purchase such investment advisory and brokerage services separately depending on various factors that bear upon the relative cost of Asset Management Solutions Program in comparison to purchasing the services available thereunder outside of a wrap program, including: • Your ability to purchase fund shares outside of the applicable Asset Management Solutions Program at NAV based on existing mutual fund relationships; • Your ability to purchase mutual fund share classes with lower underlying expenses (e.g., an institutional share class with higher minimum initial investment limits); your ability for you to purchase ETFs outside of the applicable Asset Management Solutions Program without incurring brokerage commissions; 12  • The elimination of separate fees for execution of trades; • The payment of a wrap fee; • The amount you will invest; and • The tax impact of transferring assets from one mutual fund or ETF to another to meet asset allocation goals. If you currently own assets in a mutual fund or ETF, you may have other alternatives with lower fees than moving those assets into an Asset Management Solutions Advisory Program. INVESTMENT MANAGEMENT PLATFORM FCAS has an agreement with Envestnet Asset Management, Inc. (“Envestnet”) whereby Envestnet (by and through its affiliates) will provide FCAS with its Investment Management Platform Services. Envestnet offers certain services through an integrated third-party service and technology provider, which provides various administrative, investment advisory, investment management, model portfolio management, overlay management, tax overlay services, investment and manager due diligence, research, reporting, trade implementation, compliance monitoring, operational support, and/or other services. Envestnet is not a tax advisor, nor does it provide any tax advice, and clients should consult their tax consultant prior to electing the tax overlay service offered by Envestnet. For a complete description of Envestnet’s services, please refer to Envestnet’s Form ADV Part 2A and Form Part 2A Appendix 1, which is available at https://www.investpmc.com/ADVPart2A, or you can request these documents from FCAS or your Financial Advisor at any time and free of charge. The fees charged by Envestnet for its Investment Management Platform Services are based in part on the total aggregate asset value all client assets serviced by Envestnet. These fees are based on a tiered schedule where if certain breakpoints are met for the total aggregate assets, the applicable fees for the Investment Management Platform Services (expressed in basis points) are reduced. This cost structure is a conflict of interest because it incentivizes FCAS to recommend client assets be held in an Asset Management Solutions program because it will reduce FCAS’s costs for Envestnet’s Investment Management Platform Services in connection with maintaining the AMS program. It is also a conflict of interest because we have an incentive to recommend that you increase your investment in your account, as that allows FCAS to pay lower fees for Envestnet’s Investment Management Platform Services. This conflict is mitigated by the Advisory Fee Schedule which reduces the fee percentage charged to the client based on the client’s assets within the selected Asset Management Solutions Advisory Program(s). Envestnet’s operational cost is more expensive for FCAS than certain other investment platform service providers. The Advisory Fees cover FCAS’s operating costs incurred by using Envestnet instead of another investment platform service provider. We have a conflict because our revenue from the Advisory Fees is higher than the operating costs FCAS incurs from Envestnet. This conflict is mitigated by the significant capabilities Envestnet provides to FCAS and its clients, relative to other platform services providers, including but not limited to the ability to generate custom reports, improved customer service, and the opportunity to develop and offer additional advisory programs in the future. COMPENSATION TO YOUR FINANCIAL ADVISOR FCAS and your Financial Advisor will each receive a portion of the Advisory Fee. Other fees you may incur as discussed in this Brochure related to your selected Program account, i.e., fees included in the FCBS Fee Schedule, are not shared with your Financial Advisor, and, as such, your Financial Advisor does not consider such fees when deciding what to recommend to you. Financial Advisors receive a portion of the Advisory Fee for consultation and other services to you with respect to the selected 13  Program. The amount of this compensation may be more than your Financial Advisor would receive if the client participated in other FCAS programs or paid separately for investment advice, brokerage, and other services. Your Financial Advisor therefore may have a financial incentive to recommend the wrap fee program over other programs or services. The amount paid to your Financial Advisor will generally be less than if you had purchased the same investments outside the program and paid a sales charge or brokerage fee. However, for assets remaining in the selected Asset Management Solutions Advisory Program for the long term, your Financial Advisor’s compensation may be more than if you had purchased the funds outside the selected Advisory Program. CHOOSING MUTUAL FUNDS AND EFTS TO HOLD IN THE ADVISORY PROGRAMS Choosing ETFs to Hold in Foundations. The IMT, on a fully discretionary basis, will choose ETFs for Foundations Model Portfolios from certain lists of funds that are available on Pershing’s platform. The IMT will always choose ETFs for inclusion in a Foundations Model Portfolio consistent with what serves our clients’ best interests. When the IMT conducts a search for a new ETF for inclusion in these Model Portfolios, it will narrow down the applicable investment universe to a short list of ETFs that are equally suitable and recommendable. The IMT, on a fully discretionary basis, will choose ETFs for Foundations Model Portfolios available on Pershing’s platform. The IMT will always choose ETFs for inclusion in the Model Portfolios consistent with what serves our clients’ best interests. Choosing Mutual Funds and ETFs to Hold in Select. The IMT, on a fully discretionary basis, will choose mutual funds and ETFs for Select Model Portfolios from certain lists of funds that are available on Pershing’s platform. The IMT will always choose mutual funds and ETFs for inclusion in a Select Model Portfolio consistent with what serves our clients’ best interests. When the IMT conducts a search for a new mutual fund or ETF for inclusion in these Model Portfolios, it will narrow down the applicable investment universe to a short list of mutual funds or ETFs that are equally suitable and recommendable, which includes mutual funds from the Primary Fund Families. The IMT, on a fully discretionary basis, will choose mutual funds and ETFs for Select Model Portfolios that are available on Pershing’s platform. The IMT will always choose mutual funds and ETFs for inclusion in the Model Portfolios consistent with what serves our clients’ best interests. Choosing Third-Party Investment Managers in Premier Income and Elite. The IMT, on a fully discretionary basis, will evaluate and select third-party investment managers for inclusion in Premier Income and Elite Advisory Programs. The IMT selects a portfolio managed by third-party investment manager (also known as an SMA manager) based on an available slate of available third-party managed accounts already prescreened by Envestnet’s Portfolio Management Consultants (PMC). The IMT chooses each investment option based on its own due diligence and aims to select the option based on what they deem as the most appropriate for inclusion of the Premier Income Program. Considerations include cost, performance, management team, and investment philosophy. The IMT may also rely solely on due diligence provided by PMC for ongoing due diligence on a third-party managed account’s performance. When a client chooses to open a Premier Income account, the WPM will invest in a third-party managed account that will meet the client’s best interests and investment strategy. If the client opens an Elite account, the WPM may recommend and direct investment in a third-party managed account in line with the client’s best interests and investment strategy. The third- party managed accounts selected must be approved by the IMT. Depending on the Advisory Program, your WPM has discretion to select one or more a third-party managed accounts from the IMT-approved list and to add and remove third-party investment managers from the account. Choosing Investments in Elite. The IMT, on a fully discretionary basis, will evaluate and select available program investments, including third-party investment managers, for inclusion in Elite. The IMT chooses each investment option based on its own due diligence with considerations that includes 14  each option’s cost, performance, management team, and investment philosophy. The IMT may also rely solely on due diligence provided by Envestnet’s Portfolio Management Consultants (PMC) for the selection of and ongoing due diligence on any investment. When a client chooses to open an Elite account, a WPM is assigned to work with a client and their Financial Advisor to provide a customized portfolio recommendation. The portfolio recommendation will be based upon a client's financial situation, objectives, risk tolerance, time horizon, financial information, values, liquidity needs, and other factors. The WPM then directs the implementation of these recommendations and will direct the selection and termination of investment manager(s) on a discretionary basis. PROPRIETARY HOME OFFICE MODEL SELECTION OF MUTUAL FUNDS AND ETFS The disclosures below apply to mutual funds and ETFs managed by the IMT whether as a Model Portfolio in a Foundations or Select account or as a sleeve of the Elite Advisory Program (together, “Proprietary Home Office Model”). For additional information concerning third-party investment managers that invest in mutual funds and ETFs, please refer to the disclosures of these third-party investment managers, such as their Form ADV brochures, for more information on their practices. For Proprietary Home Office Models, the IMT gives preference to mutual funds and ETFs from one of the Primary Fund Families. This creates a conflict of interest because these Primary Fund Families give FCBS money and benefits in exchange for consideration and meetings to discuss investments into their funds. This conflict is mitigated because FCAS does not use the benefits conferred to FCBS by the Primary Fund Families as a factor in the IMT’s selection of funds. If a mutual fund or ETF that is not from one of the Primary Fund Families is more suitable and recommendable, the IMT will select that mutual fund or exchange traded fund instead. If a Primary Fund Family fund or ETF is equally recommendable with that of a non-Primary Fund family, the IMT will give preference to the Primary Fund Family fund. In addition, certain mutual funds and ETFs may impose short-term redemption fees for redemptions of funds that occur prior to the specified period as outlined in the prospectus. This fee, if applicable, is withheld by the fund company upon liquidation of the fund position and is separate from other fees associated with either the fund or the applicable Advisory Program. The IMT will not consider revenue sharing, cost reimbursements, or any other type of compensation when determining which mutual funds or ETFs to purchase. The IMT is not provided with this information and does not consider it a factor in its analysis. The IMT does not choose funds that have surcharge fees associated with the funds, which may lead the IMT to select a share class that does not have the lowest expense ratio. FCAS does not receive any revenue from using mutual funds or ETFs available through Pershing’s platform. Under FCBS’s contract with Pershing, Pershing provides FCAS access to all mutual funds and ETFs offered on Pershing’s platform and does not charge FCAS or its Affiliates with transaction fees associated with the selected funds. Because FCAS does not have to pay transaction fees to Pershing in connection with the purchase and sale of mutual funds and ETFs for clients, it incurs lower costs to administer its Advisory Programs. This creates a conflict of interest because FCAS has fewer expenses due to the waiver of transaction fees and, as a result, earns more revenue. Clients could pay lower internal operating expenses on the mutual funds and ETFs that are purchased for their accounts than they would if FCBS’s contract with Pershing did not waive those transaction fees. This conflict of interest is mitigated because the waiver of transaction fees affords FCAS the flexibility to select among all available share classes in selecting funds without regard to transaction fees. These selections are further subject to due diligence as described in this Brochure. Some securities on Pershing’s platform will charge FCAS surcharge fees for the selected security and those fees will be passed on to the client. FCAS strives utilize the lowest cost share class available 15  without a surcharge, there may be other less costly share classes offered by a fund that are not available to FCAS on the Pershing platform or are subject to other conditions or restrictions that would make utilizing such share class unreasonable, costly, or prohibitive. FCAS will not select securities that are unavailable on the Pershing platform unless at the client’s direction, if permitted under the applicable advisory program. FCAS participates in regular due diligence meetings with representatives of the Primary Fund Families that allows Financial Advisors to receive the most up-to-date information about the investment products offered. This close business relationship allows FCAS to directly work with the fund managers and administrators to address client concerns and needs. FCAS also meets with fund managers to address more general questions about a fund’s performance over time, and this information inures to the benefit of FCAS clients generally. Financial Advisors generally have a greater degree of familiarity with investment products from the Primary Fund Family partners (as of the date of this Brochure): Invesco, MFS, Fidelity Advisor, Victory Pioneer, Franklin Templeton, and Blackrock. The Primary Fund Family partners also pay FCBS revenue sharing for mutual fund assets held in brokerage accounts. They do not, however, pay any revenue sharing for mutual fund assets held in AMS accounts. Some Primary Fund Families will also sponsor or offer reimbursement for costs related to training, education and other events for our Advisors and clients and/or pay marketing support services fees to FCBS. All mutual funds held in the AMS program are sold by FCBS under a prospectus where the various share classes and internal fees are outlined. FCAS strongly encourages you to review the fund prospectus. PROPRIETARY HOME OFFICE MODEL MUTUAL FUND SHARE CLASSES SELECTION The IMT, in selecting mutual fund share classes in its Proprietary Home Office Models, strives to choose the share class that serves our clients’ best interests. The appropriate share class will be chosen from among eligible share classes, after considering the underlying expense ratio and redemption fees of the share class. FCAS will generally select the share class that does not charge surcharge fees and has historically experienced the lowest expense ratio from among the share classes that FCAS is eligible to purchase in its Proprietary Home Office Models. Typically, the share class chosen will be an institutional or similar share class. In certain instances, a lower cost share class may be available, but FCAS may be ineligible to purchase such share class due to the requirements of the mutual fund or the mutual fund’s distribution guidelines or because a lower cost share class would charge surcharge fees, and this would cause an increase in expenses that would be passed along to the you, affecting the profitability of your investment. You may be eligible to purchase such lower cost share classes outside of the Asset Management Solutions Advisory Programs. All accounts (or sleeves in the Elite Advisory Program) managed in accordance with a Proprietary Home Office Model will use the same share class. The IMT will select the most appropriate share class that all clients utilizing Proprietary Home Office Models are eligible to purchase instead of selecting the share class based on individual accounts. As such, there may be a share class for a particular mutual fund that experiences lower expenses than the share class selected for such fund to be held in accounts (or sleeves for Elite) utilizing the Proprietary Home Office Models. For similar reasons, you may be eligible to purchase certain share classes for a particular mutual fund outside of the applicable Asset Management Solutions Advisory Program that may experience lower expenses than the share class used for such fund in the applicable Program. Execution of Trades for All Advisory Programs. Envestnet places trades as a block for the benefit of all accounts managed in accordance with a particular investment strategy. Given the large transaction size and percentage of holdings of certain mutual funds within client accounts, it may take an extended 16  period of time to execute a buy or sell which could result in a higher or lower price for the mutual fund or ETF, potentially affecting the profitability of your investment. OPENING A NEW ACCOUNT IN AN ADVISORY PROGRAMS To open an account in an Advisory Program, you will be required to sign the IMA for those services. The IMA is designed to clearly define the roles and responsibilities between FCAS and you. FCAS may update its services from time to time. FCAS may amend the IMA if we give you written notice of such amendment and you do not object to the amendment within thirty (30) days after we send such notice to you. We will send such notice by U.S. mail to your last known address of record, or electronically deliver the notice to you if you have agreed to receive documents and information under the IMA electronically. After FCAS sends notice of an amendment to you, you will have thirty (30) days from delivery of the amendment to respond in writing that you either consent to or do not consent to the amendment. The notice of the amendment will contain instructions on how to respond. If you do not respond by the end of the thirty (30) day period or continue to receive our investment advisory services after the thirty (30) day period, you will be deemed to have consented to the amendment. While you may consent to or not consent to any amendment we seek to make to the IMA, if you choose not to consent to any such amendment, we will terminate the IMA in accordance with its terms. Existing investment advisory clients who choose to take advantage of a new Advisory Program in the future may be required to sign a new IMA. The process to open a new account in the selected Advisory Program begins with you and your Financial Advisor completing new account paperwork and signing the IMA. This IMA, along with your initial deposit (if a check made payable to Pershing as the Custodian) or transfer instructions, is then sent to our corporate headquarters in Fort Worth, Texas (“Home Office”) for processing. Once the agreement is received and deemed to be in good order at the Home Office, the new account is opened, and your funds are deposited. Within approximately five to seven business days from when your funds are deposited and provided 90% of the account minimum required for the selected Program is reached, Envestnet will initiate the necessary transactions to invest your funds in line with investment strategy you have chosen. Pershing provides the clearing services for the trades. If 90% of the account minimum is not deposited in the account, your assets will remain in a cash equivalent position or remain in the form the assets were transferred in as until such time as this threshold is met. Additional information regarding account minimums is provided below. This entire process can take several days to complete. During this time, the market will fluctuate, which could result in you receiving a higher or lower price for the mutual funds or ETFs that are purchased in your account and potentially affect the return of your investment. Assets Transferred In Kind into an Advisory Program Account. Any assets which are transferred into a new Program account in kind will be sold only once 90% of the account minimum is reached for the applicable Program. The proceeds will then be invested in accordance with the investment strategy and Program you have chosen. Selling these assets will be a taxable event in non-tax qualified accounts. Liquidating Funds from Your Account You may request a liquidation by calling (if you have telephone redemption privileges) your Financial Advisor or the First Command Customer Service Center, or by writing to the Home Office. If the request is made in good order and cash does not need to be raised in your account (i.e., mutual fund or ETF positions do not need to be sold), your request will be processed no later than the next business day and your funds will be disbursed according to your instructions. If cash needs to be raised in your account (i.e., mutual fund or ETF positions need to be sold), your request will take longer to process. Once your request is received by the Home Office in good order, we 17  will process your request and send it to Pershing and Envestnet no later than the next business day. Within 48 business hours of receipt of your request from FCBS, Envestnet will initiate the necessary trades in your account to raise the cash needed to comply with your liquidation request (provided there are no other restrictions on your account). Your funds will then be disbursed upon settlement of the trades by Pershing. This entire process can take several days to complete. During this time, the market will fluctuate, which could result in you receiving a higher or lower price for the mutual funds and ETFs being sold to comply with your liquidation request and potentially affect the profitability of your investment. ITEM 5 - ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Requirements The account minimums for the Asset Management Solutions Advisory Programs are provided below: Program Name Additional Program Costs Minimum Account Size Maximum Annual Program Fee $20,000 1.30% First Command Foundations $50,000 1.30% First Command Select $500,000 0.50% Third-party investment manager fees First Command Premier Income $1,000,000 1.30% First Command Elite Third-party investment manager fee(s); overlay services (optional) If the minimum initial investment amount is not met within 90 days of account opening or account assets are reduced due to client withdrawals to less than the account minimum, we reserve the right to terminate your IMA, liquidate your account, and send the proceeds to you. We will provide you with prior notice indicating the specific action we will take if the minimum asset amount is not met in a timely manner or account assets are reduced due to client withdrawals to less than the account minimum. Liquidating your account or converting your account from one Advisory Program to another Advisory Program may result in a taxable event and/or a higher wrap fee. The minimum initial investment amount may be changed from time to time or waived at FCAS’s sole discretion. Subsequent investments shall not be less than $100. The notice we send to you will state the specific action we will take if the account assets are not restored to meet the account minimum in a timely manner. In the event an account is deemed ineligible for the applicable Advisory Program, such as no longer meeting a Program’s minimum requirements or not funding an account (account minimum requirements) within 90 days of opening an account, FCAS has the sole authority to move the Program account to a retail, brokerage account with FCBS. Upon this move, FCAS’s Advisory Program services will be discontinued, and the related Advisory Fee will be terminated in accordance with FCAS’s policies (e.g. never charged or refunded). FCAS and your Financial Advisor will no longer be obligated to provide ongoing advice, and any trading will be done at your request (non-discretionary) subject to retail commissions on a trade-by-trade basis. 18  TYPES OF CLIENTS Asset Management Solutions Advisory Programs are open to individuals, corporate entities, charitable organizations and other institutions, and trusts only. We do not do business with pension plans or investment companies. ITEM 6 - PORTFOLIO MANAGER SELECTION AND EVALUATION ADVISORY BUSINESS FCAS offers a variety of investment advisory services to individuals, corporate entities, charitable organizations, other institutions, and trusts. Clients engage FCAS on a discretionary basis, which means FCAS will make investment decisions without the client’s prior authorization as described in this Brochure. Additionally, FCAS’s investment advisory services are subject to conditions, such as minimum account size and annual fees. Each of FCAS’s Advisory Programs is designed to focus on a specific investment strategy, using specified types of securities. Many of FCAS’s investment advisory services are provided under wrap fee programs as described in this Brochure. FCAS also offers other investment advisory services that do not fall under the wrap fee program and are not included in this Brochure. These services can be found in FCAS’s ADV Part 2A, Description of Services Brochure. Portfolio Manager Selection and Evaluation for Foundations and Select Programs The IMT serves as the portfolio managers of the Foundations and Select Advisory Programs. Performance for individual Advisory Program accounts is calculated by Envestnet. Performance for Model Portfolios in Foundations and Select is calculated by the IMT in Morningstar Direct using monthly composite return data provided by Envestnet. Performance of Model Portfolios is measured against customized blended benchmarks chosen by the IMT, which are reviewed and approved by the First Command Investment Oversight Committee (“IOC”). FCAS does not use a third-party to review its performance information. FCAS relies on the calculations made by Envestnet for performance of individual Advisory Program accounts as well as Morningstar Direct for performance of Model Portfolios. All members of the IMT are salaried employees of FCFS, the parent company of FCAS. FCFS and FCAS do not compensate IMT members in any way that may result in a conflict of interest which may cause the IMT to make an investment decision that is not in the best interests of our clients. In addition, FCAS maintains policies and procedures to eliminate and/or mitigate conflicts of interests. If a conflict of interest does arise that cannot be eliminated, FCAS will seek to mitigate such conflict and disclose it to you. Further, as part of its policies and procedures, FCAS requires that its IOC reviews changes to the Model Portfolios and customized blended benchmarks made by the IMT. Members of the IMT and IOC are chosen by the principal executive officers of FCFS. Members may be added or removed from the IMT or the IOC whenever the principal executive officers of FCFS determine that such changes are in the best interests of the AMS program and clients. Third-Party Investment Managers in the Premier Income and Elite Advisory Programs FCAS has arrangements with non-affiliated, third-party investment managers that have expertise in managing certain asset classes and investment styles (sometimes referred to as SMA managers). Refer to the applicable third-party investment manager’s program disclosures for more information on these third-party investment managers. The Wealth Solutions Team manages these relationships. The 19  IMT selects these third-party investment managers and monitors third-party investment manager performance for inclusion in the Premier Income and Elite programs. FCAS’s WPMs have discretion over the selection of third-party investment managers at the client account level. All third-party investment managers selected by the WPM must already be approved by the IMT for inclusion in the applicable Advisory Program. As provided in more detail below, all WPMs are salaried employees of FCFS, the parent company of FCAS, and are not compensated in any way that would cause the WPM to make an investment decision that is not in the best interest of our clients and are subject to First Command IOC oversight at the Advisory Program level. WPM Services under the Elite Advisory Program FCAS’s WPMs serve as the portfolio managers of the Elite Advisory Program. Performance for individual Elite accounts is calculated by Envestnet. Performance of each Elite account is measured at the account level to ensure the account is meeting the investment strategic objectives set. FCAS, through its WPMs, relies on the calculations made by Envestnet for performance of individual Elite accounts. All WPMs are salaried employees of FCFS, the parent company of FCAS. FCFS, and FCAS do not compensate WPM members in any way that may result in a conflict of interest which may cause the WPM to make an investment recommendation and decision that is not in the best interests of our clients. In addition, FCAS maintains policies and procedures to eliminate and/or mitigate conflicts of interest. If a conflict of interest does arise that cannot be eliminated, FCAS will seek to mitigate such conflict and disclose it to you. Further, as part of its policies and procedures, FCAS requires that its IOC reviews and approves investments offered at the Advisory Program level and reviews individual investment manager and fund performance within the Elite Advisory Program. PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge performance-based fees. We also do not offer side-by-side management. INVESTMENT DISCRETION Asset Management Solutions Advisory Programs exclusively provides discretionary investment management services to manage the assets in your account(s). Granting discretionary authority means you authorize FCAS to make the investment decisions on your behalf to buy, sell or trade investments, select investment products, engage or terminate Investment Managers, perform portfolio re-balancing, and determine portfolio asset allocations as described further in this Brochure. Our discretionary authority is limited to managing your assets and does not enable FCAS or the Investment Managers to make any deposits or withdrawals of assets for your account, unless expressly authorized by you. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS FCAS, through its Financial Advisors, IMT, and WPMs use a variety of quantitative and qualitative techniques as part of its analysis to minimize risk. Of course, while risk can be managed, it cannot be avoided. We do not guarantee the performance of any investments or guarantee that our investment advice or strategies or that of any Financial Advisor will be successful or that your investment 20  objectives will be met. Investment advice or financial planning recommendations provided by us (including the IMT and WPMs) or any Financial Advisor, are largely a matter of professional judgment, and neither us nor any Financial Advisor with whom you have worked shall be liable for performance or non-performance of any investment advice or recommended investment made in good faith and in accord with our duty of care. Methods of Analysis and Investment Strategies for Foundations and Select Advisory Programs Your Financial Advisor is responsible for the client relationship in the Foundations and Select Advisory Programs and provides recommendations to you subject to FCAS’s supervision and compliance requirements. FCAS’s IMT performs due diligence on investment products purchased for or recommended to our Foundations and Select Advisory Program clients and manages the day-to-day decisions for the transactions occurring in client accounts for the Foundations and Select Advisory Programs. The IMT is responsible for creating and maintaining Model Portfolios in the Foundations and Select Advisory Programs. The IMT follows a disciplined approach in researching current and potential investments, with decisions based on: • Philosophy. We are biased toward mutual funds and ETFs managed by managers who select investments based on fundamental analysis of underlying business characteristics, comprehensive review of financial statements, and prudent consideration of risks including security valuation. • Process. We seek alignment of the process with the stated philosophy and evidence of its consistency and successful execution over time. • People. The character of the individuals who will manage the funds we select is of the utmost importance. We must maintain high confidence in the experience, integrity, and dedication of those who have primary responsibility for investment decisions and be comfortable with the teams which support them and the firm cultures in which they operate. • Price. We must believe that the cost of a product is reasonable in the context of the value it can deliver for clients and in comparison, to similar alternatives. The IMT uses a variety of quantitative and qualitative techniques as part of its analysis, including many principles which have collectively become known as Modern Portfolio Theory. Modern Portfolio Theory is a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully choosing the proportions of various assets. Methods of Analysis and Investment Strategies for Premier Income and Elite Advisory Programs Your Financial Advisor is responsible for the client relationship and will recommend the Premier Income or Elite Advisory Program to you subject to FCAS’s supervision and compliance requirements. Upon your Financial Advisor’s recommendation to you to open a Premier Income or Elite account, a WPM is assigned to work with you, your Financial Advisor, and the IMT (as applicable). For Premier Income accounts, the WPM’s role is to select a third-party investment manager and complete the manager-required documents, including any changes to the third-party investment manager selection. For Elite accounts, your WPM is responsible for providing and directing customized strategies. 21  The WPM will select investments for you in accordance with the Advisory Program’s requirements and the customized investment strategy. For example, in a Premier Income account, the WPM will select a third-party investment manager that aligns with your investment strategy. In an Elite account, the WPM will select and manage your assets across multiple sleeves selected by the WPM and available within the Elite Account. The availability of sleeves within the Elite account allows multiple investment managers, who may or may not be affiliated with FCAS, to each manage a portion of the account’s assets on a discretionary basis. FCAS’s WPMs have discretion over the selection of third-party investment managers at the Premier Income and Elite Advisory Program client account level. The WPMs recommend and select an investment strategy based on your financial situation, objectives, risk tolerance, time horizon, financial information, values, liquidity needs, and other factors. All third-party investment managers selected by the WPM must already be approved by the IMT for inclusion in the applicable advisory program. The IMT approves and monitors third-party investments managers at the Advisory Program level as further described in this Brochure and following the principles of Modern Portfolio Theory as provided above. Risk of Loss Investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of, nor predictable by FCAS. Such factors include a wide range of economic, political, competitive, technological and other conditions (including acts of terrorism and war or regional/global pandemic) that affect investments in general or in specific industries or companies. The investment decisions made, and the actions taken in managing client assets will be subject to various market, liquidity, currency, economic, political and other risks. Investing in securities involves a risk of loss that clients should be prepared to bear. The investment performance and the success of any investment strategy or particular investment can never be predicted or guaranteed, and the value of a client’s investments will fluctuate due to market conditions and other factors. Investments may lose value and past performance is never a guarantee of future results. The information contained in this Wrap Fee Brochure cannot disclose every potential risk associated with an investment strategy, nor are all of the risks applicable to a particular manager, security or investment. Risks vary by client according to their investment objectives, guidelines, liquidity needs or risk tolerances and not every strategy or portfolio will be exposed to each of the risks described in this Brochure and the applicable Advisory Program. This list is not intended to be exhaustive of all of the risks associated with investing in strategies or securities that are utilized or recommended by FCAS. Rather, it is a general description of the nature and risks of the investment advisory services provided by FCAS and the related investments. This summary is qualified in its entirety by reference to the prospectuses and offering documents that apply to the funds and/or strategies that FCAS recommends and/or in which a client invests. Clients should carefully read any applicable prospectuses and/or offering documents and should consider consulting with their legal and/or tax professionals before engaging in any particular investment strategy or transacting in any specific investment. Past performance is no guarantee of future results. The sources of information used by FCAS include materials prepared by organizations such as Morningstar, Inc., financial periodicals, annual reports, prospectuses, independent research subscription services, and the other documents created by the product issuers. While we use the methods and tools noted above as part of our due diligence, each recommendation to a client is primarily built upon the client’s goals, needs, objectives, and attitudes towards risk. The recommendations generally have a long-term focus. The actual risks associated with the investments will vary depending on the particular investment chosen, but the most important risk—like with all securities— 22  remains the potential for loss of principal and income. Other material risks include: (1) the possibility of costs even in case of negative returns; (2) lack of control (e.g., we buy mutual funds and ETFs and the fund manager or portfolio manager controls the buying and selling as well as the timing of the trades for these funds); and (3) price uncertainty (e.g., the price at which you purchase or redeem mutual fund shares will typically depend on the fund’s NAV, which may not be calculated until many hours after you’ve placed your order). Stock market volatility, interest rate changes, inflation risk, interest rate risk, credit risk, political and country risk, management and company risk, etc. should also be taken into account. Other Risks Applicable to all Programs Wash Sales. Under the wash sale rules, if a client sells a security for a loss and the client repurchases the same (or substantially identical) security either 30 days before or 30 days after the date of the sale, the loss is disallowed. The wash sale rules apply to transactions not only in that account but also to transactions in all other accounts held by the client, the client’s spouse, and certain entities controlled by them as related parties. Further, FCAS cannot monitor all assets held outside of clients’ account(s) with FCAS and therefore FCAS strategy will not necessarily consider trading activity in all other security accounts held with third parties. It is the client’s responsibility to comply with the wash sale rules with respect to such accounts. Incorrect assumptions about tax attributes and transactions outside of the FCAS strategy may lead to inefficient tax management. Operational Risk. Portfolios are exposed to operational risk introduced through human intervention or the failure of automated processes. Operational risks include, but are not limited to, reconciliation errors, trading the wrong security, trading a security for an unintended portfolio or purchasing a security that a portfolio was intended to sell, or vice versa. Cybersecurity and Information Security. A portfolio is susceptible to operational and informational security risks due to the increased use of the internet. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyberattacks include, but are not limited to, infection by computer viruses or other malicious software code, gaining unauthorized access to systems, networks, or devices through “hacking” or other means for the purpose of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cybersecurity failures or breaches of third-party service providers may cause disruptions at third-party service providers and impact business operations, potentially resulting in financial losses; the inability to transact business; violations of applicable privacy and other laws, regulatory fines, or penalties; reputational damage; unanticipated expenses or other compensation costs; and/or additional compliance costs. FCAS has an established business continuity and disaster recovery plan and related cybersecurity procedures designed to prevent or reduce the impact of such risks; there are inherent limitations in such plans and systems due in part to the evolving nature of technology and cyberattack tactics. Additionally, FCAS employs reasonable security standards and safeguards to protect clients’ personal information and prevent fraud. If you suspect fraudulent activity in your FCAS account(s), you should immediately contact your Advisor or call 800.443.2104. Technology and Third-Party Vendors. FCAS relies on third-party vendors and technology providers in order to provide many of its services. Additionally, some of the technology used is provided by third- party vendors and is, therefore, beyond FCAS’s direct control. FCAS seeks to ensure adequate backups of hardware, software, telecommunications, internet-based platforms, and other electronic systems, through its vendor due diligence procedures, but there is no guarantee that any or all third- party service provider risks will be mitigated. In addition, natural disasters, power interruptions and other events may cause system failures, which will require the use of backup systems. Backup systems may not operate as well as the primary systems and may fail to properly operate, especially when used for an extended period. To reduce the impact a system failure may have, FCAS evaluates its backup 23  and disaster recovery systems and performs periodic testing of its backup systems operations. Despite FCAS’s reasonable efforts, hardware, telecommunications, or other electronic systems malfunctions may be unavoidable and result in consequences such as the inability to execute client transactions or monitor client accounts. Concentration. Strategies that are concentrated in only a few securities, sectors or industries, regions or countries or asset classes could expose a portfolio to greater risk and may cause greater portfolio volatility. Other Risks Applicable to Elite Tax Overlay Strategy. A tax overlay strategy relies on various techniques, assumptions, and calculation methodologies and cannot be guaranteed to reduce or minimize a client’s overall tax liabilities, or as to the tax results that may be generated by a given transaction (or transactions). A tax-managed strategy may cause a client portfolio to hold a security in order to achieve more favorable tax treatment or to sell a security in order to create tax losses. Factors that could impact the value of tax-managed investing techniques include, but are not limited to market conditions, the tax characteristics of securities used to fund an account, client-imposed investment restrictions, client tax rate, asset allocation, investment approach, investment universe, and any tax law or firm policy changes. The pre-tax performance of a tax- managed account may be lower than the performance of similar advisory accounts portfolios not employing a tax overlay strategy. Under current IRS regulations wash sales, which occur when securities are sold at a loss and then re-purchased within 30 days, and any tax loss sought through the sale of a security may be disallowed by the IRS. Tax-managed investing does not equate to comprehensive tax advice, is limited in scope, and not designed to eliminate taxes in an account. VOTING CLIENT SECURITIES FCAS maintains a Proxy Voting Policy which reflects our duty as a fiduciary to vote proxies in your best interest under the Advisory Programs. FCAS currently subscribes to advisory and other proxy voting services provided by an independent proxy voting service provider, Glass, Lewis & Co. (“Glass Lewis”). FCAS has delegated proxy voting for Advisory Programs clients to Glass Lewis. FCAS has addressed conflict of interest issues by hiring Glass Lewis to vote proxies on its behalf. Glass Lewis then votes proxies in accordance with its Corporate Governance Focused Thematic Policy Guidelines, which can be found at https://www.glasslewis.com/wp-content/uploads/2023/11/2024-US- Benchmark-Policy-Guidelines-Glass-Lewis.pdf. In the event of a material conflict of interest that is not otherwise addressed through our Proxy Voting Policy and relationship with Glass Lewis, we will notify you. We maintain relevant and appropriate proxy records in accordance with our Proxy Voting Policy. If you would like to receive a copy of our Proxy Voting Policy or specific voting records for proxies related to your holdings, please write to: First Command Advisory Services Chief Investment Officer Attn: Proxy Voting Policy 1 FirstComm Plaza Fort Worth, TX 76109-4999 A client may direct a vote in a particular solicitation by writing to the above address. FCAS will then work with you in accordance with our Proxy Voting Policy. 24  ITEM 7 - CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS For FCAS Asset Management Solutions Advisory Programs, client accounts are required to be established and held through FCAS’ affiliated broker-dealer, FCBS. FCAS will share client information with FCBS, Envestnet, and Pershing solely in order to manage your account. Clients receive accounts statements directly from Pershing. Clients will also receive periodic, written reports from FCAS and its Advisors. Clients are urged to compare any report provided by FCAS and its Advisors with the statements directly received from Pershing and Envestnet. FCAS’s IMT is responsible for managing client accounts held in the Foundations and Select Programs. Further, the IMT is responsible for evaluation and selection of third-party investment manager portfolios and investment strategies made available to FCAS clients through their Financial Advisor and WPM. They do not, however, possess knowledge of your personal financial situation. For Premier Income and Elite Programs, The WPM does possess personal knowledge of your financial situation due to the direct engagement you have with them and through your Financial Advisor. For certain advisory programs, FCAS utilizes third-party investment manager model portfolios. FCAS will provide such third-party investment managers client-specific information to enable that third-party investment manager to provide the elected services. NOTE: Pershing does not verify the accuracy of FCAS’ advisory fee calculation and clients do not receive an invoice from FCAS showing calculation of its advisory fees. Clients should speak with their Financial Advisor with any questions or contact the Firm using the information on the front of this Wrap Fee Program Brochure. ITEM 8 - CLIENT CONTACT WITH PORTFOLIO MANAGERS Any questions regarding the management of the advisory programs or your account(s) should be directed to your Financial Advisor or Home Office at 800.443.2104. If you are outside the U.S., call 817.731.8621. To the extent Advisory Program accounts utilize or include third-party investment manager portfolios, portfolio managers from those entities are generally not available to discuss client-specific investment issues. Please direct all questions or concerns to your Financial Advisor or Home Office using the contact information above. ITEM 9 - ADDITIONAL INFORMATION DISCIPLINARY INFORMATION FCAS has not been subject to any material legal or disciplinary events. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS First Command Financial Services, Inc. is the parent company of First Command Advisory Services, Inc., First Command Brokerage Services, Inc., First Command Insurance Services, Inc., and First Command Bank. 25  FCAS seeks to address these conflicts of interest by monitoring and enforcing a Code of Ethics, along with other compliance and supervisory policies and procedures, and through the establishment of IOC. Furthermore, FCAS seeks to disclose material conflicts of interest to its clients and prospective through this Wrap Fee Brochure (for wrap fee based Advisory Programs) and other documents. FCBS is a broker-dealer. It recommends and effects securities transactions for you, including buying and selling securities that can be either held in accounts at Pershing, its clearing firm, or held in accounts directly with the issuer of the securities purchased such as mutual fund companies. FCBS is a member of the Financial Industry Regulatory Authority (“FINRA”). FCBS is authorized to conduct business in all 50 states, the District of Columbia, Puerto Rico, and Guam. It is also a member of the Securities Investor Protection Corporation (“SIPC”) and the Municipal Securities Rulemaking Board (“MSRB”). FCIS is an insurance general agency that provides insurance products and services including but not limited to life insurance, long term care insurance, disability income insurance, liability insurance, and annuities. FCB is a federally chartered savings and loan bank (member FDIC). Personal banking products and services provided by FCB include checking and savings accounts, money market accounts, certificates of deposit, automobile loans, mortgage loans, secured and unsecured personal loans, debt consolidation loans, credit and debit cards, online banking services, and trust services. Commercial banking products and services offered by FCB include commercial checking accounts, money market savings accounts, commercial loans, business credit and debit cards and online banking services. Financial Advisors are affiliated with FCAS, are registered representatives affiliated with FCBS; and also are insurance agents affiliated with FCIS. Financial Advisors will also receive support fees from FCB in recognition of their efforts to promote your banking relationship with FCB. FCAS seeks to address these conflicts of interest by monitoring and enforcing a Code of Ethics, along with other compliance and supervisory policies and procedures, and through the establishment of the investment oversight committee (“IOC” or “Committee”). Furthermore, FCAS seeks to disclose material conflicts of interest to its clients and prospective through this Brochure and other documents. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENTS TRANSACTIONS AND PERSONAL TRADING FCFS and all of its subsidiaries, including FCAS, have adopted a rigorous Code of Ethics that sets forth the high ethical standards of business conduct required of FCFS and its subsidiaries’ employees and Advisors. FCAS takes great pride in our integrity and our commitment to serving clients’ needs. The Code of Ethics sets forth the standards of conduct expected of all FCAS personnel. The Code is based on the principle that all employees and supervised persons of FCAS have a fiduciary duty to place the interests of clients ahead of their own and of FCAS. It is a means of memorializing our vision of appropriate and professional conduct in servicing our clients. Each of FCAS’s employees and representatives have been furnished with a copy of this Code and has acknowledged and accepted its terms. The Code espouses policies to safeguard your confidential information, engage in fair dealing, and avoid conflicts of interest in decision-making. We do not tolerate violations to our Code of Ethics by taking allegations of a violation to this policy seriously and holding each employee and representative responsible for maintaining the standards set by the Code of Ethics. 26  We comply with all applicable laws and regulations that govern our business. You may review the FCFS Code of Ethics at any time. It is available on the website at https://cdn.firstcommand.com/assets/web-documents/code-of-ethics.pdf. You may also obtain a paper copy of the Code of Ethics by calling us at 800.443.2104 or writing to us at the following address: First Command Advisory Services Attn. Chief Compliance Officer 1 FirstComm Plaza Fort Worth, TX 76109-4999 FCAS, Financial Advisors, and its Affiliated Companies recommend or effect transactions in securities in which an FCAS or Affiliate director, officer, employee, or another Financial Advisor may also invest directly or indirectly. This poses a conflict of interest to the extent that transactions in such securities on behalf of FCAS clients may advantage such related persons. FCAS and its Affiliated Companies do not buy from, sell to, or otherwise enter into transactions for securities with clients or client accounts. BROKERAGE PRACTICES FCAS uses its affiliate FCBS for all brokerage transactions and services. FCBS is an introducing broker- dealer. As an introducing broker-dealer, it recommends and effects securities transactions for you, including buying and selling securities that can be either held in accounts at Pershing, its clearing firm, or held in accounts directly with the issuer of the securities purchased such as mutual fund companies. Pershing is not affiliated with any First Command Affiliated Companies. Pershing or the issuer of the securities purchased, as applicable, will be responsible for maintaining policies and procedures for aggregating the purchase or sales of securities for client accounts. Aggregation will generally not have an effect on the price you pay or receive when purchasing or selling mutual funds and ETFs. Pursuant to the terms and conditions set forth in the IMA, if you select FCAS as your investment adviser to manage your cash, securities and other assets which will be custodied (or maintained) at a designated third-party custodian selected by FCAS, i.e., Pershing and managed in a FCAS Advisory Program, client understands and agrees that it must use FCBS for any brokerage-related service. Not all investment advisers require their clients to use a specific broker-dealer. Requiring clients to use a particular broker-dealer may result in being unable to achieve the most favorable execution of client transactions, which could cost clients more money. In the case of mutual funds, it is important to note that the price at which you purchase or redeem shares will depend on the fund’s NAV, which the fund may not calculate until many hours after you've placed your order. In general, mutual funds must calculate their NAV at least once every stock market trading day, typically after the major U.S. exchanges close. As such, requiring you to use a particular broker-dealer will generally not have an effect on the price you pay or receive when purchasing or selling mutual funds. There is a conflict of interest when offering investment advisory services that require our Affiliated Company to provide brokerage services for which it is compensated. FCAS maintains policies, procedures, supervision systems and other measures to help mitigate its conflict of interest. FCAS does not receive additional compensation, is not subject to quotas, and does not qualify for bonuses or awards based on the purchase or referral of proprietary products. A client’s assets in an Advisory Program will be maintained in client’s name by a qualified custodian selected by FCAS, which is Pershing. Accounts are required to be established and held through FCAS’ 27  affiliated broker-dealer, Pershing, a non-affiliated firm, member Financial Industry Regulatory Authority (FINRA) and Securities Investor Protection Corporation (SIPC). FCBS provides brokerage, custody and execution services through its clearing arrangement with Pershing. Services provided by Pershing include, but are not limited to: (i) maintaining custody of client’s assets; (ii) trading client’s assets; (iii) providing client with monthly or quarterly account statements, (iv) providing client with certain tax reporting documents, (v) delivering prospectuses, proxy materials and other similar documents, (vi) managing credit interest and dividend payments in the account, (vii) crediting principal on called or matured securities in the account, and (viii) other custodial functions. FCAS’s and FCBS’s affiliation creates conflicts of interest and, in many cases, incentivizes FCAS and its Financial Advisors to recommend an affiliate’s products and/or services versus other, similar, non- affiliated providers. Additionally, many of FCAS’s Financial Advisors serve in multiple capacities and may be incentivized to recommend products or services that create the greatest compensation for the Financial Advisor. For additional information about FCBS’s order execution and routing practices, contact the First Command Home Office using the information on the cover page of this brochure. FCAS selected FCBS primarily due to its Affiliated Company status and FCBS’s relationship with Pershing. As part of this relationship, FCAS, through its affiliation with FCBS, receives substantial economic and non-economic benefits from Pershing, including but not limited to accessibility to dedicated service personnel, electronic and institutional trading, third party research and technology, technical and operational support, advisory fee processing, and electronic communications and reporting to clients. FCBS receives substantial financial incentives and access to other products, services, and fee reductions from Pershing as part of its overall relationship with Pershing; however, some of these benefits may be based on the amount of brokerage and advisory assets held by Pershing. For example, FCBS receives quarterly financial incentives from Pershing based on the number of funded brokerage and advisory accounts custodied at Pershing and the total assets under management from these accounts. Further, FCBS receives additional financial incentives from Pershing for FCBS reaching specific threshold targets for moving and consolidating assets in client accounts custodied by Pershing. FCAS’s and FCBS’s affiliation creates a conflict of interest and, in many cases, incentivizes FCAS and its Financial Advisors to recommend FCBS and Pershing brokerage products and clearing services versus other, similar, non-affiliated providers. Further, First Command Financial Advisors serve in multiple capacities and may be incentivized to recommend products or services that create the greatest compensation for the Financial Advisor. As further detailed in this Brochure, as part of FCBS’s overall relationship with Pershing, FCAS receives research and other products or services (other than custody of securities, trade execution, clearance and settlement of transactions) from Pershing. Some of these benefits may be based on the amount of advisory assets held by the custodian. Additionally, FCBS receives asset-based pricing on custodial charges in lieu of ticket or transactional charges. The receipt of these benefits creates a conflict of interest because FCAS has an incentive to base advice in part on the benefit to FCAS and not solely on the nature, cost or quality of custody or brokerage services provided by FCBS and Pershing. In addition to disclosing these conflicts of interest, FCAS has created and implemented a compliance and supervisory program to mitigate such conflicts through the oversight of client accounts and investment advisory activities. FCBS and Pershing have negotiated a long-term contractual arrangement that provides FCBS substantial financial incentives and access to other products, services, and fee reductions from Pershing as part of its overall relationship with Pershing. The contract FCBS has with Pershing spells out the costs and commitments as well as the fees FCBS receives from Pershing for certain activities. 28  As part of their negotiated contract, if FCBS chooses to leave Pershing before the contract expires and move to another custodian, FCBS is required to pay a substantial sum of money back to Pershing (which reduces over time), as well as a per-account fee for certain retirement accounts that transfer away from Pershing. The terms of this negotiated contract, including the payments disclosed herein, incentivize FCBS to remain with Pershing. FCBS’s selection of Pershing was not based solely on these payments but instead was based on intensive search and due diligence of other possible custodians that FCBS felt met the requirements and needs of FCBS and its customers. Nevertheless, these financial and other incentives create conflicts of interest. The compensation and incentives FCBS receives through Pershing are not directly shared with our IMT, WPM, or Financial Advisors. The various types of compensation and incentives FCBS receives from Pershing are described below: • Quarterly Financial Incentives. FCBS receives quarterly financial incentives from Pershing based on the number of funded brokerage and advisory accounts custodied at Pershing and the total assets under management from these accounts. Further, FCBS receives additional financial incentives from Pershing for FCBS reaching specific threshold targets for moving and consolidating assets in client accounts custodied by Pershing. Additionally, FCBS receives asset-based pricing on custodial charges in lieu of ticket or transactional charges. • Account Credits. Pershing financially compensates FCBS based on the number of accounts and their average account size on the Pershing platform. This creates a conflict of interest because Pershing provides a substantial financial incentive to FCBS to consolidate assets onto the Pershing platform in order for FCBS to receive additional monetary compensation from Pershing. • Asset Credits. Pershing paid FCBS a one-time, substantial asset consolidation support payment upon long-term renewal of Pershing custodial services to FCBS. FCBS is also able to receive additional asset consolidation support payments on an ongoing basis upon receiving certain conversion thresholds. Further, Pershing provides monetary compensation to FCBS for net new assets introduced to the Pershing platform each quarter. Eligible accounts for transfer include Direct to Fund accounts and IRA accounts held directly with a mutual fund sponsor. On an aggregate basis, the amount of the credits amount to significant amounts of money considering the number of accounts that can transfer to Pershing. This creates a conflict of interest as the transfer credit may be more than FCBS and FCAS’ costs and expenses. In most cases. clients will also incur additional costs by transferring their accounts held directly with a mutual fund sponsor to Pershing. These costs will likely exceed a client’s direct mutual fund costs and will benefit FCAS or its affiliates. Although, the transfer credit is not shared with clients or Advisors, it is a material conflict of interest when an account held directly with a mutual fund sponsor transfers to Pershing. This also concerns circumstances where a direct retirement plan is transferred to an individual retirement account held through Pershing. FCBS, at its sole discretion, adds a markup to various brokerage and custodial fees that are paid by clients. The markup generates additional revenue for FCBS. The actual fees and charges that clients will incur are dependent upon the type of account, the nature of the transaction, the quantity of the transaction, the services provided, or the positions held in the account. Not all brokerage firms mark up these or other fees. FCAS is obligated to seek best execution for all trades, regardless of program; however, 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 services. While FCAS reviews the accuracy, timeliness and execution of trades processed through Pershing, FCAS cannot guarantee that a client will receive the most favorable execution of trades, which in turn may cost clients more money. Periodically, FCAS reviews the custodial services provided by other qualified 29  custodians in comparison to those provided by FCBS and Pershing. Please refer to FCBS’s Regulation Best Interest Disclosure (also known as the “Reg BI”) for more information regarding FCBS’s practices and conflicts of interest. For more information or to request a copy of the Regulation Best Interest Disclosure, contact your Financial Advisor. CLIENT REFERRALS AND OTHER COMPENSATION We do not receive any compensation for our advisory services other than compensation related to our AMS program (as described in this brochure) We also do not pay fees to other parties for client referrals. Please see our ADV Part 2A Disclosure of Services brochure for further details on these financial interests and associated conflicts of interest. CUSTODY As noted above, Pershing serves as the custodian of advisory clients’ funds and securities and clears and settles all trades for the Advisory Program. Accordingly, FCAS does not have physical custody of your assets. However, pursuant to a triparty agreement with Pershing, FCBS and FCB perform certain functions to administer the account with respect to which FCAS provides investment advisory services, as described above in Section I. Brokerage Practices. Further, FCAS has the authority to deduct, or instruct the custodian to deduct, advisory fees directly from client accounts. FCAS is therefore considered to have legal custody of your funds or securities because of this authority and because it is an Affiliated Company of FCBS and FCB. For example, if you maintain an advisory account with FCAS, you may authorize FCBS to perform certain Automated Clearing House (ACH) functions such as direct deposits, distributions, and asset movements which FCBS personnel will facilitate on your behalf through Pershing’s systems. In addition, FCB provides limited, tax-related reporting services for individual retirement accounts. FCBS is only permitted to have physical possession of your funds or securities for a very limited time period; Pershing, in its role as a full-service broker-dealer, is responsible for maintaining your funds and securities upon receipt from FCBS, FCB, and other third parties. Pershing will send you statements on at least a quarterly basis. In addition, FCAS will provide clients with quarterly performance monitoring reports for clients’ accounts which may be accessed electronically through FCAS’s Client Portal (i.e., “Command Center”). Clients will receive all documents electronically unless you opt-in to receive paper documents. Importantly, clients will incur fees and costs for electing to receive paper statement via regular mail. You should carefully review all statements received, ensure that they are accurate, and notify us immediately if there are any discrepancies. FINANCIAL INFORMATION FCAS is financially able to meet all of its obligations. We have not been the subject of a bankruptcy petition and do not anticipate any issues that would limit our ability to meet our contractual obligations to our clients or business partners. 30  31 FORM ADV PART 2B BROCHURE SUPPLEMENT BROCHURE SUPPLEMENT INVESTMENT MANAGEMENT TEAM First Command Advisory Services, Inc. (“FCAS”) 1 FirstComm Plaza, Fort Worth, Texas 76109-4999 1-800-443-2104 Overseas, Call 817-731-8621 www.firstcommand.com clientservices@firstcommand.com This brochure supplement provides information about FCAS’s Investment Management Team (“IMT”) that supplements the FCAS Brochure. Please contact our Home Office at 800.443.2104 if you did not receive a complete copy of the ADV Part 2A or if you have any questions about the contents of this supplement. Additional information about the First Command’s IMT is available on the SEC’s website at www.adviserinfo.sec.gov.  MATT WILEY Year of Birth: 1981 Item 1: Address and Phone Number 1 FirstComm Plaza Fort Worth, Texas 76109-4999 1-800-443-2104 Item 2: Educational Background and Professional Experience: Education Florida Atlantic University, Boca Raton, FL ................................. 2007, B.B.A., Management and Marketing Nova Southeastern University, Fort Lauderdale, FL .................... M.B.A., Finance Professional Experience First Command Advisory Services, Inc ....................................... 5/2020 – Present Vice President, Investment Management DFW Airport Interfaith Chaplaincy .............................................. 1/2013 – Present Treasurer/Chair of Finance Committee PlainsCapital Bank ...................................................................... 2/2009 – 5/2020 SVP, Director of Portfolio Management Professional Designations Chartered Financial Analyst* ...................................................... 2011 Item 3: Disciplinary Information There is no disciplinary information to report. Item 4: Other Business Activities Matt Wiley does not receive compensation from business activities outside of FCAS. Matt Wiley is a member of the IMT and an employee of FCFS. He is compensated by salary, bonus and other employee benefits. He does not receive a portion of the annual wrap fee charged to Advisory Program accounts or commissions based on the sale of securities or other investment products. Item 5: Additional Compensation Matt Wiley does not receive compensation for providing advisory services from sources other than FCAS. Item 6: Supervision Our IMT serves as the portfolio manager for all Model Portfolios within the First Command Foundations and Select Advisory Programs. They are also responsible for managing and continuously reviewing the securities and third-party investment managers available within the Advisory Programs as further described in our Wrap Fee Program Brochure. First Command’s IOC is responsible for overseeing changes to the Model Portfolios, and selection of third-party investment managers and portfolios made by the IMT. Members of the IMT and IOC are chosen by the principal executive officers of FCFS. Members may be added or removed from the IMT or the IOC whenever the principal executive officers of FCFS determine that such changes are in the best interests of the Advisory Programs and clients. Matt Wiley, as the head of the IMT, is supervised by John Weitzer, Chief Investment Officer, who can be reached by calling 817-569-2654. 32  WILLIAM SAGER Year of Birth: 1984 Item 1: Address and Phone Number 1 FirstComm Plaza Fort Worth, Texas 76109-4999 1-800-443-2104 Item 2: Educational Background and Professional Experience: Education Texas Christian University, Fort Worth, TX ................................. 2007, B.B.A., Finance and Accounting Professional Experience First Command Advisory Services, Inc ....................................... 3/2018 – Present Director of Portfolio Management Frenkel Benefits, LLC ................................................................. 4/2016 – 8/2017 Account Manager – Retirement Services Noise4Good, LLC ....................................................................... 7/2014 – 12/2015 Senior Vice President of Finance Operations Howard Financial Services, Ltd ................................................... 6/2008 – 3/2011 and 2/2012 – 5/2013 Investment Analyst B.C. Holdings, Inc ....................................................................... 3/2011 – 1/2012 Investment Analyst Professional Designations Chartered Financial Analyst* ...................................................... 2012 Item 3: Disciplinary Information There is no disciplinary information to report. Item 4: Other Business Activities William Sager does not receive compensation from business activities outside of FCAS. William Sager is a member of the IMT and an employee of FCFS. He is compensated by salary, bonus and other employee benefits. He does not receive a portion of the annual wrap fee charged to Advisory Program accounts or commissions based on the sale of securities or other investment products. Item 5: Additional Compensation William Sager does not receive compensation for providing advisory services from sources other than FCAS. Item 6: Supervision. Our IMT serves as the portfolio manager for all Model Portfolios within the First Command Foundations and Select Advisory Programs. They are also responsible for managing and continuously reviewing the securities and third-party investment managers available within the Advisory Programs as further described in our Wrap Fee Program Brochure. First Command’s IOC is responsible for overseeing changes to the Model Portfolios, and selection of third-party investment managers and 33  portfolios made by the IMT. Members of the IMT and IOC are chosen by the principal executive officers of FCFS. Members may be added or removed from the IMT or the IOC whenever the principal executive officers of FCFS determine that such changes are in the best interests of the Advisory Programs and clients. William Sager is a member of the IMT and reports to Matt Wiley, who supervises all advisory activities of the IMT. Matt Wiley can be reached by calling 817-569-3971. DANIEL B. MURPHY Year of Birth: 1967 Item 1: Address and Phone Number 1 FirstComm Plaza Fort Worth, Texas 76109-4999 1-800-443-2104 Item 2: Educational Background and Professional Experience: Education University of Notre Dame, Notre Dame, IN ................................. 1990, B.S., Electrical Engineering Columbia Business School, New York City, NY .......................... 1995, M.B.A., Finance Professional Experience First Command Advisory Services, Inc ....................................... 9/2022 – Present Investment Strategist Ocelus Capital, LLC .................................................................... 2/2013 – 12/2020 Equity Portfolio Manager UBS Investment Bank ................................................................. 1/2011 – 2/2012 Investment Strategist Wellington Management LLP ...................................................... 5/2003 – 12/2008 Macro Analyst Professional Designations Chartered Financial Analyst* ...................................................... 1999 Item 3: Disciplinary Information There is no disciplinary information to report. Item 4: Other Business Activities Daniel Murphy does not receive compensation from business activities outside of FCAS. Daniel Murphy is a member of the IMT and an employee of FCFS. He is compensated by salary, bonus and other employee benefits. He does not receive a portion of the annual wrap fee charged to Advisory Program accounts or commissions based on the sale of securities or other investment products. Item 5: Additional Compensation Daniel Murphy does not receive compensation for providing advisory services from sources other than FCAS. 34  Item 6: Supervision. Our IMT serves as the portfolio manager for all Model Portfolios within the First Command Foundations and Select Advisory Programs. They are also responsible for managing and continuously reviewing the securities and third-party investment managers available within the Advisory Programs as further described in our Wrap Fee Program Brochure. First Command’s IOC is responsible for overseeing changes to the Model Portfolios, and selection of third-party investment managers and portfolios made by the IMT. Members of the IMT and IOC are chosen by the principal executive officers of FCFS. Members may be added or removed from the IMT or the IOC whenever the principal executive officers of FCFS determine that such changes are in the best interests of the Advisory Programs and clients. Daniel Murphy is a member of the IMT and reports to Matt Wiley, who supervises all advisory activities of the IMT. Matt Wiley can be reached by calling 817-569-3971. MATTHEW D. CONNER Year of Birth: 1987 Item 1: Address and Phone Number 1 FirstComm Plaza Fort Worth, Texas 76109-4999 1-800-443-2104 Item 2: Educational Background and Professional Experience: Education Virginia Commonwealth University, Richmond, VA ..................... 2005, B.S. John’s Hopkins University, Baltimore, MD .................................. 2018, M.S., Applied Econometrics Professional Experience First Command Advisory Services, Inc ....................................... 3/2022 – Present Senior Investment Consultant First Command Financial Services, Inc ....................................... 12/2019 – 3/2022 Financial Advisor US Department of Defense ........................................................ 3/2012 – 4/2019 Psychological Operations Specialist Federal Reserve Bank of Richmond ........................................... 6/2008 – 7/2009 Researcher; Writer Professional Designations Chartered Financial Analyst* ...................................................... 2022 Item 3: Disciplinary Information There is no disciplinary information to report. Item 4: Other Business Activities Matthew Conner does not receive compensation from business activities outside of FCAS. Matthew Conner is a member of the IMT and an employee of FCFS. He is compensated by salary, bonus and other employee benefits. He does not receive a portion of the annual wrap fee charged to Advisory Program accounts or commissions based on the sale of securities or other investment products. 35  Item 5: Additional Compensation Matthew Conner does not receive compensation for providing advisory services from sources other than FCAS. Item 6: Supervision Our IMT serves as the portfolio manager for all Model Portfolios within the First Command Foundations and Select Advisory Programs. They are also responsible for managing and continuously reviewing the securities and third-party investment managers available within the Advisory Programs as further described in our Wrap Fee Program Brochure. First Command’s IOC is responsible for overseeing changes to the Model Portfolios, and selection of third-party investment managers and portfolios made by the IMT. Members of the IMT and IOC are chosen by the principal executive officers of FCFS. Members may be added or removed from the IMT or the IOC whenever the principal executive officers of FCFS determine that such changes are in the best interests of the Advisory Programs and clients. Matthew Conner is a member of the IMT and reports to Matt Wiley, who supervises all advisory activities of the IMT. Matt Wiley can be reached by calling 817-569-3971. WILLIAM HAYNES Year of Birth: 1969 Item 1: Address and Phone Number 1 FirstComm Plaza Fort Worth, Texas 76109-4999 1-800-443-2104 Item 2: Educational Background and Professional Experience: Education University of Texas, Austin, TX ................................................... 1991 B.A. Texas Christian University, Fort Worth, TX ................................. 1997 M.B.A. Chartered Financial Analyst* ...................................................... 2004 Chartered Public Accountant** ................................................... 2013 Professional Experience First Command Advisory Services, Inc ....................................... 4/2019 – Present Investment Analyst First Command Financial Services, Inc ....................................... 6/2010 – 4/2019 Senior Financial Analyst Monitronics, Inc .......................................................................... 12/2006 – 07/2009 Financial Planning & Analysis Manager Professional Designations Chartered Financial Analyst* ...................................................... 2004 Chartered Public Accountant** ................................................... 2013 Certificate in Investment Performance Measurement*** ............. 2022 36  Item 3: Disciplinary Information There is no disciplinary information to report. Item 4: Other Business Activities William Haynes does not receive compensation from business activities outside of FCAS. William Haynes is a member of the IMT and an employee of FCFS. He is compensated by salary, bonus and other employee benefits. He does not receive a portion of the annual wrap fee charged to Advisory Program accounts or commissions based on the sale of securities or other investment products. Item 5: Additional Compensation William Haynes does not receive compensation for providing advisory services from sources other than FCAS. Item 6: Supervision Our IMT serves as the portfolio manager for all Model Portfolios within the First Command Foundations and Select Advisory Programs. They are also responsible for managing and continuously reviewing the securities and third-party investment managers available within the Advisory Programs as further described in our Wrap Fee Program Brochure. First Command’s IOC is responsible for overseeing changes to the Model Portfolios, and selection of third-party investment managers and portfolios made by the IMT. Members of the IMT and IOC are chosen by the principal executive officers of FCFS. Members may be added or removed from the IMT or the IOC whenever the principal executive officers of FCFS determine that such changes are in the best interests of the Advisory Programs and clients. William Haynes is a member of the IMT. The IMT is supervised by Matt Wiley, who supervises all advisory activities of the IMT. Matt Wiley can be reached by calling 817-569-3971. REEDER MENGWASSER Year of Birth: 1997 Item 1: Address and Phone Number 1 FirstComm Plaza Fort Worth, Texas 76109-4999 1-800-443-2104 Item 2: Educational Background and Professional Experience: Education Texas A&M University, College Station, TX ............................... 2019, B.B.A. Professional Experience First Command Advisory Services, Inc ...................................... 5/2018 – Present Investment Analyst Item 3: Disciplinary Information There is no disciplinary information to report. 37  Item 4: Other Business Activities Reeder Mengwasser does not receive compensation from business activities outside of FCAS. Reeder Mengwasser is a member of the IMT and an employee of FCFS. He is compensated by salary, bonus and other employee benefits. He does not receive a portion of the annual wrap fee charged to Advisory Program accounts or commissions based on the sale of securities or other investment products. Item 5: Additional Compensation Reeder Mengwasser does not receive compensation for providing advisory services from sources other than FCAS. Item 6: Supervision Our IMT serves as the portfolio manager for all Model Portfolios within the First Command Foundations and Select Advisory Programs. They are also responsible for managing and continuously reviewing the securities and third-party investment managers available within the Advisory Programs as further described in our Wrap Fee Program Brochure. First Command’s IOC is responsible for overseeing changes to the Model Portfolios, and selection of third-party investment managers and portfolios made by the IMT. Members of the IMT and IOC are chosen by the principal executive officers of FCFS. Members may be added or removed from the IMT or the IOC whenever the principal executive officers of FCFS determine that such changes are in the best interests of the Advisory Programs and clients. Reeder Mengwasser is a member of the IMT. The IMT is supervised by Matt Wiley, who supervises all advisory activities of the IMT. Matt Wiley can be reached by calling 817-569-3971. ROBBIE DAFFRON Year of Birth: 2000 Item 1: Address and Phone Number 1 FirstComm Plaza Fort Worth, Texas 76109-4999 1-800-443-2104 Item 2: Educational Background and Professional Experience: Education University of North Florida, Jacksonville, FL ............................... 2021, B.B.A. University of North Florida, Jacksonville, FL ............................... 2023, M.B.A. Professional Experience First Command Advisory Services, Inc ....................................... 1/2022 – Present Investment Analyst Item 3: Disciplinary Information There is no disciplinary information to report. 38  Item 4: Other Business Activities Robbie Daffron does not receive compensation from business activities outside of FCAS. Robbie Daffron is a member of the IMT and an employee of FCFS. He is compensated by salary, bonus and other employee benefits. He does not receive a portion of the annual wrap fee charged to Advisory Programs accounts or commissions based on the sale of securities or other investment products. Item 5: Additional Compensation Robbie Daffron does not receive compensation for providing advisory services from sources other than FCAS. Item 6: Supervision Our IMT serves as the portfolio manager for all Model Portfolios within the First Command Foundations and Select Advisory Programs. They are also responsible for managing and continuously reviewing the securities and third-party investment managers available within the Advisory Programs as further described in our Wrap Fee Program Brochure. First Command’s IOC is responsible for overseeing changes to the Model Portfolios, and selection of third-party investment managers and portfolios made by the IMT. Members of the IMT and IOC are chosen by the principal executive officers of FCFS. Members may be added or removed from the IMT or the IOC whenever the principal executive officers of FCFS determine that such changes are in the best interests of the Advisory Programs and clients. Robbie Daffron is a member of the IMT. The IMT is supervised by Matt Wiley, who supervises all advisory activities of the IMT. Matt Wiley can be reached by calling 817-569-3971. Professional Designations As identified in this Brochure Supplement, one or more team members of the IMT possess professional designations as outlined in their supplement. The following are descriptions of the minimum qualifications required for an individual to possess each of the professional designations contained in this supplement. *The Chartered Financial Analyst® (CFA) designation is awarded by the CFA Institute to individuals who possess an undergraduate degree and four years of professional experience involving investment decision making or four years of qualified work experience, who complete a three level self-directed course of study and who pass final examinations at each level. No continuing education/experience is required for maintenance of the designation. **Certified Public Accountants (CPA) are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the education, experience and testing requirements for licensure as a CPA generally include minimum college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in accounting), minimum experience levels (most states require at least one year of experience providing services that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA), and successful passage of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion of 40 hours of continuing professional education (CPE) each year (or 80 hours over a two-year period or 120 hours over a three-year period). Additionally, all 39  American Institute of Certified Public Accountants (AICPA) members are required to follow a rigorous Code of Professional Conduct which requires that they act with integrity, objectivity, due care, competence, fully disclose any conflicts of interest (and obtain client consent if a conflict exists), maintain client confidentiality, disclose to the client any commission or referral fees, and serve the public interest when providing financial services. The vast majority of state boards of accountancy have adopted the AICPA’s Code of Professional Conduct within their state accountancy laws or have created their own. ***Certificate in Investment Performance Measurement ® (CIPM®) is a specialized course of study offered by the CFA Institute that leads to the CIPM certificate and is dedicated to investment performance evaluation and presentation. The program promotes professional ethics, global best practices in investment performance measurement, attribution, appraisal, and reporting techniques as well as proficiency using the increasingly important Global Investment Performance Standards (GIPS®). To earn the CIPM certificate, candidates must qualify for or pass two exams and have two years of professional experience substantially entailing performance-related activities or four years in the investment industry. Our Financial Advisors Your Financial Advisor will provide you a separate brochure supplement with information about himself or herself. You may contact your Financial Advisor or our Home Office at 800.443.2104 if you have any questions about your Financial Advisor’s brochure supplement. IMPORTANT INFORMATION RELATED TO RETIREMENT ACCOUNTS For purposes of complying with the Department of Labor’s Prohibited Transaction Exemption 2020- 02 (“PTE 2020-02”), we acknowledge that when we provide investment advice to you regarding your retirement accounts, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates certain conflicts with your interests, so we operate under PTE 2020-02, a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under PTE 2020-02, when providing individualized investment advice to retirement accounts, we must also: • Meet a professional standard of care (give prudent advice); • Not put our financial interests ahead of yours (give loyal advice); • Avoid misleading statements about our conflicts of interest, fees and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about our conflicts of interest. This information is provided to you in this Wrap Fee Program Brochure and our other firm disclosures. This fiduciary acknowledgment does not create an ongoing duty to monitor your accounts or create or modify a contractual obligation or fiduciary status under state law. Not all services or activities we provide to your retirement account(s) are subject to the provisions above. When we talk about retirement accounts, we are referring to all types of employee benefit plans qualified under Section 401(a) or described under Section 403(b)(7) or a governmental plan under ERISA and the Internal Revenue Code of 1986, as amended, and their regulations. 40  First Command Advisory Services, Inc. 1 FirstComm Plaza, Fort Worth, Texas 76109-4999 1-800-443-2104 • Overseas, Call 817-731-8621 www.firstcommand.com clientservices@firstcommand.com 10225