FIRST COMMAND ADVISORY SERVICES

DESCRIPTION OF SERVICES BROCHURE 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 December 18, 2023. 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.  MATERIAL CHANGES SINCE LAST UPDATE This brochure is dated December 18, 2023. We may update this brochure at any time. We will notify you whenever there are material changes to our Form ADV Part 2A. In addition, we will annually provide you a summary of material changes along with an offer to provide you with a current copy of our Form ADV Part 2A. We have not made any material changes to our Form ADV Part 2A since our last update dated October 2022. You may request a current copy of this brochure at any time by contacting your Financial Advisor, calling First Command’s Home Office at 800.443.2104 (overseas, call 817.731.8621), or visiting www.firstcommand.com. 1  TABLE OF CONTENTS I. FORM ADV PART 2A: FIRM BROCHURE ...................................................................................... 3 A. OUR ADVISORY BUSINESS ..................................................................................................... 3 B. FEES AND COMPENSATION .................................................................................................... 5 C. PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT ...................................... 6 D. TYPES OF CLIENTS .................................................................................................................. 7 E. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ......................... 7 F. DISCIPLINARY INFORMATION ................................................................................................. 8 G. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................ 8 H. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENTS TRANSACTIONS & PERSONAL TRADING ............................................................................................................... 9 I. BROKERAGE PRACTICES ........................................................................................................ 9 J. REVIEW OF ACCOUNTS ........................................................................................................... 9 K. CLIENT REFERRALS AND OTHER COMPENSATION ............................................................ 10 L. CUSTODY ................................................................................................................................ 10 M. INVESTMENT DISCRETION .................................................................................................... 10 N. VOTING CLIENT SECURITIES ................................................................................................ 10 O. FINANCIAL INFORMATION ..................................................................................................... 10 II. FIRST COMMAND PRIVACY NOTICE .......................................................................................... 11 III. OTHER IMPORTANT DISCLOSURES........................................................................................... 14 A. OUR CUSTOMER IDENTIFICATION PROGRAM .................................................................... 14 B. FINRA’S BROKERCHECK PROGRAM .................................................................................... 14 C. BUSINESS RECOVERY NOTICE ............................................................................................ 14 D. ADDRESS CHANGES AND CLIENT ASSIGNMENT ................................................................ 15 E. CUSTOMER COMPLAINTS ..................................................................................................... 16 F. ADDITIONAL RIGHTS WE RESERVE ..................................................................................... 16 G. WORKING WITH OTHER PROFESSIONALS .......................................................................... 16 H. INFORMATION REGARDING CFP® CERTIFICANTS............................................................... 16 I. IMPORTANT NOTICE REGARDING DELIVERY OF DISCLOSURE DOCUMENTS (HOUSEHOLDING AND E-DELIVERY) .................................................................................... 17 J. CHOOSING A TRUSTED CONTACT PERSON ........................................................................ 17 K. IMPORTANT INFORMATION RELATED TO RETIREMENT ACCOUNTS ................................ 17 IV. INVESTMENT ADVISORY AGREEMENT ...................................................................................... 19 V. ELECTRONIC DELIVERY AGREEMENT ...................................................................................... 24 VI. GLOSSARY OF TERMS ................................................................................................................ 25 APPENDIX A: DATA PRIVACY AND PROTECTION POLICY Forms ▪ CLIENT CONSENT ▪ TPS SERVICE FORM ▪ CLIENT IDENTIFICATION VERIFICATION 2  I. FORM ADV PART 2A: FIRM BROCHURE A. OUR ADVISORY BUSINESS 1. Who We Are First Command Advisory Services, Inc. (“First Command”) and its affiliated entities have been serving American families since 1958. First Command is registered as an investment adviser with the U.S. Securities and Exchange Commission (“SEC”). 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 (“Advisor” or “Advisors”). First Command is a wholly owned subsidiary of First Command Financial Services, Inc. First Command Financial Services, Inc. is 100 percent owned by the First Command Employee Stock Ownership Plan. All references to “you” and “your” in this brochure refer to prospective and existing clients of First Command. References to “we,” “us” or “our” refer to First Command and/or your Advisor. Registration as an investment adviser with the SEC does not imply a certain level of skill or training. 2. 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. These services are described in further detail below. 3. Our Tailored Professional Services We offer our clients personalized investment advisory services and financial planning services for a fee. These services are collectively called Tailored Professional Services (“TPS”). If you choose to become a TPS client, you will be entitled to personalized investment advisory services and financial planning services from us for a term of 12 months. The 12-month term begins on the date that you sign the Investment Advisory Agreement (“IAA”). You may renew prior to the end of each term for an additional 12-month term of service. The following services are included as part of 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 changes during the Service Period to your circumstances you report to your 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 Advisor within the Service Period. ▪ When appropriate, and with your consent, bringing together other professionals independent of First Command 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 First Command does not provide legal or tax advice and the TPS fee does not cover fees that may be charged and billed separately by other professionals. 3  In addition to the above services, we also provide you with other advisory services based upon your specific situation and needs. At the beginning of the term, , you and your Advisor will discuss the services expected to be provided during the term when negotiating the fee for that term. In order to provide you with TPS, our 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 with your Advisor. We will work collaboratively with you and encourage you to be an active participant in all discussions related to the advisory services we provide to you. In addition to providing you with financial planning services, you will also receive recommendations for specific products. Any recommendations for transactions in investment brokerage products will be provided to you by First Command Brokerage Services, Inc., in its capacity as a broker-dealer. First Command Brokerage Services, Inc.’s product offerings include mutual funds, variable annuities, variable life insurance, and Section 529 Plans. You will pay commissions when you make a new investment in a brokerage product or when you trade in a brokerage account. First Command Brokerage Services, Inc.’s recommendations will generally be limited to these types of investments only. ▪ For mutual fund investments, First Command Brokerage Services, Inc. will typically make recommendations for new accounts from the following mutual fund families: Fidelity Advisor Funds, Franklin Templeton Investments, Invesco, Ltd, Amundi Pioneer Investments, Massachusetts Financial Services Company, BlackRock, and American Funds. ▪ For variable annuities, First Command Brokerage Services, Inc. will make recommendations for new contracts from the following insurance carriers: Equitable (AXA); Lincoln National Life Insurance Company; and Brighthouse Securities, LLC (formerly MetLife). ▪ For variable life insurance, First Command Brokerage Services, Inc. will make recommendations for new contracts from the following insurance carrier: Lincoln National Life Insurance Company. ▪ On a limited basis, First Command Brokerage Services, Inc. may also effect transactions in individual equites, exchange traded funds or bonds/debt instruments. Any recommendations for Asset Management Solutions accounts will be provided by First Command Advisory Services, Inc., in its capacity as an investment adviser. You will pay investment advisory fees for maintaining investment advisory accounts with First Command Advisory Services, Inc. Any recommendations for insurance products will be provided by First Command Insurance Services, Inc., an insurance general agent. No part of the advisory fee charged to you is for recommendations related to insurance. You will pay commissions when you purchase insurance products through First Command Insurance Services, Inc. Any recommendations for banking products and services (including Investment Management Accounts) will be provided by First Command Bank. You determine whether to implement any of the recommendations provided to you and are under no obligation to purchase any product or service through First Command Advisory Services, Inc. or its affiliates. Your Advisor must be appropriately licensed in order to offer the recommendations provided in connection with the TPS. Risk is inherent in investing and therefore we do not guarantee future financial results as a result of your implementation of any of the recommendations we make to you. You may elect to implement any of the recommendations provided to you in whole or in part through First Command Advisory Services, Inc., or its affiliates. If you elect to implement any of the recommendations provided to you, then you are responsible for all fees and expenses (such as investment advisory fees and/or commissions and expenses related with brokerage or insurance products) incurred in connection with the implementation of a financial plan. You will receive an 4  appropriate disclosure document and an agreement describing the nature and extent of the services provided by First Command Advisory Services, Inc. or its affiliates and the applicable fees charged for those services. The fees charged by First Command Advisory Services, Inc. such as investment advisory fees in connection with the implementation of a financial plan are in addition to the fees incurred by you for the TPS and in connection with the formulation of a financial plan. As stated above, some recommendations may be for advisory products and services through First Command Advisory Services, Inc., brokerage products and services through First Command Brokerage Services, Inc. or insurance products and services sold through First Command Insurance Agency, Inc. These products and services pay 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 Advisor. 4. Limited Advisory Services Without a Fee At our discretion, we may also provide investment advice and financial planning services to clients who may not be TPS clients or Asset Management Solutions (“AMS”) program clients without charging an advisory fee. As noted herein below, we do not charge TPS fees to active-duty military clients and their dependents. 5. Our Asset Management Solutions™ Program As part of our AMS program, we offer two services: the Foundations Investment Program and the Select Investor Program. The AMS program enables us to provide you with customized investment portfolio options composed of mutual funds and/or exchange-traded funds managed by our Investment Management Team. If you desire to invest in our AMS program, your Advisor will provide you with a copy of our Wrap Fee Brochure which explains the AMS program, including details about fees, features of the program, etc. If you participate in the AMS program, First Command will manage and periodically rebalance your account assets consistent with the asset allocation for your chosen model portfolio. First Command does not monitor AMS accounts on an individual basis. First Command also will not monitor any other types of accounts, including those held by clients who participate in its TPS program. First Command and your Advisor will each share a portion of the wrap fee charged to you for your participation in the AMS program. 6. Assets Under Management As of September 30, 2023, First Command manages 17.8 billion on a discretionary basis as part of its AMS program. 7. Investment Advisory Agreement In order to obtain investment advisory services from First Command, you will be required to enter into an Investment Advisory Agreement (“IAA”). An Investment Management Agreement (“IMA”) also will be required for clients opening an AMS account. These agreements are designed to clearly define the roles and responsibilities that you have as a client and that First Command has as a service provider. One clause in each agreement discusses how disputes between you and First Command will be resolved. The agreements require that you submit a dispute to either mediation or arbitration. By consenting to mediation or arbitration, you are not waiving any of the protections afforded to you by federal or state securities laws, rules, or provisions. We may update our service offerings from time to time. However, we will continue to honor our obligations under agreements entered into with existing clients until notice is provided otherwise or until a new agreement which replaces the existing agreement is signed. Existing clients who choose to take advantage of new offerings may be required to sign a new agreement. 5  B. FEES AND COMPENSATION Our fees and compensation for the above-described investment advisory services are as follows: 1. Our TPS Fees and Compensation ▪ Fee. The fee you pay for TPS reflects the time and effort which First Command and your Advisor will devote to providing you with personalized investment advisory services and financial planning services, as well as our training and experience. First Command will calculate the initial fee for TPS based upon your income and investable assets, the complexity of your situation, and the experience and credentials of the Advisor assigned to you. The fee will be between $750 and $6,000 and will be valid for the initial 12 months term only. The fee is negotiable and will be payable when signing the IAA. You and your Advisor will discuss the personalized investment advisory services and financial planning services expected to be provided during the term when negotiating the fee for that term. ▪ Terms. The fee for each 12-month term for TPS will be determined by mutual agreement between you and your Advisor. ▪ Refunds. In the event you decide to terminate the IAA within five (5) business days after signing it, you will receive a full refund of the TPS fee you paid. ▪ Discounts. First Command may discount, reduce, or waive TPS fees at its sole discretion. ▪ Active Duty Military Clients. In recognition of the service and sacrifice those members of the U.S. military provide to our Nation, First Command will not charge TPS fees to active-duty military clients and their dependents. ▪ Compensation to Your Advisor. Both First Command and your Advisor will receive a portion of the TPS fee charged to you. This compensation is paid to Advisors for their time and effort in providing services to you. 2. Our AMS Program Related Fees Compensation If you desire to invest in our AMS program, your Advisor will provide you with a copy of our Wrap Fee Brochure which explains the AMS program. Our Wrap Fee Brochure discusses the fees and compensation for our AMS program in detail. 3. Fees and Compensation Related to Brokerage, Insurance, and Banking Products Commissions, fees, and other costs may be applicable should you desire to implement recommendations made to you for brokerage products offered by First Command Brokerage Services, Inc., insurance products offered by First Command Insurance Services, Inc. or banking products offered by First Command Bank. These fees and charges are in addition to and separate from the fees discussed above. Advisory fees discussed above related to the TPS and the AMS program are not offset by these commissions, fees, and other costs. Our Financial Advisors receive compensation for the sale of brokerage products (including fees from the sale of mutual funds), insurance products and banking products. The payment by you and receipt of compensation by us and your Advisor 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. We work hard to mitigate conflicts of interest by employing a range of policies, procedures, training, supervision systems and other measures. We strive to ensure that the recommendations our Financial Advisors make to you through your financial plan are in your best interest. We make recommendations for products and services that are in your best interest, and we do not put our interests ahead of yours. We disclose this conflict of interest to you in this Description of Services brochure. In this way, we help you consider such conflicts when deciding whether to adopt our advice. 6  4. First Command Brokerage Services, Inc.’s Regulation Best Interest Disclosure First Command Brokerage Services, Inc.’s Regulation Best Interest Disclosure includes information related to (1) material facts relating to the scope and terms of your relationship with First Command Brokerage Services, Inc. including the capacity in which it acts when providing services to you; (2) the material fees and costs that will apply to your transactions, holdings and accounts with First Command Brokerage Services, Inc.; and (3) conflicts of interest associated with First Command Brokerage Services, Inc. making a recommendation of a securities transaction or investment strategy involving securities to you. First Command Brokerage Services, Inc. employs a range of policies, procedures, supervision systems and other measures to help mitigate these conflicts of interest. You will receive this disclosure prior to or at the time you receive a recommendation from First Command Brokerage Services, Inc. in its capacity as a broker-dealer. You may also obtain a copy of this disclosure by contacting your Financial Advisor, calling First Command’s Home Office at 800.443.2104 (overseas, call 817.731.8621), or visiting www.firstcommand.com. You have the option to purchase brokerage products through other brokers or agents instead of our affiliate, First Command Brokerage Services, Inc. C. PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge performance-based fees. We also do not offer side-by-side management of accounts. D. TYPES OF CLIENTS In our capacity as an investment adviser, we offer advisory services to individuals, corporate entities, and trusts only. We do not do business with pension plans, investment companies or institutional clients. Should you desire to invest in our AMS program, the minimum initial investment requirement to participate in the Foundations program is $20,000 per registration type and the minimum initial requirement to participate in the SIP program is $50,000 per registration type. We do not have a minimum account size or investment amount requirement to participate in the TPS program. E. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS First Command’s Investment Management Team (IMT) conducts the firm’s due diligence on investment products offered to our clients and manages the day-to-day decisions for the model portfolios in the AMS program. First Command requires the IMT to follow a disciplined approach in researching current and potential investments, with decisions based on: ▪ Philosophy. We are biased toward 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 our clients’ assets 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 7  proportions of various assets. 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 Advisor will be successful or that your investment objectives will be met. Investment advice or financial planning recommendations provided by us or any Advisor are largely a matter of professional judgment, and neither us nor any 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 with reasonable care. Investing in securities involves risk of loss that clients should be prepared to bear. The sources of information used by First Command 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 (the fund manager or portfolio manager controls the buying and selling as well as the timing of those trades); and (3) price uncertainty (the price at which you purchase or redeem 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. F. DISCIPLINARY INFORMATION First Command has not been subject to any material legal or disciplinary events. G. 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., First Command Bank, and First Command Europe Ltd. First Command Brokerage Services, Inc. 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 LLC, its clearing firm, or held in accounts directly with the issuer of the securities purchased. First Command Brokerage Services, Inc. is a member of the Financial Industry Regulatory Authority (“FINRA”). First Command Brokerage Services, Inc. is authorized to conduct business in all 50 states, the District of Columbia and Guam. It is also a member of the Securities Investor Protection Corporation (“SIPC”) and the Municipal Securities Rulemaking Board (“MSRB”). First Command Insurance Services, Inc. is an insurance general agency. Insurance products and services are provided by First Command Insurance Services, Inc. Insurance product offerings include life insurance, long term care insurance, disability income insurance, liability insurance, and annuities. First Command Bank is a federally chartered savings and loan association and a member of the Federal Deposit Insurance Corporation (FDIC). Personal banking products and services provided by First Command Bank 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 First Command Bank include commercial checking accounts, money market savings accounts, commercial loans, business credit and debit cards and online banking services. Our Advisors are investment adviser representatives for First Command Advisory Services, Inc., registered representatives for First Command Brokerage Services, Inc. and insurance agents for First Command Insurance Services, Inc. Our Advisors will also receive support fees from First Command Bank in recognition of their efforts to promote your banking relationship with First Command Bank. 8  In the United Kingdom, investment and insurance products and services are offered through First Command Europe Ltd. First Command Europe Ltd. is authorized and regulated by the Financial Conduct Authority (FCA) and is bound by the FCA’s rules and regulations in the conduct of its business. First Command Europe Ltd.’s FCA register number is 482323 and its head office is located at: Unit 4 Wallis Court, James Carter Road, Mildenhall, Suffolk, IP28 7DD, United Kingdom. You may check First Command Europe Ltd.’s authorizations with the FCA at by calling the FCA at 0800 111 6768, by writing to the FCA at 12 Endeavour Square, London UK E20 1JN or through other contact options listed at https://www.fca.org.uk/contact. Certain investment and insurance products offered in the United States may not be available in Europe. H. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENTS’ TRANSACTIONS & PERSONAL TRADING First Command has adopted a rigorous Code of Ethics that sets forth the high ethical standards of business conduct that we require of our employees and Advisors. It includes our core values and commitment to our clients. We promise to put the interests of our clients ahead of our own. We comply with all applicable laws and regulations that govern our business. You may review our Code of Ethics at any time. It is available on our website at https://www.firstcommand.com/assets/pdf/code-of-ethics.pdf. You may also obtain a paper copy of our Code of Ethics by calling us at 800.443.2104 or writing to us at the following address: 1 FirstComm Plaza, Fort Worth, TX 76109-4999. Attn. Chief Compliance Officer. First Command, its parent company and affiliates participate in many of the same securities we recommend to you for their corporate holdings and their retirement plans maintained for employees. In all instances, the positions these companies maintain are small enough to have no impact on the pricing or performance of the security. First Command, its parent company and affiliates do not buy from, sell to, or otherwise enter into transactions for securities with clients or client accounts. I. BROKERAGE PRACTICES First Command Advisory Services, Inc. will recommend its affiliate First Command Brokerage Services, Inc. for all brokerage transactions. First Command Brokerage Services, Inc. is an introducing broker-dealer. As an introducing broker- dealer, it recommends and effect securities transactions for you, including buying and selling securities that can be either held in accounts at Pershing LLC, its clearing firm, or held in accounts directly with the issuer of the securities purchased. Pershing LLC and First Command Brokerage Services, Inc. are not affiliated entities of each other. Pershing LLC 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. You may choose to use a broker-dealer other than our affiliate First Command Brokerage Services, Inc. for brokerage transactions, except for in our AMS program, if you desire to do so. Not all investment advisers require their clients to use a specific broker-dealer. Directing brokerage may result in broker-dealers 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 typically 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 business day, typically after the major U.S. exchanges close. As such, directing brokerage will generally not have an effect on the price you pay or receive when purchasing or selling mutual funds. As previously noted, we recognize there is a conflict of interest when offering investment advisory services while our affiliates are also being compensated for the sale of brokerage, insurance, and banking products. This conflict is disclosed to you in this brochure. First Command maintains policies, procedures, supervision systems and other measures to help mitigate this conflict of interest. 9  J. REVIEW OF ACCOUNTS If you participate in the AMS program, First Command will manage and periodically rebalance your account assets consistent with the asset allocation for your chosen model portfolio. First Command does not monitor AMS accounts on an individual basis. First Command also will not monitor any other types of accounts, including those held by clients who participate in its TPS program. We recommend that all clients meet with their Advisor on at least an annual basis for a review. During reviews, your personal financial information will be updated. You may require more frequent reviews depending on your particular situation or if a periodic review raises questions about your portfolio. You should contact your Advisor any time a material change in your circumstances occurs which might affect the manner in which your assets should be invested. A revised recommendation will be made, if appropriate. For AMS accounts, account statements will be provided to you in writing or electronically on at least a quarterly basis. 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. Unless you notify us within 30 days, we will not be responsible for any unauthorized transactions or other errors in your account. K. CLIENT REFERRALS AND OTHER COMPENSATION We do not receive any additional compensation for our advisory services other than as described in this brochure. We also do not pay fees to other parties for client referrals. L. CUSTODY We do not have custody of your assets. Pershing LLC is the custodian of assets and executes and settles all trades for AMS accounts. Pershing LLC will send you statements on at least a quarterly basis. You should carefully review all statements received, ensure that they are accurate, and notify us immediately if there are any discrepancies. M. INVESTMENT DISCRETION If you participate in the AMS program, you will enter into an Investment Management Agreement whereby you will grant First Command authority to buy and sell securities in your AMS account without asking for your consent in advance (also known as “discretion”). This authority is valid until rescinded by you and it may only be exercised consistent with your chosen model portfolio and any other restrictions agreed upon by you and First Command. First Command will not have any investment authority for any other types of accounts, including those held by clients who participate in its TPS program. N. VOTING CLIENT SECURITIES For AMS accounts, we will have the authority to vote client securities. We maintain a Proxy Voting Policy, which is discussed in our Wrap Fee Brochure. You may write to the below address for a copy of our Proxy Voting Policy for AMS: SVP, Chief Investment Officer Attn: Proxy Voting Policy 1 FirstComm Plaza, Fort Worth, TX 76109-4999 O. FINANCIAL INFORMATION First Command 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. 10  II. FIRST COMMAND PRIVACY NOTICE First Command respects the privacy of our clients and is committed to safeguarding their information. This Privacy Notice is designed to explain what type of information we collect, how we collect it, how it is used, who we share it with, and under what circumstances it will be shared. First Command’s Privacy Notice applies to First Command Financial Services, Inc., and its wholly owned subsidiary companies, including First Command Brokerage Service, Inc., First Command Advisory Services, Inc., First Command Insurance Services, Inc., First Command Bank and First Command Europe Ltd. (together the “First Command Family of Companies”). Please refer to Appendix A. DATA PRIVACY AND PROTECTION POLICY CORE POLICY FC-11 APPROVED DATE: 11/01/2023 LAST REVIEWED: 11/01/2023 III. OTHER IMPORTANT DISCLOSURES A. OUR CUSTOMER IDENTIFICATION PROGRAM To help the government fight the funding of terrorism and money laundering activities, federal law requires First Command Advisory Services, Inc., its affiliates, and all other financial institutions to obtain, verify, and record information that identifies each person who opens an account. This notice answers some questions about our Customer Identification Program. When you open an account, we require the following information: 1. Name 2. Date of birth 3. U.S. Physical Address 4. Taxpayer identification number, Social Security number or employer identification number You may also need to show your driver’s license or other identifying documents. A corporation, partnership, trust, or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement, or a trust agreement. U.S. Department of the Treasury, Securities and Exchange Commission, FINRA, and New York Stock Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives, and risk tolerance. We may not be able to open an account or carry out transactions for you if you do not provide the information requested or your identity cannot be verified. If we have already opened an account for you, we may have to close it. B. FINRA’S BROKERCHECK PROGRAM FINRA Rule 2267 requires broker-dealer firms, such as First Command Brokerage Services, Inc., to inform you that the FINRA BrokerCheck hotline number is 800.289.9999 and the FINRA web site address is www.finra.org. An investor brochure that includes information describing the BrokerCheck program may be obtained from FINRA. 11  C. BUSINESS RECOVERY NOTICE As an integral element of your financial success, we have considered at length possible serious situations which could disrupt our business and your ability to avail yourself of our services or gain access to your funds. We have considered scenarios such as cyber events, power outages, pandemics, natural disasters and other significant events. We will keep our contingency and business continuity plans current and effective and will address material changes as they occur. Our plans will be formally reviewed on an annual basis. The plans outlined here are based on estimates and assumptions about possible future occurrences. Actual events may dictate some modification and, depending upon the event, substantial modification may be required. We will make every effort to ensure continued service to you at all times. You should also check our Client Portal and www.firstcommand.com for important information in the case of an event. ▪ Investment Accounts. Clients who are unable to contact their Advisor may contact our Home Office or another First Command office for assistance or information. Our Home Office may be contacted by writing to 1 FirstComm Plaza, Fort Worth, TX 76109-4999, by calling 800.443.2104 or by emailing clientservices@firstcommand.com. Contact information for other First Command offices is available on our website at www.firstcommand.com. For queries regarding mutual fund accounts held directly at the fund company, clients may also contact the individual fund companies directly by consulting the fund company Web sites or the toll-free number referenced on your transaction statements. ▪ Insurance Products. Clients who are unable to contact their Advisor may contact our Home Office or another First Command office for information. In the event First Command experiences a significant business interruption and no First Command representative is available, please contact your insurance company using the information on the front cover or specification page of your policy. ▪ Banking Products. For queries regarding your banking products, please use the following information below to contact First Command Bank. This information is also listed on the back of the Depository Agreement and Disclosure, mailed directly to all First Command Bank account owners: First Command Bank 1 FirstComm Plaza, Fort Worth TX 76109-4999 or PO Box 901041, Fort Worth, TX 76101-204B1 Phone: 817 731-8621 Toll Free: 888.763.7600 24 hour automated banking 888-763-7601 Toll Free Fax: 888.763.7605 Email: Bankinfo@firstcommandbank.com Web site: www.firstcommand.com D. ADDRESS CHANGES AND CLIENT ASSIGNMENT It is vitally important that First Command have accurate contact information for you in order to provide you with the highest quality service. As your address changes over time, please feel free to use any of the options below to notify us of your new address: ▪ On the Web Command Center web site (www.firstcommand.com) featuring password-protected access. ▪ By mail First Command, Attn. Address Change Request, 1 FirstComm Plaza, Fort Worth, TX 76109-4999 You may also use an Address Change Request form available from each office. 12  ▪ Telephone First Command Client Services Department: 800.443.2104 ▪ Email First Command Client Services Department: clientservices@firstcommand.com ▪ Contact your local First Command Office In the office or by telephone, in conjunction with a written confirmation of your request. ▪ Contacting First Command Bank For those First Command Bank clients that also have products with First Command Brokerage Services, Inc. and/or First Command Advisory Services, Inc., you can direct that First Command Bank notify First Command Brokerage Services, Inc. and/or First Command Advisory Services, Inc. of your new address, as well. As a necessary measure of security, we will verify your identity prior to any request you make to update your address of record. Our goal is to provide you with the best, face-to-face service we possibly can. To this end, we prefer to assign you to an Advisor who is local to your area to assist you with your financial services needs. We recognize that military members and others may move due to a change in duty location, job, family situation, etc. When you move, we will reassign you to another Advisor who is closer to your new location. In locations where we are unable to assign you to a local Advisor, we will offer you remote assistance through a team of Advisors in our Home Office. Requests for exceptions to this policy may be considered on a case-by-case and are subject to our sole discretion. E. CUSTOMER COMPLAINTS Prompt attention will be given to all customer complaints. Customer complaints should be directed to: First Command Quality Management Department 1 FirstComm Plaza, Fort Worth, TX 76109-4999 Email: Quality_Management_Inbox@firstcommand.com Telephone: 800.443.2104 Fax: 817.569.2244 F. ADDITIONAL RIGHTS WE RESERVE In addition to the rights expressly stated in this document and elsewhere, First Command Brokerage Services, Inc., First Command Advisory Services, Inc., First Command Bank and their affiliates and parent company reserve the right to: (1) freeze any account or policy held through us and/or suspend any services when we have received reasonable notice of a dispute regarding the account, policy, or service, including but not limited to notice of a dispute between the registered or beneficial account owners or when we reasonably believe a fraudulent transaction may occur or has occurred; (2) freeze any account or policy held through us and/or suspend services upon initial notification to us of the death or incapacity of the owner until we receive required documentation in good order; (3) set off the funds in any of your accounts held through us against any due and payable debt you owe us now or in the future without your permission to do so and when permitted by law; and/or (4) terminate our relationship with you for cause (e.g., in cases of abusive or threatening conduct, or suspicious, fraudulent, or illegal activity) or without cause. These actions may be taken at our sole discretion and without your prior consent. 13  G. WORKING WITH OTHER PROFESSIONALS From time to time, your Advisor may suggest and, with your written permission, work with other professionals (i.e., estate planners, accountants, attorneys, etc.) in the development and/or implementation of your financial plan or delivery of other services. Such professionals may charge fees which are separate from, and in addition to, fees charged by First Command or any of our product providers. An Advisor’s suggestion of any other professionals to the client shall not constitute endorsement of such other professionals by the Advisor or First Command. Clients engaging any such other professionals do so independently of the Advisor or First Command. Clients are solely responsible for all aspects of their relationship with any other professionals (including, but not limited to, independently interviewing, negotiating fee schedules, payment terms, hiring and firing, etc.). H. INFORMATION REGARDING CFP® CERTIFICANTS If your Advisor is a CFP® certificant, he or she acknowledges his or her responsibility to adhere to the standards established in CFP Board’s Standards of Professional Conduct, including the duty of care of a fiduciary, as defined by CFP Board. If you become aware that his or her conduct may violate the Standards, you may file a complaint with CFP Board at www.CFP.net/complaint. The Certified Financial Planner Board of Standards, Inc. owns the certification marks CFP®, CERTIFIED FINANCIAL PLANNER™ and federally registered CFP (with flame design) in the U.S., which it awards to individuals who successfully complete CFP Board’s initial and ongoing certification requirements. IMPORTANT NOTICE REGARDING DELIVERY OF DISCLOSURE DOCUMENTS I. (HOUSEHOLDING AND E-DELIVERY) Each year, we are required to automatically send you our privacy policy notice and certain other disclosure documents. In order to reduce the volume of mail you receive, when possible, only one copy of these documents will be sent to clients who are part of the same family and share the same household address. Household-based mailings will be sent to your mailing address on file with us or will be delivered to you electronically if you have authorized e-delivery. To sign up for e-delivery, choose from these options: ▪ Log on to your Command Center account and consent to e-delivery via the MyProfile screen. ▪ Call the First Command Client Services Center at 800.443.2104 so that a representative can assist you in making the arrangements that best fit your needs. ▪ Visit your First Command Financial Advisor. We will continue to send disclosure documents to you on a household basis until such time as you notify us of your desire to opt out. To opt out of household-based mailings, you may write to the First Command Legal and Compliance Department, Re: Householding of Disclosure Documents, 1 FirstComm Plaza, Fort Worth, TX 76109-4999 or call 800.443.2104 (overseas 817.731.8621), and we will begin sending individual copies to you within 30 days after you opt out. J. CHOOSING A TRUSTED CONTACT PERSON To provide additional account security, First Command allows you the option to designate a trusted contact for your products with us. We will only communicate with your trusted contact if we cannot reach you, or if we suspect financial exploitation. You can remove, change, or update your trusted contact at any time. Your trusted contact does not have the authority to access your account or make transactions on your behalf. Rather, this person’s role is to help us contact you; to provide the identity of any legal guardian, executor, trustee, or holder of power of attorney; or to help us look into possible financial exploitation. You should choose someone that you trust to act on your behalf, will know how to reach you, and is at least 18 years old. 14  To designate, remove, change, or update your trusted contact, please contact your Financial Advisor or our Home Office at 1 FirstComm Plaza, Fort Worth, TX 76109-4999 or call 800.443.2104 (overseas 817.731.8621). K. 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 Description of Services 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. 15  IV. INVESTMENT ADVISORY AGREEMENT First Command Advisory Services, Inc. (“First Command,” “We” or “Us”) is a Registered Investment Adviser. Client (“Client” or “You”) has requested investment advisory services from First Command. First Command will service Client’s needs through its investment adviser representatives (“Advisor” or “Advisors”). First Command and Client may individually be referred to as a “Party.” This Agreement (“Agreement” or “IAA”) explains how First Command and its Advisor or Advisors will provide investment advisory services to You. First Command and Client agree: 1. Disclosure; We will explain who We are and our services and products. You have received a copy of First Command’s disclosure brochure called the Description of Services (“DOS”). The DOS tells You about First Command and its products and services. It is important to Us that You have the opportunity to ask your Advisor questions relating to First Command and its products and services. You have the right to terminate this Agreement within five (5) business days after You have signed it. In the event You decide to terminate this Agreement within five (5) business days after signing it, fees for investment advisory services paid by You under this Agreement will be refunded. Note: First Command will not charge any fee if You terminate this Agreement within five (5) business days of signature and We will return all fees paid by You under this Agreement. However, if You purchase securities prior to termination it will result in sales charges or commissions, redemption or other fees upon cancellation of the purchase and possible changes in the investment’s market position, either positively or negatively, all of which shall be your sole responsibility. 2. How We will serve You; our Tailored Professional Services. We will provide personalized investment advisory services and financial planning services to You. These activities on your behalf are collectively called Tailored Professional Services (“TPS”). We will provide TPS to You for a twelve (12) month period beginning with the date of this Agreement (the “Service Period”). The following services are included as part of the TPS program: ▪ A written financial plan with recommendations and strategies for cash management (banking) and wealth accumulation and management (investing) and risk management (insurance) during the initial twelve (12) month Service Period. ▪ An updated written financial plan during any renewal Service Period in which You report a material change to your circumstances. ▪ 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 Advisor within the Service Period. ▪ When appropriate, and with your consent, bringing together other professionals independent of First Command 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 We 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 addition to the above services, We will also provide You with other advisory services based upon your specific situation and needs. 16  3. Fees. The fee We will charge for providing You TPS will be based on your income and investable assets; the complexity of your situation; and the experience and credentials of the Advisor assigned to You. The fee will be between $750 and $6,000 and will be valid for the Service Period only. The fee is negotiable and will be payable when signing this Agreement. You and your Advisor will discuss the personalized investment advisory services and financial planning services expected to be provided during the Service Period when negotiating the fee. The expected services and agreed- upon fee will be documented on a First Command TPS Service Form and signed by You. Your signature on this form will constitute your acknowledgment that the fee is appropriate considering the expected services to be provided. We note that the services which will be listed on the TPS Service Form are expected services only. Actual services provided may vary depending on a variety of factors, including your desires and level of engagement as part of the process, as well as our professional judgment regarding your needs after analyzing your situation. In the event that actual services require Us to expend greater time and effort than the expected services discussed when negotiating the fee, We reserve the right to require an additional fee from You. You will be notified that an additional fee is required prior to the additional required services being performed. The fee for each Service Period will be determined by mutual agreement between you and your Advisor. You will be required to complete and sign a new First Command TPS Service Form for each Service Period. The fee You pay for TPS reflects the time and effort which We will devote to providing You with personalized investment advisory services and financial planning services, as well as our training and experience. The fee is for advice and service related to Wealth Accumulation and Management (investing) and Cash Management (banking) only. No part of the fee covers or relates to insurance, although We may consider and recommend insurance options to You in our capacity as an insurance agent. Insurance products and services are compensated through insurance commissions only. In addition to the fee for TPS, You may also pay commissions and/or management or service fees should You purchase products or services. You are not obligated to purchase any products or services recommended by First Command or our affiliates and will only incur fees, commissions or sales charges for the products purchased. 4. Information You must provide. In order to provide you with TPS under this Agreement, We will ask You to provide information and financial data (“information”). It is important that the information You give to the Advisor is complete and accurate in all respects. Any financial plan and/or other financial planning recommendations prepared for You will address your current financial circumstances and goals and be based on the information You provide on questionnaires, documents and during interviews with your Advisor. 5. We will not have custody of your assets; We will only act at your direction. Neither First Command nor Advisor will hold or have custody of your assets, accounts, or securities. Unless You invest in our Asset Management Solutions (“AMS”) program, We will not monitor or have any discretionary authority over your assets. If You invest in our AMS program, You will be required to enter into an Investment Management Agreement (“IMA”) in addition to this IAA. The IMA grants Us discretionary authority over any accounts You hold as part of the AMS program. Any management fees paid by You under the terms and conditions of the IMA will be separate from and in addition to any fees paid by You under this IAA. 17  6. Limited advisory services without a fee. At our discretion, We may provide investment advisory services to clients without charging a fee for advisory services. 7. We can rely on your authority to act. You have the legal ability to enter into this Agreement and it is valid and binding. If You are acting on behalf of a corporation, limited liability company or partnership including a charitable organization such as a church (collectively “your company”), You state that your company has given You the authority to act. If We ask, You agree to provide other papers to prove your authority to act. 8. Changes to your situation. In the event your circumstances change in any manner that You believe to be material or significant, You should call or write Us and explain the change. A material change is one of real consequence for your financial situation and is essential for Us to know and consider in providing guidance on important matters for You. 9. How long does this Agreement last? This Agreement will continue unless cancelled by either You or First Command upon thirty (30) days written or electronic notice sent by one to the other. 10. We can use affiliated companies and other providers of services to help You. First Command is a subsidiary, or part, of First Command Financial Services, Inc. (“FCFS”) and exchanges services with FCFS. First Command also exchanges services with First Command Brokerage Services, Inc., First Command Bank, First Command Insurance Services, Inc. and other subsidiaries of FCFS. You authorize us to use corporations affiliated with First Command (an “Affiliated Company”) to help Us serve You. This includes recommending First Command Brokerage Services, Inc. for all brokerage transactions. The Affiliated Company will be paid for providing this help. So that we may provide reasonable services to You, We will share with Affiliated Companies any information We have or may obtain about You. We will also hire any nonaffiliated companies (“Providers”) to help Us serve your needs. 11. We do not provide legal or tax advice. First Command and Advisor will not provide You with legal or tax advice. You should seek the assistance of an attorney, CPA or other tax professional regarding the legal and/or tax ramifications of implementing recommendations We may make to You. At your request We will assist You in securing legal, tax or other professional services provided by independent professionals, including the members of the deliverables team. The choice of which legal, tax or other expert to select is your decision. The recommendation to You of an attorney, CPA or other professional does not constitute an endorsement of the professional by Advisor or First Command. Your engagement of any professional is independent of Advisor or First Command. Since neither First Command nor Advisor control your interaction with the other professionals, You are solely responsible for all aspects of your relationship with any other professionals (including, but not limited to, independently interviewing, negotiating fee schedules, providing direction, payment terms, hiring and firing, etc.), and You agree that First Command is not responsible for your decisions or liable for the results. First Command and Advisor will work in collaboration with your legal and tax professionals. 12. If We do what You tell us to, We are not responsible for the results; indemnity if We follow your directions. First Command and the Advisor will not be liable to You for what We do or fail to do if done in good faith in reliance on the information You have given or your instructions to Us. You agree that You will indemnify, or compensate, Us and the Advisor for losses, costs, damages, or expenses suffered, including reasonable attorneys’ fees, that result solely from any action We take based on your instructions to Us or the Advisor in providing advisory services to You and purchasing at your direction products We may recommend. These limitations on our liability do not relieve Us or the Advisor from our responsibility or liability to You that may exist under state or federal law. 18  13. Transfer (assignment). Neither You nor First Command may assign or transfer this Agreement or any part of it unless both You and First Command agree in writing to the assignment or transfer. This provision neither prohibits nor is intended to interfere with your right to transfer an account. 14. Your privacy. All of your private information that is collected as part of this Agreement, called nonpublic personal information, and all recommendations or suggestions will remain confidential. You authorize Us to share your nonpublic personal information with (1) Affiliated Companies, (2) Providers that give direct service to Us on your behalf, and (3) as otherwise permitted by law. We will use commercially reasonable efforts to have all Providers agree to protect your nonpublic personal information. For more information about our privacy practices, you may review the First Command Privacy Policy which is contained in the DOS. 15. Anti-money laundering representations. Fighting terrorism and illegal activity is the responsibility of all persons. The evidence of identity and all related information You have provided in connection with this Agreement must be true and correct. You must provide any information deemed necessary by Us in our sole discretion to comply with the U.S.A. Patriot Act, the First Command anti-money laundering program and related responsibilities. In the event of delay or failure by You to produce any information requested in this Agreement or required for verification purposes, We may refuse to act. You represent that neither You, nor any person controlling, controlled by, or under common control with You, nor any person having a beneficial interest in You or any company You represent related to this Agreement, is an individual, organization, or entity listed on the List of Specially Designated Nationals and Blocked Persons (the “OFAC Control List”) maintained by the U. S. Office of Foreign Assets Control (“OFAC”) (available at www.ustreas.gov/ofac/t11sdn.pdf), and that You are not investing and will not invest on behalf of or for the benefit of any individual, organization, or entity listed on the OFAC Control List. 16. Texas law controls this Agreement. This Agreement is governed by the laws of the State of Texas, U.S.A., without regard to Texas conflict of laws rules, and shall remain in full force and effect unless terminated as stated in Section ‘10’ of this Agreement. This Agreement is binding upon the persons that come to control your interests and those persons to whom You transfer this Agreement with our consent. 17. Amendments or changes to this Agreement. This Agreement may be amended or changed if We give You written notice or electronic notice of a change. Any such changes may only be done under applicable law and shall only be effective thirty (30) days after We mail written notice to You by U.S. mail to your last known address of record, or electronically deliver such notice to You pursuant to Your authorization. 18. Failure to enforce this Agreement does not prevent future enforcement. If We do not enforce a part of this Agreement in a given instance, that does not prevent Us from enforcing the same or another part in the future. 19. Investments are subject to the risks of the marketplace; limitation on our liability. Investments that You decide to make are subject to risks associated with investing in securities, including various market, currency, economic, political, and business risks. We do not guarantee the performance of your investments or guarantee that our investment advice or strategies or that of any Advisor will be successful or that your investment objectives will be met. Investment advice or recommendations provided by Us or any Advisor are largely a matter of professional judgment, and neither We nor any 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 with reasonable care. 19  20. What if there is a dispute between You and First Command? We will attempt to settle a dispute between You and First Command or a complaint You have relating to this Agreement by working closely with You. If You are not satisfied with our efforts, disputes or complaints will be referred to mandatory mediation under the Commercial Mediation Procedures of the American Arbitration Association. The mediation will be non-binding. If either You or First Command do not accept the result of the mediation, there may be agreement for binding arbitration. Where there is no agreement to arbitrate the dispute, either You or First Command will be free to pursue any remedy to settle the dispute or complaint including a lawsuit. No part of this dispute resolution paragraph is intended to diminish your rights under the Investment Advisers Act of 1940 or the law of your state of residence. 21. This IAA states all of the agreements between You and First Command. This Agreement states all of the matters upon which You and First Command have agreed. If a subject is not covered in writing in this Agreement then as between You and First Command it does not exist. This Agreement shall not become effective until both First Command and Client agree to its terms and conditions in writing. By signing below, First Command agrees to the terms and conditions of this Agreement. Tina Caddell Vice President, First Command Advisory Services, Inc. . 20  V. ELECTRONIC DELIVERY AGREEMENT By electing e-Delivery, you affirmatively consent and agree to permit First Command Brokerage Services, Inc. and First Command Advisory Services, Inc., their parent company and affiliated companies (together “First Command”) to enter into transactions, make disclosures and provide notices to you in electronic form instead of in writing for purposes of entering into agreements with First Command and/or receiving delivery of communications and documents from First Command (“Account Communications”). Your consent shall apply to all Account Communications including, but not limited to, the Description of Services Brochure; First Command disclosure documents; financial plans; account agreements; product offering documents; applications; application supplements and addendums; account statements; trade confirmations; tax documents; policy contracts; customer correspondence; privacy notices; performance reports; Notifications; notices concerning any change in the terms of your relationship or agreements; and/or other documents as they may be made available to you electronically. “Notifications” means disclosures and other information related to your account including, without limitation, prospectus, prospectus supplements, quarterly, semi-annual or annual shareholder reports, proxy statements, offering documents, disclosure brochures, and legal and regulatory notices and documents permitted by law to be sent electronically, in electronic format when available instead of receiving paper copies. “Authorized User” means any person that you have authorized to be provided a User ID which enables access to your account online. Account Communications are being made available to you in electronic form as described herein in lieu of mailing them to you in paper form. Account Communications will be made available to you online via a website maintained by Pershing LLC (“Pershing”) on behalf of First Command (the “Website”). Account Communications will be available in portable document format (PDF). You may request a mailed copy of your Account Communications by contacting your Financial Advisor. Unless otherwise required by law, Account Communications will generally be sent to you via email and may include an attachment or a web link to allow you to retrieve information. You may also need to register and access First Command’s web portal, Command CenterTM, or another website made available to you by First Command, to retrieve information. Account Communications will be sent to the email address that you have provided to us. You agree to update your email address by notifying us in case of any changes. You may view and verify your email addresses via the Website and change the email address(es) through the Website or by contacting First Command. You further agree that electronic delivery of the Account Communications is deemed accepted, regardless of whether you access or view a particular Account Communication document. You acknowledge that any Authorized User of your account are able to make changes to the electronic delivery settings for your account, and You agree to accept responsibility for such changes. You affirm that you have provided a valid electronic mail (email) address, have access to the Internet and are at least 18 years of age. You also affirm that you have installed a recent version of Adobe Acrobat Reader or other software application that allows you to view and print your Account Communications. You may print or save your Account Communications at any time. You can download Adobe Acrobat Reader at no charge by visiting www.adobe.com. In the event of an email notification failure as defined by Pershing as three consecutive undeliverable email notification, Pershing may discontinue electronic delivery and mail your Account Communications in paper form until You re-enroll through the Website. A paper surcharge fee can be charged to your account for account notifications in paper form. If You lose access to the Website, You should contact First Command to have access reinstated. 21  You expressly agree and acknowledge that your use and any Authorized User’s use of the Website is subject to additional terms and conditions that are posted on the Website including, without limitation, any disclaimers of warranties and other notices therein. Such terms and conditions may be amended from time to time by posting them on the Website. Continued use of the Website by You or your Authorized User will constitute your acceptance of the then- current terms and conditions. You agree that you are solely responsible for (a) safeguarding and keeping confidential your password and user IDs that You and your Authorized Users use to access the Website and any information that is retrieved from the Website. You agree that You and your Authorized User will only access the Website from devices with industry standard anti-virus / anti-malware protection. You agree to accept responsibility for all activities that occur under such user IDs or password(s). You agree to immediately notify First Command if: (1) the passwords or user IDs are lost or stolen, or (2) You become aware of any unauthorized use of the passwords, user IDs, or access to your accounts that may be related to your use of the Website. You agree that the providers of the Website are not liable for any loss or damage arising from any activity that occurs via the use of your password and/or user ID. This Electronic Delivery Agreement is effective until revoked by you or First Command. You may revoke your consent for electronic delivery and resume receiving paper Account Communications by changing your delivery preferences by following instructions on the website, or by contacting First Command directly for assistance. First Command at 800.443.2104 or write First Command at PO Box 2387, Fort Worth, TX 76113. By agreeing to this Electronic Delivery Agreement, you acknowledge that you have carefully read, understand, and agree to the terms and conditions herein; represent and warrant that you are authorized to make this election; and indicate your informed and affirmative consent to the termination of paper copies and the transmission of an electronic notice to a designated email address(es) as the only notice sent when Account Communications become available. Your request shall apply to all accounts for which you are an owner, joint owner, custodian, trustee, or participant. 22  VI. GLOSSARY OF TERMS AMS – Asset Management Solutions CFP® – Certified Financial Planner DOS – Description of Services Brochure FINRA – Financial Industry Regulatory Authority Foundations – Foundations Investment Program IAA – Investment Advisory Agreement IMA – Investment Management Agreement IMT – Investment Management Team NAV – Net Asset Value SIP – Select Investor Program TPS – Tailored Professional Services  APPENDIX A: DATA PRIVACY AND PROTECTION POLICY CORE POLICY FC-11 APPROVED DATE: 11/01/2023 LAST REVIEWED: 11/01/2023 Summary The purpose of this Data Privacy and Protection Policy (“Policy”) is to establish global principles for First Command Financial Services, Inc. and its wholly owned subsidiaries including First Command Brokerage Services, Inc., First Command Advisory Services, Inc., First Command Insurance Services, Inc., First Command Europe Ltd. and First Command Bank (together “First Command” or the “Company”) to follow in protecting and securing the privacy of confidential information, including, but not limited to personal information (as defined below). Applicability This Policy applies to all Home Office personnel, Registered Persons, Advisor Trainees, Associated Persons, and employees or independent contractors of registered persons with access to confidential information maintained by First Command Financial Services, Inc. and its wholly owned subsidiaries including First Command Financial Planning, Inc., First Command Advisory Services, Inc., First Command Insurance Services, Inc., First Command Europe Ltd. and First Command Bank (collectively referred to herein as “First Command”). Approval And Suggested Improvement The Risk Management Committee of the Board of Directors of First Command Financial Services, Inc. has approved this Policy. The proponents of this Policy are the Chief Legal Officer and the Chief Data Privacy Officer. Comments and suggested improvements to this Policy should be directed to those individuals. TABLE OF CONTENTS 1. Administration and Implementation ____________________________________________________ 2 2. First Command Privacy Philosophy ____________________________________________________ 2 3. Processing of Personal Information ____________________________________________________ 3 4. Chief Data Privacy Officer ____________________________________________________________ 3 5. Data Privacy Manager _______________________________________________________________ 4 6. Enforcement ______________________________________________________________________ 4 7. Record Retention___________________________________________________________________ 4 8. Review __________________________________________________________________________ 4 9. First Command Privacy Notice _______________________________________________________ 5  1. ADMINISTRATION AND IMPLEMENTATION The Chief Legal Officer and the Chief Data Privacy Officer will be responsible for the implementation and administration of this Policy. First Command has determined that it is in the interest of the Company to ensure that an appropriate group of senior leaders meet regularly to engage in specific activities that support and enhance the Company’s Data Privacy Program (“Privacy Program”). Therefore, the Company has established a Data Privacy Committee (“DPC”). The DPC will consist of the following individuals:  Chief Legal Officer  Chief Data Privacy Officer  Data Privacy Manager  Key Stakeholders necessary to support and enhance the Privacy Program The DPC will assist the Chief Legal Officer and Chief Data Privacy Officer with:  developing policies and procedures to protect personal information.  providing strategic guidance and oversight to the Privacy Program  training and providing advice and counsel on privacy and data protection matters.  monitoring compliance with privacy and data protection laws and regulations  communicating with legal and regulatory authorities on privacy and data protection matters. 2. FIRST COMMAND PRIVACY PHILOSOPHY The Company values and respects the personal data and rights of its Clients, Employees, Independent Contractor Advisors, District Advisors, Prospects, Business Partners, and Third-Party Vendors. It is committed to the protection and responsible use of the information it collects. The Company endeavors to ensure the proper collection, use, disclosure, and disposition of such information by implementing technology, training, policies and procedures and by adhering to the Fair Information Practices Principles (“FIPPs”) framework, including the following 8 principles: 1. The Collection Limitation Principle. There should be limits to the collection of personal data and any such data should be obtained by lawful and fair means and, where appropriate, with the knowledge or consent of the data subject. 2. The Data Quality Principle. Personal data should be relevant to the purposes for which it is to be used and, to the extent necessary for those purposes, should be accurate, complete, and kept up to date. 3. The Purpose Specification Principle. The purposes for which personal data are collected should be specified not later than at the time of data collection and the subsequent use limited to the fulfillment of those purposes or such others as are not incompatible with those purposes and as are specified on each occasion of change of purpose. 4. The Use Limitation Principle. Personal data should not be disclosed, made available or otherwise used for purposes other than those specified, except a) with the consent of the data subject, or b) by the authority of law. 5. The Security Safeguards Principle. Personal data should be protected by reasonable security safeguards against such risks as loss or unauthorized access, destruction, use, modification, or disclosure of data. 6. The Openness Principle. There should be a general policy of openness about developments, practices, and policies with respect to personal data. Means should be readily available of establishing the existence and nature of personal data and the main purposes of their use, as well as the identity and usual residence of the data controller.  7. The Individual Participation Principle. An individual should have the right: a. to obtain from a data controller, or otherwise, confirmation of whether, the data controller has data relating to him. b. to have data relating to him communicated to him, within a reasonable time, at a charge, if any, that is not excessive; in a reasonable manner, and in a form that is readily intelligible to him. c. to be given reasons if a request made under subparagraphs (a) and (b) is denied and to be able to challenge such denial. d. to challenge data relating to him and, if the challenge is successful, to have the data erased, rectified, completed, or amended. 8. The Accountability Principle. A data controller should be accountable for complying with measures which give effect to the principles stated above. 3. PROCESSING OF CONFIDENTIAL INFORMATION First Command will ensure responsible data processing and comply with all applicable data protection laws when transferring data within First Command and to third parties, including implementing appropriate technical and organizational security measures with respect to data transfers. See also FC-10, Information Security Policy and FC-8, Vendor Management Policy. 4. CHIEF DATA PRIVACY OFFICER The Chief Data Privacy Officer leads the Company’s Privacy Program and is responsible for:  Assessing privacy-related risks arising from processing operations for existing products and services  Communicating issues to senior-leadership, board, and regulators  Ensuring that data protection impact assessments are conducted on a periodic basis.  Works with Data Privacy Manager to improve the Company’s Privacy Maturity  Monitoring the effectiveness of privacy-related risk mitigation and compliance measures  Leading incident responses. 5. DATA PRIVACY MANAGER The Data Privacy Manager is responsible for the daily operations of the Company’s Privacy Program by ensuring all business processes and procedures adhere to the Company’s privacy policies and procedures. The main functions of the Data Privacy Manager are:  Assisting with the administration of this Policy and the policies and procedures adopted pursuant to it.  Conducting Privacy Impact Assessments to identify risks in new or changed business activities.  Developing and implementing a Roadmap that addresses controls for managing privacy compliance and promoting data breach preparedness.  Identifying privacy obligations for the Company  Identifying employee and client privacy risks  Driving privacy-related awareness and training  Communicating privacy objectives and considerations, both internally and externally.  Works with the Data Privacy Officer to improve the Company’s Privacy Maturity  Maintaining the register of processing operations of the Company is responsible for  Monitoring the Company’s compliance with relevant data privacy rules and regulations  Communicating and reviewing documents  6. ENFORCEMENT First Command reserves the right to take any steps deemed necessary to protect Confidential Information without prior notice, including terminating access to PI at any time. Disclosure of Confidential Information may result in severe damage to First Command. For that reason, employees, registered persons, and others covered by this Policy are cautioned that a violation of this Policy may result in disciplinary action, up to and including termination of employment or association with First Command. 7. DOCUMENT/DATA RETENTION AND DESTRUCTION A. Physical Documents The housing of confidential documents at any location, other than an approved First Command facility (e.g., Home Office, Field Office) is prohibited. Exceptions will be granted for approved business purposes assuming the following conditions are met: • Physical access to these documents must be necessary for the performance of the individual’s job responsibilities. • The documents must be secured at all times per guidelines in SOP 3-2 • This exception only lasts for the duration of the work being performed. When any of the three criteria are no longer met, all copies of documents must be returned to a First Command facility from where they originated or disposed of in accordance with First Command’s document destruction policies and procedures as outlined in SOP 08-03 Document Retention Program. B. Electronic Media The storage of confidential information on other than First Command approved methods, as outlined in SOP 3- 2, is prohibited. All documents or data created pursuant to this Policy will be retained in accordance with applicable laws and other applicable First Command policies and procedures outlined in SOP 08-03 8. REVIEW The Risk Management Committee of the Board of Directors of First Command Financial Services, Inc. will review this Policy periodically, at a minimum of annually, to ensure consistency with the regulatory and legal requirements applicable to First Command, First Command’s business needs, and strategic goals. 9. EXTERNAL FIRST COMMAND PRIVACY NOTICE First Command respects the privacy of our clients and is committed to safeguarding their information. This Privacy Notice is designed to explain what type of information we collect, how we collect it, how it is used, who we share it with, and under what circumstances it will be shared. First Command’s Privacy Notice applies to First Command Financial Services, Inc., and its wholly owned subsidiary companies, including First Command Brokerage Service, Inc., First Command Advisory Services, Inc., First Command Insurance Services, Inc., First Command Bank and First Command Europe Ltd. (together the “First Command Family of Companies”). A. Collection Of Information We collect information about you to provide you with exceptional customer service, to better understand your needs, and to manage our business and risks. We collect information about you from the following sources:  Directly from you on forms, applications, and other similar documents; via the Internet; by telephone; or otherwise. Examples of this type of information include your name, address, names of family members, marital status, Social Security Number, employment information, and financial situation, etc.  From transactions with us or with companies through which we provide you products and services. For example, account balances, holdings, and transaction history (bank, mutual fund, annuity, etc.); insurance coverages, limits, rates, beneficiaries, and claims history.   From consumer report agencies, such as information relating to your creditworthiness, your credit score, credit usage, and claims history.  From third parties to verify the information you have given us and protect against fraudulent activity as required by law. B. Protecting Your Information Keeping your information secure is one of our most important responsibilities. We maintain physical, electronic and procedural safeguards that comply with federal regulations to protect your information. We limit access to customer information to those employees and others who have a business reason to know this information. We maintain strict internal policies against unauthorized disclosure or use of client information. Even if you are no longer a customer, we will treat your information in the same manner as if you were still a customer. C. Information Sharing with Third Parties Individuals or companies outside the First Command Family of Companies are considered third parties. We will not share your information with third parties for the purpose of marketing their products or services to you. We may share the information we collect about you as described above with third parties for other purposes, but only as permitted or required by law. For example, we may share information:  With service providers that assist us with a variety of business activities, including marketing on our behalf, customer service, account administration, online support, and research.  To protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability.  To process your requests or provide services regarding a financial product or service you request or authorize (such as mutual funds, financial planning services, insurance, deposit accounts, loans, credit cards, etc.). Companies with whom we may share your information in this regard include mutual fund companies, insurance companies, banks, and transfer agents which maintain your accounts.  With government entities in response to subpoenas or regulatory requirements.  With consumer reporting agencies and/or credit bureaus.  Pursuant to your written consent. All third parties with whom we share your information are required to protect the confidentiality of the information provided by us and may only disclose such information as permitted by law. D. Information Sharing Within The First Command Family Of Companies The reason you share your information with us is so that we may use your information to determine whether the investment, insurance and banking products and services we offer are a good fit for you and to provide you with recommendations and service for these products and services. In order to accomplish this objective and provide the recommendations and services you request; we share your information within the First Command Family of Companies to ensure that the recommendations and services we provide consider your complete financial picture and complement each other. Federal law allows you to direct us:  not to share information about your creditworthiness received from you or others within the First Command Family of Companies, and/or  not to market products or services to you based on information received from one of our other companies. These limitations may not apply in certain circumstances permitted by law, such as if you already have a pre- existing relationship with the company desiring to market its products or services to you. Importantly, should you choose to exercise your right to limit our ability to share your information among the First Command Family of Companies, it may have an impact on our ability to provide you with the best services or products. To inform us of your choices, you may write or email: First Command’s Data Privacy Department, Attn. Privacy Notice, 1 FirstComm Plaza, Fort Worth, TX 76109-4999, or DataPrivacy@firstcommand.com. Alternatively, you may call us at 800- 443-2104. Your decision will not expire until you revoke it in writing. If you have a joint account, your direction will apply only to you unless you specifically state that your direction is on behalf of all joint account owners.  E. Protecting Medical And Health Information We do not share any medical or health information with third parties or within the First Command Family of Companies, except as necessary to process transactions or services you have requested or initiated or as otherwise permitted by law. For example, we may share medical or health information you have provided to us in connection with an insurance application with insurance companies to determine your eligibility or for underwriting purposes. F. Making Sure Your Information Is Accurate You have the right to review the information we have collected about you to ensure that it is accurate and current. You can also request corrections to any personal information maintained by us. To review the information we collect about you, you may submit a request in writing or via email to: First Command’s Data Privacy Department, Attn. Privacy Notice, 1 FirstComm Plaza, Fort Worth, TX 76109-4999, or DataPrivacy@firstcommand.com. Alternatively, you may call us at 800- 443-2104. You must describe the kind of information you want to review and include your full name, address, telephone number, and date of birth. Upon receipt of your request, we will contact you within 30 business days to describe what information is available for your review. We will not provide information that is privileged, confidential and/or exempt from disclosure under applicable law. To rectify information about you, send a written request as described above, explaining your desired correction. Upon receipt of your request, we will contact you within 30 business days to inform you whether we will make the correction or tell you why we will not. We cannot correct consumer report information, such as your credit report. To do this, you must contact the consumer report agency that provided it. This Privacy Notice replaces any previous notices provided to you by us about the privacy, security, and protection of your information. We reserve the right to amend this notice as we deem necessary or appropriate due to legal requirements or changes in our business practices. We will notify you of any changes to our Privacy Notice as required by law. If you have any questions about the privacy, security and protection of your information, you may write or email: First Command’s Data Privacy Department, Attn. Privacy Notice, 1 FirstComm Plaza, Fort Worth, TX 76109- 4999, or DataPrivacy@firstcommand.com. Or call us at 800- 443-2104. Last Updated: This Privacy Notice was last updated on November 1, 2023. AS APPROVED BY THE RISK MANAGEMENT COMMITTEE OF THE BOARD OF DIRECTORS OF FIRST COMMAND FINANCIAL SERVICES, INC. November 1, 2023  CLIENT CONSENT 1. Acknowledgement of Receipt Please check the appropriate response: I acknowledge receipt of First Command Advisory Services, Inc.’s Description of Services brochure (Form ADV Part 2A), Form CRS (Client Relationship Summary) and my Financial Advisor’s brochure supplement, and agree to the terms and conditions of the Investment Advisory Agreement in Section IV. ▪ TPS clients also must complete Form 852, TPS Service Form. I acknowledge receipt of my Financial Advisor’s brochure supplement. I am an existing client. I have previously received a Description of Services, Form CRS (Client Relationship Summary) and signed an Investment Advisory Agreement. 2. Consent A. Consent to Share Information: I authorize First Command Advisory Services, Inc., First Command Brokerage Services, Inc., First Command Bank, First Command Insurance Services Inc., and their affiliated companies and parent company (together “First Command”) to release my financial information to the following parties. This consent will remain in effect until such time as I instruct First Command otherwise in writing. Authorizations granted to the parties named below shall be considered in addition to any prior authorizations granted to other parties which have not been revoked. (Name of spouse/partner) Name of deliverables team member, other person, firm, etc. Relationship Name of deliverables team member, other person, firm, etc. Relationship B. Consent to Electronic Delivery: By checking this box, I agree to the Electronic Delivery Agreement in Section V, and authorize First Command to make disclosures, enter into transactions and provide notices to me in electronic form instead of in paper. I understand that if I check this box and do not provide you with an email address below, you will use the email address you have on file for me. I also understand I may update my email address at any time by contacting my Financial Advisor or by calling 800.443.2104. Client 1 Email: Client 2 Email: IMPORTANT! For communications related to brokerage accounts held at Pershing LLC and Asset Management Solutions (AMS) accounts: If you desire electronic delivery of Account Communications specific to your brokerage or AMS accounts, you must establish a Client Portal/Command Center account to retrieve these documents. If you have a current Client Portal/Command Center user id and email, you can update your electronic delivery methods on the Client Portal or by contacting your Financial Advisor or by calling 800.443.2104 to authorize enrollment or unenrollment in electronic delivery of Account Communications. The account can incur paper fee charges for Account Communications. 3. Signature  Client 1 Signature Last 4 Digits of SSN Client 1 Printed Name Date Last 4 Digits of SSN  Client 2 Signature Date Client 2 Printed Name Advisor Name Number Distribution Guidance: 1) Scan and index signed form into ACE (Content Type=Compliance, Form Name=850). 2) If Section 2B is completed, update client’s e-Delivery information in CRM. Do not fax this form to the Home Office. 120423 850 (12/23) Supersedes 850 (5/23) which should be destroyed. ©2023 First Command Financial Services, Inc.  TPS SERVICE FORM 1. Delivery of Services planned meetings Below are the services both Advisor and Client expect to be delivered during the service period. Actual services provided may vary depending on a variety of factors, including the Client’s desires, needs and engagement. (Check all that apply) ❑ ❑ Complexity issues to be addressed: Asset Allocation Business Planning Cash Flow Planning Debt Liquidation Planning Education Planning Trust/Estate Planning Goal Setting Investment Planning Net Worth Analysis Retirement Planning Risk Management Special Needs Child Survivor Needs Planning TDT – Tax Triangle Other: ❑ Delivery of a written financial plan (required for initial TPS term of service) 2. Payment For Service Fees Fee............................. $ Discount ..................... $ Tax ............................. $ (if applicable) (if applicable) ❑ New Fee Range (ex. Gold, Platinum, Platinum Premium): TOTAL PAYMENT .... $ I authorize First Command Advisory Services, Inc. to process a one-time payment as follows: Check (payable to First Command Advisory Services, Inc.; please include a copy of this form with payment) Name on Check: Check Number: Credit / Debit Card: Visa MasterCard American Express ) Discover → (ZIP Code: ** Note: Enter credit card information into Shopping Cart directly. Do not write credit card information on this form.** 3. Notes 4. Signatures By signing below, I acknowledge that I have entered into an Investment Advisory Agreement with First Command Advisory Services, Inc., which contains the terms and conditions applicable to the Tailored Professional Services (TPS) program.  Client 1 Signature Date Client 1 Printed Name Last 4 Digits of SSN  Client 2 Signature Date Client 2 Printed Name Last 4 Digits of SSN Advisor Name Number Distribution Instructions: Scan signed form into CDM. If payment is by check, please include a photocopy of this form with check sent to Home Office. DA Initials Date 120423 852 (12/23) Supersedes 852 (10/22) which should be destroyed. © 2023First Command Financial Services, Inc.  CLIENT IDENTIFICATION VERIFICATION To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account. This form must be completed while the client is physically in the presence of the Advisor and the Advisor verifies the identity of the client using a government issued ID. The form may not be emailed, faxed or mailed to a client to complete outside the presence of the Advisor. Client Information Printed Name of Person Being Verified Printed Name of Person Being Verified Client Identification Check here if client is active duty military (Reminder: Do not photocopy a military ID) CLIENT’S ID CLIENT’S ID Instructions: Instructions: In this space, tape client’s valid government- issued (non-military) ID and photocopy, or complete the information below. In this space, tape client’s valid government- issued (non-military) ID and photocopy, or complete the information below. Document used to verify identity: Document used to verify identity: ❑ Drivers License ❑ Drivers License ❑ Military I.D. ❑ Military I.D. ❑ Passport ❑ Passport ❑ Other: ❑ Other: Issued By: Number: Issued By: Number: Issue Date: Exp. Date: Issue Date: Exp. Date: U.S. Citizen: Yes No U.S. Citizen: Yes No First Command Advisor Information As the First Command Financial Advisor for the person(s) identified above, I hereby state that I personally verified the identity of the above-named person(s) using valid government-issued document(s) as recorded on this form and these documents were personally provided to me by such person(s). Advisor’s Name and Number  Advisor’s Signature Date 120423 811-E (12/23) Supersedes 811-E (10/22) which should be destroyed. © 2023 First Command Financial Services, Inc. Pursuant to CFR 103.121 other required CIP information, such as social security number, address and date of birth, are collected on Form 1500, Planning Organizer.  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 120423 850 (12/23) Supersedes 850 (5/23) which should be destroyed. © 2023 First Command Financial Services, Inc., parent of First Command Advisory Services, Inc. 

Asset Management SolutionsSM Form ADV Part 2A, Appendix 1 “Wrap Fee Program Brochure” 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 This Wrap Fee Program Brochure is dated December 18, 2023. 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.  Material Changes This Wrap Fee Program Brochure is dated December 18, 2023. We may update this brochure at any time. We will notify you whenever there are material changes to our disclosures in this brochure. In addition, we will annually send you a summary of material changes along with an offer to provide you with a current copy of this brochure. We have not made any changes to our disclosures in this Wrap Fee Program Brochure since our last annual update dated October 2022. You may request a current copy of this Wrap Fee Program Brochure at any time by contacting your Financial Advisor, calling First Command’s Home Office at 800.443.2104 (overseas, call 817.731.8621) or visiting www.firstcommand.com. 1  Table of Contents I. SERVICES, FEES AND COMPENSATION........................................................................................ 3 Introduction ........................................................................................................................................ 3 Overview of the AMS Program ........................................................................................................... 3 Model Portfolios and Implementation Strategies ................................................................................. 4 Management of Your AMS Program Account ..................................................................................... 4 Discretion and Restrictions ................................................................................................................. 4 Services Provided .............................................................................................................................. 4 Fees and Compensation .................................................................................................................... 5 Choosing Mutual Funds and ETFs to Hold in the AMS Program ......................................................... 9 Choosing Mutual Fund Share Classes ............................................................................................. 10 Execution of Trades ......................................................................................................................... 10 Opening a New Account in the AMS Program .................................................................................. 10 Assets Transferred In Kind into an AMS Account ............................................................................. 10 Liquidating Funds from Your AMS Account ...................................................................................... 10 II. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ............................................................... 11 Account Minimums .......................................................................................................................... 11 Types of Clients ............................................................................................................................... 11 III. PORTFOLIO MANAGER SELECTION AND EVALUATION ............................................................ 11 Other Advisory Services ................................................................................................................... 12 Assets Under Management .............................................................................................................. 13 Performance Based Fees and Side-By-Side Management ............................................................... 13 Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 13 Voting Client Securities .................................................................................................................... 14 IV. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ............................................... 14 V. CLIENT CONTACT WITH PORTFOLIO MANAGERS ..................................................................... 14 VI. ADDITIONAL INFORMATION ......................................................................................................... 15 Disciplinary Information .................................................................................................................... 15 Other Financial Industry Activities and Affiliations ............................................................................. 15 Code of Ethics, Participation or Interest in Clients Transactions and Personal Trading ...................... 15 Brokerage Practices ......................................................................................................................... 16 Review of Accounts ......................................................................................................................... 16 Client Referrals and Other Compensation ........................................................................................ 16 Custody ........................................................................................................................................... 17 Investment Discretion....................................................................................................................... 17 Financial Information ........................................................................................................................ 17 VII. BROCHURE SUPPLEMENTS FOR OUR INVESTMENT MANAGEMENT TEAM ........................... 18 Educational Background and Business Experience .......................................................................... 18 Disciplinary Information .................................................................................................................... 20 Other Business Activities.................................................................................................................. 21 Additional Compensation ................................................................................................................. 21 Supervision ...................................................................................................................................... 21 Our Financial Advisors ..................................................................................................................... 21 VIII. IMPORTANT INFORMATION RELATED TO RETIREMENT ACCOUNTS ........................... 22 2  I. SERVICES, FEES AND COMPENSATION Introduction First Command Advisory Services, Inc. (“First Command”) is registered with the SEC as an investment adviser and has filed notices in all states where filings are required. The disclosures in this brochure are formatted to comply with the SEC’s Form ADV Part 2A, Appendix 1, which governs the preparation of this document. First Command Advisory Services, Inc. is the sponsor and investment adviser which offers and administers the Asset Management Solutions (“AMS”) program. Our services are provided to you through investment adviser representatives which we refer to as Financial Advisors (“Advisor”). As a “wrap fee program,” we provide investment advisory services, brokerage and non-IRA custody services for a single, inclusive fee (i.e., wrap fee). To enroll in AMS, you will be required to complete our new account agreement and agree to our Investment Management Agreement, which contains additional terms and conditions governing your AMS account and your relationship with us. All references to “you” and “your” in this brochure refer to prospective and existing AMS program clients of First Command. References to “we,” “us” or “our” may collectively refer to First Command and/or your Advisor. We also offer other investment advisory services, including financial planning services, not discussed in this brochure. You may request a copy of our Description of Services brochure (i.e., Form ADV, Part 2A brochure) if you wish to learn more about these other services. Overview of the AMS Program As part of the AMS program, we offer two services: the Foundations Investment Program (“Foundations”) and the Select Investor Program (“SIP”). The AMS program enables us to provide you with customized investment portfolio options (“Model Portfolios”) composed of mutual funds and/or exchange-traded funds (“Model Portfolios”) managed by our Investment Management Team (“IMT”). Your 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 sell your investments), risk tolerance (certain investments are riskier than others) and other relevant factors. Based on this information, your Advisor will then propose an overall strategy that includes asset allocation (this is the practice of attempting to limit risk by investing among a range of different asset classes) and investment portfolio recommendations in the form of one or more Model Portfolios, with each Model Portfolio to be managed in a separate account within either Foundations or SIP. Your Advisor will periodically meet with you to discuss any changes to your financial situation, goals and objectives to ensure that the Model Portfolio upon which your investments are based continues to meet your investment needs. Each of the Model Portfolios are designed using asset allocation and diversification strategies to help you pursue investment opportunities and manage risk. For some Model Portfolios, municipal bond fund options are available. Model Portfolios may be added or discontinued over time. The IMT determines which mutual funds and/or exchange-traded funds to include in the Model Portfolios and will periodically adjust and rebalance Model Portfolio investments to remain consistent with their investment strategies. Any modifications to the Model Portfolios by the IMT are effected through the sale of securities in your account, which may have tax ramifications for you based on the transactions that result. While the IMT is responsible for managing the Model Portfolios which are recommended to you by your Advisor, the IMT does not possess knowledge of your individual information or investment goals and objectives or provide personalized investment advice to you. You remain the owner of all securities held in your Model Portfolio account and have all ownership rights associated with these securities. This brochure provides you with a general overview of our responsibilities. You can obtain more specific information about the process by which Model Portfolios are constructed, the mutual funds and exchange- traded funds currently held within each of the Model Portfolios, how investment strategies are carried out, options to customize your investments, the IMT, investment returns, and other information through discussion with your Advisor. We encourage you to review this brochure carefully and to talk to your Advisor to make certain you fully understand our investment process and the features available to you as a participant in the AMS program. 3  Model Portfolios and Implementation Strategies As discussed above, the Model Portfolios will consist of mutual funds and/or exchange-traded funds (“ETFs”) selected by the IMT. A mutual fund is a pooled investment company that brings together money from many people which it invests in stocks, bonds/debt instruments or other assets. If your assets are invested in mutual funds, First Command will act as your agent and not as a dealer for the mutual fund issuing the shares. An exchange-traded fund (also called an “ETF”) is an open-ended investment product that is listed on an exchange and whose shares are traded like ordinary shares of a public company. Unlike traditional mutual funds, which are priced at the end of the day, ETFs can be bought and sold throughout the trading day at the prevailing price. ETFs may be passively managed investments aiming to replicate the performance of a given market, generally by tracking an underlying benchmark index (an “index” is a method of tracking the overall investment performance of a large category of selected securities, like stocks or bonds), or may be actively managed (where a manager selects underlying investments based on a specified investment strategy). Even with respect to ETFs that are designed to track the performance of a specific index, there is no assurance that the price and investment return of the specified index can be fully matched. ETFs may be used to gain broad exposure and diversification of investments held by a client, achieve lower expenses, facilitate increased selling capability, and attain improved tax efficiency. Management of Your AMS Program Account The Model Portfolios are developed and managed by the IMT. Our Investment Oversight Committee will periodically review the ongoing performance of AMS Model Portfolios. The IMT will periodically assess and rebalance the asset weightings within the Model Portfolios to realign their underlying investments. Fluctuations in the value of investments over certain time periods (known as “dispersion”) may occur between the holdings and performance of the Model Portfolios and the actual AMS program accounts that are maintained by clients based on the Model Portfolios. Account dispersion may be due to differences in account size, cash flow, and the timing of securities trades placed by the IMT, certain trading and system limitations, and other factors. Discretion and Restrictions To participate in the AMS program, you must grant us discretionary authority to manage your invested assets by agreeing to our Investment Management Agreement (“IMA”) at account opening. Neither you nor First Command may transact in your AMS 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. ▪ You may direct that the payment of lump sum withdrawals be from the investment assets instead of from the cash equivalent position within your account. ▪ 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.) ▪ You may direct that a particular sum be held in a cash equivalent position for a specified period of time. You should consult with your Financial Advisor prior to imposing these restrictions. Other than by choosing your Model Portfolios and as described in the IMA, you may not place other restrictions on investing in your account, including imposing restrictions on investing in certain securities or types of securities. 4  Services Provided The following services are included as part of Foundations and SIP: ▪ Asset management as described above. ▪ 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. ▪ One-time or periodic third-party distributions upon your written request. Signature guarantee may be required. In addition to the above services, SIP accounts also allow you to take advantage of lower wrap fees and additional diversification (i.e., additional mutual funds, ETFs and additional asset classes in the Model Portfolio you select). Fees and Compensation The following fees and compensation are applicable to AMS program accounts: a) Wrap Fees. This is the fee we charge for the day-to-day asset management, oversight and trading in your AMS account. Fees are non-negotiable. Fees are assessed quarterly in arrears based on the average daily balance of assets under management in your account. Fees will be deducted from your account assets when due. The wrap fee that we charge pays for our advisory services as well as costs for execution of securities transactions and other services. Foundations Investment Program The annual wrap fee for Foundations will be calculated as follows: Annual Fee Assets Under Management 1.35% Up to $20,000 and until $50,000 Foundations accounts valued at $50,000 or greater in assets under management at the end of each month will be automatically converted (without additional notice) into SIP accounts to allow you to take advantage of the lower fee and additional diversification (i.e., additional mutual funds, ETFs and additional asset classes) associated with SIP. This conversion will take place no later than 30 days from the end of the month in which your Foundations account becomes valued at $50,000 or greater in assets under management. Upon conversion, you will receive a transaction statement and trade confirmations (unless you have elected trade confirmation suppression) which will detail the purchases and sales made by First Command to convert your Foundations account into a SIP account. The conversion from a Foundations account to a SIP account may be a taxable event in a non-tax qualified account. Select Investor Program The annual wrap fee for SIP will be calculated as follows: Annual Fee 1.10% 0.85% 0.70% 0.50% Assets Under Management 1.25% Up to $250,000 Of the Next $250,001 – $500,000 Of the Next $500,001 – $1 million Plus Of the Next $1,000,001 – $2 million Plus Of the Next $2 million and greater You may aggregate assets you have in Foundations and/or SIP for purposes of qualifying for a lower annual fee. Assets may be aggregated regardless of whether you invest only in Foundations, only in SIP, or any combination of Foundations and SIP. 5  If you invest in any combination of Foundations or SIP, your wrap fees will be calculated using a blended fee structure. We will: (1) first calculate the fee that would result if all assets were held in each program; (2) and then determine the percentage of assets held in each program compared to all AMS assets; (3) finally, the percentage realized for each program in step ‘(2)’ will be applied to the fee determined for that program in step ‘(1)’ to arrive at the final prorated Foundations and SIP wrap fees. We reserve the right to maintain prior fee schedules for existing clients and to offer fee discounts to our employees or employees of our affiliates. b) Fees and Expenses Outside the Wrap Fee. Fees for Certain Requested Services and Specific Account Actions. All securities and brokerage transactions in the AMS program are effected by First Command Brokerage Services, Inc., as an introducing broker-dealer. As described above, you will not pay a separate fee for brokerage expenses incurred in your account (i.e., commissions, ticket charges, etc.). First Command Brokerage Services, Inc. incurs certain fees pursuant to its clearing relationship with Pershing LLC related to processing requested services and facilitating specific administrative actions for your AMS account. Pershing LLC is the firm that is responsible for custodianship of assets and execution and settlement of all trades within the AMS program. These fees are passed along to you after being adjusted to take into account First Command Brokerage Services, Inc.’s compensation for assisting with the service or action. First Command Brokerage Services, Inc., at its discretion, marks-up the various fees detailed below or that are assessed by Pershing and paid by clients. FCBS decides how much and which fees will be marked up. Not all brokerage firm’s markup these or other fees. The markup on these fees generates additional revenue for First Command Brokerage Services, Inc. Markups on these types of fees are a conflict of interest. Certain fees 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 that are provided, or the positions that are held in the account. Below is a schedule of such fees and how much you will be charged: Returned ACH Fee ............................. $30.00 Stop Payment Fee .............................. $20.00 ACAT Processing Fee ......................... $90.00 Wire Fee (U.S.) ................................... $25.00 Wire Fee (Foreign) .............................. $30.00 Courier Fees: Overnight Standard ...................... $12.00 Saturday ...................................... $18.00 Overnight Foreign......................... $25.00 Returned Check Fee .................... $30.00 Paper Surcharge Fees: Transaction Statements. ....................... $.75 each Trade Confirmations. ............................ $.75 each Paper Surcharge feed is effective through 12/31/2023. See Paper Subscription Fee for updated fee effective 01/01/2024. Paper Subscription Fee Effective 01/01/2024: Transaction Statements, Trade Confirmations, and Account Notifications Monthly Fee charged Quarterly ……. $2.00 Accounts must be enrolled in e-Delivery of all three document types (Account Statements, Trade Confirmations, and Account notifications) to avoid the monthly paper subscription fee. Tax Document Fee Effective 01/01/2024: Annual Fee ......................................... $10.00 If enrolled in the monthly paper subscription on 12/31, the annual Tax Document Fee will not apply for tax documents for the prior year. The paper fee will accrue as of December 31st and assessed in March. 6  Other fees and charges not listed above may apply depending on the services and account actions requested by you. These fees and charges will be disclosed to you on your transaction statements. Should you have any questions, please do not hesitate to contact us. The above fees and charges are not shared by Pershing LLC or First Command Brokerage Services, Inc. with First Command Advisory Services, Inc. or your Advisor. IRA Custodial Fees. If you own an IRA account within the AMS program, First Command Bank will serve as your IRA custodian. First Command Bank will charge the following fees for the administrative services it performs as your IRA custodian: Annual Maintenance Fee: ▪ $35 per Traditional IRA, Roth IRA, SEP IRA or Coverdell ESA account. ▪ $50 per SARSEP or SIMPLE IRA account. First Command Bank will waive the annual maintenance fee for Traditional and Roth IRA accounts in excess of $250,000. The account value will be calculated as of September 30 each calendar year. (The waiver shall not apply to the other types of IRA accounts listed above.) Termination Fee: ▪ $75 per IRA account First Command Bank will share the above IRA Custodial fees with First Command Brokerage Services, Inc. and Pershing LLC in consideration for the services provided by these entities to support First Command Bank as custodian of your IRA. Neither First Command Advisory Services, Inc. nor your Advisor receives any portion of the IRA custodial fees described above. c) Indirect Costs of Mutual Funds and ETFs. 1) Mutual Fund Related Costs. First Command will not receive any compensation from a mutual fund company related to the purchase and holding of mutual funds in the AMS 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 in the AMS program 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 First Command or your Advisor, or by visiting the fund’s website at any time at no cost. These expenses may include, but are not limited to, fund operating expenses, management fees, distribution/service fees and/or redemption fees (including short-term trading redemption fees). The internal expenses of the underlying mutual funds will typically range from 0.5% to 1.5% of your assets annually and are in addition to the AMS and other fees discussed above. The internal expenses of the underlying mutual funds can have a negative impact on your investment rate of return. ▪ Sales Charges and 12b-1 Fees. First Command will not select or hold mutual funds in the AMS program that pay front-end or back-end sales charges or 12b-1 fees. All mutual fund shares held in the AMS program will be purchased at Net Asset Value (“NAV”). Therefore, sales charges and 12b-1 fees will not impact the rate or return of your investments in the AMS program. 2) ETF Related Costs and Expenses. First Command will not receive any compensation related to the purchase and holding of ETFs in the AMS program. However, you should be aware of the following fees, costs, and expenses and their impact on your investment rate or return: 7  ▪ Internal Expenses of ETFs. Assets invested in the AMS program 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 First Command or your Advisor, or by visiting the ETF’s website at any time at no cost. These expenses may 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. The internal expenses of the ETF can have a negative impact on your investment rate of return. ▪ Bid-Ask Spread. You will also incur costs associated with trading ETFs 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. Pershing LLC, our clearing firm, is responsible for the best execution of trades in ETFs. The bid/ask spread of the ETF can have a negative impact on your investment rate of return. ▪ Other Costs and Expenses. First Command 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 LLC related to the purchase or holding of ETFs in AMS accounts. d) Revenue Sharing. Neither the distributors of mutual funds or ETFs nor Pershing LLC pay revenue sharing to First Command Brokerage Services, Inc. or First Command Advisory Services, Inc. for mutual fund or ETF assets held within the AMS program. However, for assets held in brokerage accounts (which are commission- based accounts), First Command Brokerage Services, Inc. receives payments for, marketing support, client service and training we provide on behalf of certain mutual fund companies. Currently, Invesco, Fidelity, Amundi Pioneer, Franklin Templeton, and Blackrock pay fees that range from 0.01% to 0.15% of net assets invested and/or fund sales to us. American Funds does not pay us revenue sharing. BlackRock, Inc. currently pays First Command Brokerage Services, Inc. an annual sponsorship payment of $200,000 for sponsorship benefits at training and education events for our Advisors, including our Annual Advisor Conference. Other distributors of mutual funds or ETFs held within the AMS program will also occasionally sponsor or offer reimbursement for costs related to: ▪ their participation in training and/or education sessions that we conduct for our 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”). Additionally, MFS Fund Distributors, Inc. pays First Command Brokerage Services, Inc. an annual flat fee of $550,000 in consideration for First Command Brokerage Services, Inc. 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 First Command Advisory Services, Inc. or your Advisor. Your Advisor therefore does not have an incentive to consider such payments when deciding whether to recommend AMS or which specific AMS Model Portfolio to recommend. 8  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 the AMS program. We recognize that sponsorship payments and marketing support service fees create a conflict of interest as such payments create an incentive for us to include in AMS Model Portfolios mutual funds and ETFs from distributors that make such payments over other distributors that do not. This conflict is disclosed to you in this brochure. In order to address this conflict, we maintain policies and procedures to ensure that sponsorship payments and marketing support service fees are not a factor in deciding which funds and ETFs to hold within AMS Model Portfolios. We recognize our fiduciary duty and base our decisions on what serves our clients’ best interests. e) Overall Cost. You have the option to purchase products similar to the AMS program from other financial services firms. These products may be available at lower or higher overall costs. You may also be able to purchase many of the mutual funds and ETFs held within the AMS program without participating in the AMS program. It may cost more or less to purchase such mutual funds and ETFs separately depending on the funds, share classes and ETFs that are available to you outside of the AMS program. Some factors that bear upon the relative cost of the AMS program in comparison to other investment options are: ▪ ability for you to purchase fund shares outside of the AMS program at NAV based on existing mutual fund relationships; ▪ ability for you to purchase mutual fund share classes with lower underlying expenses (e.g., an institutional share class with higher minimum initial investment limits); ability for you to purchase ETFs outside of the AMS program without incurring brokerage commissions; ▪ elimination of separate fees for execution of trades; ▪ payment of wrap fee; and ▪ 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 alternative with lower fees than moving those assets into the AMS program. In, addition, First Command maintains an agreement with Pershing’s affiliate, Lockwood Advisors, Inc. (“Lockwood”), an SEC registered investment adviser and broker-dealer, to assist First Command with the performance of specific managed account services in the AMS program. Through this arrangement, Lockwood provides First Command with access to Lockwood’s proprietary technology solutions, which aids First Command in the management of the AMS program. In addition, Lockwood performs certain operational services for First Command including, but not limited to, trading in client accounts; account reviews; model maintenance and creation; fee billing; account reconciliation; performance reporting; information systems training; branding services; money market program; and an ETF asset program. First Command pays Lockwood for these services and these services are an expense incurred by First Command for administering the AMS program. The fees charged by Lockwood for its services are based on the total aggregate asset value of the of the client assets serviced by Lockwood in the AMS program. These fees are based on a tiered schedule where when certain breakpoints are met for the total aggregate assets in the AMS program, the applicable fees for Lockwood’s services (expressed in basis points) are reduced. This cost structure is a conflict of interest because it incentivizes First Command to recommend client assets be held in the AMS program because it will reduce First Command’s costs for Lockwood’s services in connection with administering the AMS program. It is also a conflict of interest because we have an incentive to recommend that you increase your investment in your advisory account, as that allows First Command to pay Lockwood lower fees for its services. 9  f) Compensation to Your Advisor. First Command and your Advisor will each receive a portion of the wrap fee. (The other fees discussed above related to your AMS account are not shared with your Advisor, and, as such, your Advisor does not consider such fees when deciding which investments to recommend to you.) This compensation is paid to Advisors for consultation and other services to you. The amount paid to your 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 Advisor’s compensation may be more than if you had purchased the funds outside the program. Choosing Mutual Funds and ETFs to Hold in the AMS Program The IMT will choose mutual funds and ETFs for AMS Model Portfolios from the entire universe of funds that are available on the Pershing LLC platform. These funds may include mutual funds that participate in Pershing LLC’s mutual fund no-transaction-fee program (“NTF Program”) (e.g., FundVest® Focus and FundVest® Institutional mutual funds) as well as non-FundVest® mutual funds. First Command does not receive any revenue from using mutual funds on Pershing LLC’s mutual fund no-transaction-fee program versus non-FundVest® mutual funds, but First Command will not be charged transaction fees for buying and selling mutual funds in the NTF programs and this presents a conflict of interest (which is discussed below). The IMT will always choose mutual funds and ETFs for inclusion in an AMS Model Portfolio consistent with what serves our clients’ best interests. 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 this information and does not consider it a factor in its analysis. When the IMT conducts a search for a new mutual fund or ETF for inclusion in AMS 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. There may be times when mutual funds or ETFs on this short list are from First Command’s “Primary Fund Families.” The Primary Fund Families are: Invesco, Fidelity Advisor, Amundi Pioneer, Franklin Templeton, Blackrock, and MFS. First Command has long-standing, close business relationships with these companies. In these situations, the IMT will give preference to and select a mutual fund or ETF from one of the Primary Fund Families. If a mutual fund or exchange traded fund 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. 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 that is a feature of First Command’s investment philosophy for meeting client needs. In addition, First Command participates in regular due diligence meetings with representatives of the Primary Fund Families that allows First Command Advisors to receive the most up-to-date information about the investment products offered. This close business relationship allows First Command to directly work with the fund managers and administrators to address client concerns and needs. First Command 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 First Command clients generally. First Command Advisors generally have a greater degree of familiarity with investment products from the Primary Fund Family Partners. Invesco, Fidelity Advisor, Amundi Pioneer, Franklin Templeton, and Blackrock also pay First Command Brokerage Services, Inc. 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. (For more information on revenue sharing and marketing service support fees, please see the above section on “Revenue Sharing” and “Sponsorship Payments for Training, Education and Due Diligence Events and Marketing Support Service Fees.”) As mentioned above, Pershing also offers First Command access to its NTF 10  Program. As part of the NTF Program, Pershing waives transactions fees that it, and First Command, would otherwise charge the client for purchases and sales of certain mutual funds available on Pershing’s platform. Instead of charging a transaction fee, these funds generally have higher internal fees and expenses, than a similar, non-NTF Program fund. Such fees and expenses negatively impact the performance of the fund over time. Depending on how long you remain invested in a fund that participates in the NTF Program fund, you may pay more in fees than you would if you had invested in a non-NTF Program fund, even though there was no transaction charge on the purchase. Higher internal expenses will reduce investor returns. Not paying transaction fees for certain mutual funds that participate in the NTF Program presents a conflict of interest because it reduces First Command’s costs for administering the AMS Program and increases First Command’s revenue for the AMS Program. In addition, certain mutual funds, index funds or ETFs may also impose short-term redemption fees for sales of funds that occur prior to the specified period as outlined in the prospectus. All mutual funds that will be held in the AMS Program are sold under prospectus where the various share classes and internal fees are outlined. The Firm strongly encourages you to review the fund prospectus. Choosing Mutual Fund Share Classes First Command’s IMT strives to choose the share class that serves our clients’ best interests. The appropriate share class will be chosen from among share classes for which the AMS Model Portfolios are eligible, after considering the underlying expense ratio, transaction fees, and redemption fees of the share class. First Command will generally select the share class that does not charge transaction fees and has historically experienced the lowest expense ratio from among the share classes that it is eligible to purchase at the Model Portfolio level. 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 First Command may be ineligible to purchase such share class at the Model Portfolio level due to the requirements of the mutual fund or the mutual fund’s distribution guidelines or a lower cost share class would charge transaction fees, and this would cause First Command’s overall expenses for administering the AMS Program to increase. You may be eligible to purchase such share class outside of the AMS Model Portfolio. All accounts in an AMS Model Portfolio will use the same share class to maintain the efficiency of the AMS program. The IMT will select the most appropriate share class that all clients in an AMS Model Portfolio are eligible to purchase as opposed to selecting the share class by individual account. 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 an AMS Model Portfolio. For similar reasons, you may be eligible to purchase certain share classes for a particular mutual fund outside of the AMS Model Portfolio that may experience lower expenses than the share class used for such fund in an AMS Model Portfolio. Choosing ETFs First Command may limit the percentage of ETFs in an individual’s asset allocation model to 35% of the total portfolio. This limitation is based on the clearing and custodial agreement between Pershing and First Command’s affiliated broker-dealer, First Command Brokerage Services, Inc. This 35% limitation is designed to keep the costs of administering the AMS Program lower because the purchase and sale of ETFs have transaction fees, which, if incurred, would increase the costs of administering the AMS Program. Keeping the costs for administering the AMS Program lower ultimately allows First Command to charge clients more reasonable advisory fees. Execution of Trades First Command Brokerage Services, Inc. executes trades as a block for the benefit of all accounts invested in a particular AMS Model Portfolio. Given the large transaction size and percentage of holdings of certain mutual funds within an AMS Model Portfolio, it may take an extended 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. 11  Opening a New Account in the AMS Program The process to open a new account in the AMS program begins with you and your Financial Advisor completing an new account agreement. This agreement, along with your initial deposit (if a check made payable to Pershing LLC) or transfer instructions, is then sent to our Home Office in Fort Worth, TX 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 48 business hours from this point and provided 80% of the account minimum is reached ($16,000 for Foundations or $40,000 for SIP), Pershing LLC will initiate the necessary transactions to invest your funds in line with the Model Portfolio you have chosen. (If 80% of the account minimum is not deposited in the account, your assets will remain in a cash equivalent position until such time as this threshold is met. Additional information regarding AMS 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 AMS account and potentially affect the return of your investment. Assets Transferred In Kind into an AMS Account Any assets which are transferred into a new AMS account in kind will be sold only once 80% of the account minimum is reached ($16,000 for Foundations or $40,000 for SIP). The proceeds will then be invested into the Model Portfolio you have chosen. Selling these assets will be a taxable event in non-tax qualified accounts. Liquidating Funds from Your AMS 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 First Command 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 will process your request and send it to Pershing LLC no later than the next business day. Within 48 business hours of receipt of your request from First Command Brokerage Services, Inc., Pershing LLC 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. 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 being sold to comply with your liquidation request and potentially affect the profitability of your investment. II. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Minimums The minimum initial investment requirement to participate in Foundations is $20,000 per registration type and the minimum initial requirement to participate in SIP is $50,000 per registration type. If the minimum initial investment amount is not met within 90 days of account opening, we reserve the right to: (1) terminate your IMA, liquidate your account, and send the proceeds to you; or (2) convert your account from SIP to Foundations depending on the account balance at that time. 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. Liquidating your account or converting your account from SIP to Foundation 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 First Command’s sole discretion. Subsequent investments shall not be less than $100. In the event that account assets are reduced due to client withdrawals to less than the account minimum, we will notify you and you will have 30 days from the date such notice is sent to restore the account assets to meet the account minimum. If you fail to restore the account assets to the minimum within the 30-day period, we reserve the right to: (1) terminate your IMA, liquidate your account, and send the proceeds to you; or (2) convert your account from a SIP account to a 12  Foundations account, depending on the account balance. Liquidating your account or converting your account from SIP to Foundations may result in a taxable event and/or a higher wrap fee. 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. Types of Clients The AMS program is open to individuals, corporate entities and trusts only. We do not do business with pension plans, investment companies or institutional clients. III. PORTFOLIO MANAGER SELECTION AND EVALUATION The IMT serves as the portfolio manager of the AMS program. Performance for individual AMS accounts is calculated by Pershing LLC, the custodian of assets for the AMS program. Performance for Model Portfolios is calculated by the IMT using Morningstar Direct. Performance of Model Portfolios is measured against customized blended benchmarks chosen by the IMT, which are reviewed and approved by Investment Oversight Committee (“IOC”). First Command does not use a third-party to review its performance information. First Command relies on the calculations made by Pershing LLC for performance of individual AMS accounts and Morningstar Direct for performance of Model Portfolios. All members of the IMT are salaried employees of First Command Financial Services, Inc., the parent company of First Command Advisory Services, Inc. First Command does 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, First Command maintains policies and procedures to eliminate and/or mitigate conflicts of interests. If a conflict of interest does arise that cannot be eliminated, First Command will seek to mitigate such conflict and disclose it to you. Further, as part of its policies and procedures, First Command 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 First Command Financial Services, Inc. Members may be added or removed from the IMT or the IOC whenever the principal executive officers of First Command Financial Services, Inc. determine that such changes are in the best interests of the AMS program and clients. Other Advisory Services In addition to our AMS program, we offer our clients personalized investment advisory services and financial planning services through our Tailored Professional Services (“TPS”) program. TPS program clients are entitled to personalized investment advisory services and financial planning services from us for a term of 12 months. The initial 12-month term begins on the date that the client signs an Investment Advisory Agreement. The following services are included as part of 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 the initial term of service. ▪ An updated written financial plan during any renewal term in which a TPS client reports a material change to the client’s circumstances. ▪ Reasonable personal or telephone access to the Advisor for continued financial advice. ▪ Periodic financial reviews or “progress meetings” with an Advisor within the Service Period. When appropriate, and with the client’s consent, bringing together other professionals into a “deliverables team” to provide more complete service. This may include a CPA/accountant, tax analyst, estate planner, attorney, real estate specialist and/or financial product specialist. Note: The TPS fee does not cover fees charged by other professionals on the deliverables team who will bill separately for their services. In addition to the above services, we will also provide TPS clients with other advisory services based upon the client’s specific situation and needs. At the beginning of the initial term, as well as at each 13  renewal term, each TPS client and the client’s Advisor will discuss the services expected to be provided during the term when negotiating the fee for that term. In order to provide clients with TPS, our Advisors will gather detailed information from the client to determine the client’s existing financial condition, attitudes, goals, risk tolerance and planning horizon. We rely on the client to provide us with the client’s complete financial situation, goals and needs, as well as any updates to the client’s situation. Any financial plan and/or other recommendations prepared for a TPS client will address the client’s current financial circumstances and goals and will be based on the information the client provided on questionnaires, documents and during interviews with the client’s Advisor. We will work collaboratively with each TPS client and encourage them to be an active participant in all discussions related to the advisory services we provide. In addition to financial planning services, TPS clients will also receive recommendations for specific products. Any recommendations for AMS accounts will be provided by First Command Advisory Services, Inc., in its capacity as an investment adviser. Any recommendations for transactions in investment brokerage products will be provided to you by First Command Brokerage Services, Inc., in its capacity as a broker-dealer. First Command Brokerage Services, Inc.’s product offerings include mutual funds, variable annuities, variable life insurance, and Section 529 Plans. First Command Brokerage Services, Inc.’s recommendations will generally be limited to these types of investments only. For mutual fund investments, First Command Brokerage Services, Inc. will typically make recommendations for new accounts from the following mutual fund families: Fidelity Advisor Funds, Franklin Templeton Investments, Invesco, Ltd, Amundi Pioneer Investments, Massachusetts Financial Services Company, Blackrock, and American Funds. For variable annuities, First Command Brokerage Services, Inc. will make recommendations for new contracts from the following insurance carriers: Equitable (AXA); Lincoln National Life Insurance Company; and Brighthouse Securities, LLC (formerly MetLife). For variable life insurance, First Command Brokerage Services, Inc. will make recommendations for new contracts from the following insurance carrier: Lincoln National Life Insurance Company. On a limited basis, First Command Brokerage Services, Inc. may also effect transactions in individual equites, exchange traded funds exchange- traded funds or bonds/debt instruments. Any recommendations for insurance products will be provided by First Command Insurance Services, Inc., an insurance general agent. No part of the advisory fee charged to you is for recommendations related to insurance. Any recommendations for banking products and services (including Investment Management Accounts) will be provided by First Command Bank. You determine whether to implement any of the recommendations provided to you and are under no obligation to purchase any product or service through First Command Advisory Services, Inc. or its affiliates. Risk is inherent in investing and therefore we do not guarantee future financial results as a result of your implementation of any of the recommendations we make to you. Additional information about the Tailored Professional Services program is available in our Description of Services brochure (i.e., Form ADV, Part 2A brochure). You may request a copy of our Description of Services brochure by contacting your Advisor, calling First Command’s Home Office at 800.443.2104 (overseas, call 817.731.8621), or visiting www.firstcommand.com. If you participate in the AMS program, First Command will manage and periodically rebalance your account assets consistent with the asset allocation for your chosen Model Portfolio. First Command does not monitor AMS accounts on an individual basis. First Command also will not monitor any other types of accounts, including those held by clients who participate in its TPS program. First Command and your Advisor share the wrap fee charged to you if you participate in the AMS program. First Command and your Advisor share the TPS fee charged to you if you participate in the TPS program. If you invest in non-advisory products brokered by First Command Brokerage Services, Inc., First Command Brokerage Services, Inc. and your Advisor will be compensated via commissions and/or sales commissions and other third-party payments from the applicable investment and/or insurance company. 14  Assets Under Management As of September 30, 2023, First Command Advisory Services, Inc. manages 17.8 billion on a discretionary basis as part of its AMS 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. Methods of Analysis, Investment Strategies and Risk of Loss The IMT conducts the firm’s due diligence on investment products offered to our clients and manages the day- to-day decisions for the Model Portfolios in the AMS program. Information about the IMT is included in Section II of this brochure. First Command requires the IMT to follow a disciplined approach in researching current and potential investments, with decisions based on: ▪ Philosophy. We are biased toward 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. Additionally, we complement these managers with exposures to low-cost passive index funds and ETFs. ▪ Process. We demand 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 our clients’ assets 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. 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 Advisor will be successful or that your investment objectives will be met. Investment advice or financial planning recommendations provided by us or any Advisor are largely a matter of professional judgment, and neither us nor any 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 with reasonable care. Investing in securities involves risk of loss. The sources of information used by the IMT 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. The actual risks associated with the investments selected 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 (the fund manager or portfolio manager controls the buying and selling as well as the timing of those trades); and (3) price uncertainty (the price at which you purchase or redeem shares of a mutual fund will depend on the fund's NAV, which may not be calculated until many hours after you have placed your order, and the market price of an ETF’s shares may fluctuate with the market and may differ from its NAV). 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 considered. A mutual fund or ETF in a Model Portfolio may be replaced at any time the IMT determines it no longer meets the requirements of a Model Portfolio. Reasons for replacement may include change of investment objective, discretionary strategy, manager, or fund performance. 15  Voting Client Securities For AMS accounts, we maintain a Proxy Voting Policy which reflects our duty as a fiduciary to vote proxies in your best interest. First Command currently subscribes to advisory and other proxy voting services provided by an independent proxy voting service provider, Glass, Lewis & Co. (“Glass Lewis”). First Command has delegated proxy voting for AMS clients to Glass Lewis. In the event of a material conflict of interest that is not otherwise addressed through our Proxy Voting Policy, we will notify you of the conflict and the actions we will take to address the conflict. 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: SVP, Chief Investment Officer Attn: Proxy Voting Policy 1 FirstComm Plaza, Fort Worth, TX 76109-4999 You may also write to the above address if you desire to direct a vote in a particular solicitation. IV. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS First Command’s IMT is responsible for managing the Model Portfolios in the AMS program. They do not, however, possess knowledge of your individual information or investment goals and objectives and do not provide investment advice directly to you. V. CLIENT CONTACT WITH PORTFOLIO MANAGERS Any questions regarding the management of the AMS program or your account should be directed to your Advisor or First Command’s Home Office at 1-800-443-2104. If you are outside the U.S., call 817-731- 8621.ADDITIONAL INFORMATION Disciplinary Information First Command Advisory Services, Inc. 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., First Command Bank, and First Command Europe Ltd. First Command Brokerage Services, Inc. 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 LLC, its clearing firm, or held in accounts directly with the issuer of the securities purchased. First Command Brokerage Services, Inc. is a member of the Financial Industry Regulatory Authority (“FINRA”). First Command Brokerage Services, Inc. is authorized to conduct business in all 50 states, the District of Columbia and Guam. It is also a member of the Securities Investor Protection Corporation (“SIPC”) and the Municipal Securities Rulemaking Board (“MSRB”). First Command Insurance Services, Inc. is a life insurance general agency. Insurance products and services are offered by First Command Insurance Services, Inc. Insurance product offerings include life insurance; long term care insurance; disability income insurance; and annuities. First Command Bank is a federally chartered savings and loan association and a member of the Federal Deposit Insurance Corporation (FDIC). Personal banking products and services offered by First Command Bank include checking and savings accounts, money market accounts, certificates of deposit, mortgage loans, automobile 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 First Command Bank include commercial checking accounts, money market savings accounts, commercial loans, business credit and debit cards and online banking services. 16  Our Advisors are investment adviser representatives for First Command Advisory Services, Inc., registered representatives for First Command Brokerage Services, Inc. and insurance agents for First Command Insurance Services, Inc. Our Advisors will also receive support fees from First Command Bank in recognition of their efforts to promote your banking relationship with First Command Bank. In Europe, investment and insurance products and services are offered through First Command Europe Ltd. First Command Europe Ltd. is authorized and regulated by the Financial Conduct Authority (FCA) and is bound by the FCA’s rules and regulations in the conduct of its business. First Command Europe Ltd.’s FCA register number is 482323 and its head office is located at: Unit 4, Wallis Court, James Carter Road, Mildenhall, Bury St. Edmunds, Suffolk, IP28 7DD. You may check First Command Europe Ltd.’s authorizations with the FCA at www.fsa.gov.uk/register/home.do, by calling the FCA at 0845 606 1234, or by writing to the FCA at 25 The North Colonnade, Canary Wharf, London, E14 5HS. Certain investment and insurance products offered in the United States may not be available in Europe. We recognize there is a conflict of interest when offering investment advisory services while our affiliates are also being compensated for the sale of brokerage, insurance and banking products. This conflict is disclosed to you in this brochure. First Command maintains policies, procedures, supervision systems and other measures to help mitigate this conflict of interest. Code of Ethics, Participation or Interest in Clients Transactions and Personal Trading First Command has adopted a Code of Ethics that sets forth the ethical standards of business conduct that we require of our employees and Advisors. Our Code ensures our compliance with applicable Federal Securities Laws, regulatory oversight, enforcement and recordkeeping provisions. A copy of our Code of Ethics is available to any client or prospective client upon written request to: Chief Compliance Officer Attn: First Command Code of Ethics 1 FirstComm Plaza, Fort Worth, TX 76109-4999 First Command, its parent company and affiliates participate in many of the same securities we recommend to you for their corporate holdings and their retirement plans maintained for employees. In all instances, the positions these companies maintain are small enough to have no impact on the pricing or performance of the security. First Command, its parent company and affiliates do not buy from, sell to, or otherwise enter into transactions for securities with clients or client accounts. Brokerage Practices First Command Advisory Services, Inc. will recommend its affiliate First Command Brokerage Services, Inc. for all brokerage transactions. For transactions in AMS accounts, we will submit your trade to First Command Brokerage Services, Inc., as the introducing broker-dealer. Pershing LLC is the custodian of assets and executes and settles all trades for AMS accounts pursuant to its clearing agreement with First Command Brokerage Services, Inc. Pershing LLC and First Command Brokerage Services, Inc. are not affiliated entities of each other. Pershing LLC is a subsidiary of BNY Mellon and a member of the Securities Investor Protection Corporation (SIPC®). Pershing LLC will mail you a disclosure statement with important information about itself and its clearing agreement with First Command Brokerage Services, Inc. upon account opening. You may also visit Pershing LLC’s website at www.Pershing.com. You may not choose to use a broker-dealer other than our affiliate First Command Brokerage Services, Inc. for transactions in our AMS program. You may also not choose a custodian of assets other than Pershing LLC. We reserve the right to change the custodian of assets and will notify you in the event of such a change. Your investment in each Model Portfolio you select will be held in a separate brokerage account maintained by Pershing LLC. Mutual fund shares are issued in “book” form, meaning that a certificate of ownership is not issued, although the shares remain assets held within your Model Portfolio account. 17  As noted above, trading will occur through the brokerage accounts established with Pershing LLC. The IMT will initiate trades at their discretion. Pershing LLC ensures best execution of trades. Review of Accounts The IMT will periodically rebalance your AMS account assets consistent with the asset allocation of your selected Model Portfolio. A rebalancing review will be conducted periodically. The IMT may time the rebalancing to allow for payment of fees, estimated taxes or withdrawals prior to rebalancing. This rebalancing will be accomplished by selling the over-weighted investment assets and purchasing corresponding dollar amounts of underweighted investment assets. Rebalancing is effected through the sale and purchase of securities in your account, which may have tax ramifications for you based on the transactions that result. A mutual fund or ETF may also be replaced at any time the IMT determines it no longer meets the requirements of a Model Portfolio. Reasons for replacement may include change of investment objective, discretionary strategy, manager, or fund performance. We recommend that all clients meet with their Advisor on at least an annual basis for a review. During reviews, your personal financial information will be updated. We may recommend more frequent reviews depending on your particular situation or if a periodic review raises questions about your portfolio. You should contact your Advisor any time a material change in your circumstances occurs which might affect the way your assets should be invested. A revised recommendation will be made, if appropriate. Account statements will be provided to you in writing or electronically on at least a quarterly basis. 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. Unless you notify us within 30 days, we will not be responsible for any unauthorized transactions or other errors in your account. 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) and our Tailored Professional Services program (see our Description of Services brochure, i.e., our Form ADV Part 2A brochure). We also do not pay fees to other parties for client referrals. Custody We do not have custody of your assets. Pershing LLC (Member FINRA, SIPC) is the custodian of assets and executes and settles all trades for AMS accounts. Pershing LLC will send you statements on at least a quarterly basis. Investment Discretion For the AMS program, we will exercise our discretion as granted by you in the IMA. Neither you nor First Command Advisory Services, Inc. may transact in Foundations or SIP account other than as described in the IMA. However, the IMA does allow 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. ▪ You may direct that the payment of lump sum withdrawals be from the investment assets instead of from the cash equivalent position within your account. ▪ 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.) ▪ You may direct that a particular sum be held in a cash equivalent position for a specified period of time. You should consult with your Financial Advisor prior to imposing these restrictions. 18  Other than by choosing your Model Portfolios and as described above and in the IMA, you may not place other restrictions on investing in your account, including imposing restrictions on investing in certain securities or types of securities. Financial Information First Command 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. VI. BROCHURE SUPPLEMENTS FOR OUR INVESTMENT MANAGEMENT TEAM First Command Advisory Services, Inc. 1 FirstComm Plaza, Fort Worth, TX 76109 Phone: 800.443.2104. This brochure supplement is dated December XX, 2023 This Brochure supplement provides information about First Command’s IMT and supplements the First Command Description of Services Brochure (“DOS”). Please contact our Home Office at 800.443.2104 if you did not receive a complete copy of the DOS 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. Educational Background and Business Experience MATT WILEY, CFA Year of Birth: 1981 Education: Florida Atlantic University, Boca Raton, FL .................................... 2007 B.B.A., Management and Marketing Nova Southeastern University, Fort Lauderdale, FL ....................... M.B.A., Finance Chartered Financial Analyst* ......................................................... 2011 Employment: First Command Advisory Services, Inc .......................................... 5/2020 – Present Vice President, Investments DFW Airport Interfaith Chaplaincy ................................................. 1/2013 – Present Treasurer/Chair of Finance Committee PlainsCapital Bank ........................................................................ 2/2009 – 5/2020 SVP, Director of Portfolio Management WILLIAM SAGER, CFA Year of Birth: 1984 Education: Texas Christian University, Fort Worth, TX .................................... 2007 B.B.A., Finance and Accounting Chartered Financial Analyst* ......................................................... 2012 Employment: First Command Advisory Services, Inc .......................................... 3/2018 – Present Associate Director of Portfolio Management Frenkel Benefits, LLC .................................................................... 4/2016 – 8/2017 Account Manager – Retirement Services Noise4Good, LLC ......................................................................... 7/2014 – 12/2015 19  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 WILLIAM HAYNES, CFA, CIPM, CPA Year of Birth: 1969 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 Certificate in Investment Performance Measurement*** ................. 2022 Employment: 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 DANIEL B. MURPHY, CFA Year of Birth: 1967 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 Chartered Financial Analyst* ......................................................... 1999 Employment 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 REEDER MENGWASSER Year of Birth: 1997 Education: Texas A&M University, College Station, TX ................................... 2019 B.B.A. Employment: First Command Advisory Services, Inc .......................................... 5/2018 – Present Investment Analyst 20  MATTHEW D. CONNER , CFA Year of birth: 1987 Education: Virginia Commonwealth University, Richmond, VA ........................ 2005 B.S. John’s Hopkins University, Baltimore, MD ..................................... 2018 M.S., Applied Econometrics Chartered Financial Analyst*. .............................................................. 2022 Employment: 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 ROBBIE DAFFRON Year of Birth: 2000 Education: University of North Florida, Jacksonville, FL .................................. 2021 B.B.A. University of North Florida, Jacksonville, FL .................................. 2023 M.B.A. (In Progress) Employment: First Command Advisory Services, Inc .......................................... 1/2022 – Present Investment Analyst The IMT is supervised by Matt Wiley, Director of Investments. Matt Wiley’s information is provided above. Matt Wiley reports to John Weitzer, SVP, Chief Investment Officer. JOHN S. WEITZER, CFA Year of Birth: 1967 Education: Marquette University, Milwaukee, WI ............................................. 1990 B.A. Marquette University Law School, Milwaukee, WI .......................... 1993 J.D. Chartered Financial Analyst* ......................................................... 2003 Employment: First Command Advisory Services, Inc .......................................... 1/2017 – Present SVP, Chief Investment Officer Wells Fargo .................................................................................. 7/2005 – 12/2016 Wealth Advisor, SVP *The Chartered Financial Analyst 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 21  80 hours over a two-year period or 120 hours over a three-year period). Additionally, all 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™ designation (CIPM®). The CIPM program 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. Disciplinary Information None of the persons listed above have been subject to any reportable legal or disciplinary events. Other Business Activities None of the persons listed above receive compensation from business activities outside of First Command Advisory Services, Inc. Members of the IMT are employees of First Command Financial Services, Inc., the parent company of First Command Advisory Services, Inc. and First Command Brokerage Services, Inc. They are compensated by salary, bonus and other employee benefits. They may be registered through First Command Advisory Services, Inc. as investment adviser representatives and/or First Command Brokerage Services, Inc. as broker-dealer registered representatives. However, they do not receive a portion of the annual wrap fee charged to AMS accounts or commissions based on the sale of securities or other investment products. Additional Compensation None of the persons listed above receive compensation for providing advisory services from sources other than First Command Advisory Services, Inc. Supervision Our IMT serves as the portfolio manager for all Model Portfolios within the AMS program. They are responsible for managing and continuously reviewing the investments within the Model Portfolios. A mutual fund or exchange traded fund may be replaced at any time the IMT determines it no longer meets the requirements of a Model Portfolio. Reasons for replacement may include change of investment objective, discretionary strategy, manager, or fund performance. First Command’s IOC is responsible for overseeing changes to the Model Portfolios made by the IMT. Members of the IMT and IOC are chosen by the principal executive officers of First Command Financial Services, Inc. Members may be added or removed from the IMT or the IOC whenever the principal executive officers of First Command Financial Services, Inc. determine that such changes are in the best interests of the AMS program and clients. The persons listed above report directly to John S. Weitzer, Senior Vice President, Chief Investment Officer. You may contact John S. Weitzer at 800.443.2104. His education and employment information is provided above. Our Financial Advisors Your First Command 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. 22  VII. 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. 23